Long story short. They are trying to directly tie down the blame here. A statement that the declaration is issued under the sole responsibility of the manufacturer (so don't blame the lab or the distributor (or even an outside contract designer) Signed for and on behalf of - the CEO doesn't get to claim plausible deniability you are signing this for him.
If you have the list and the statements about who signed the document and under whose authority you still haven't said anything about whether or not you meet any of the actual requirements - just that you legally wrote them down. What I'm surprised by is that a statement is required that says something on the order of I attest that the requirements of the list were fulfilled - in other words I didn't just write down some directive numbers I'm telling you I comply with them. To be a witness in a court in the United States you have to attest to three things actually Do you promise to: * Tell the truth (bold faced lies are not acceptable) * The whole truth ( you can't lie by omission) * Nothing but the truth (you can't tell the truth Interestingly enough the officers of the court prosecution and defense lawyers don't have to take the same oath about their questions. Did you quit beating your wife. A half truth question with no winnable yes, or no answer. Assuming you aren't a wife beater so you answer no, then the impression is that you continue to beat your wife. If you answer yes, the impressions is that you are a recovering wife beater. From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Thursday, August 20, 2015 12:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] New EMCD DoC Requirements To All, It is strange how the simplest things seem to take up the bulk of my time. Once again we are looking at the information required on the Declaration of Conformity. We are trying to determine if the New EMC Directive will force our current DoC format to change from what we currently have. Changes in the DoC format can be costly to some companies and requires re-translations into 20+ languages. Please review the 2014/30/EU, Annex IV: I do not understand the new way this annex is trying to convey what it wants on the DoC. For instance, points 1, 2, 4,6, & 7 seems like just a list of information they want on the DoC. But points 3, 5, and 8 seems like a "Statement" or text that we are supposed to quote on the DoC. Is this how you read it? For example, point 3 says, "." The Blue Guide says, "A statement that the declaration is issued under the sole responsibility of the manufacturer." So the guide would seem to imply that this "Statement" is required. Is it? Point 5 is also written as a Statement, yet the Blue guide says nothing about a statement. Only that we list the harmonized standards and dates. And lastly, point 8 says, "Signed for and on behalf of . . . . . :" Again, is this a statement we are required to place in the DoCs? If these are "Statements" which we have to specifically quote on the DoCs, are any of the other points required text and I'm not reading them correctly? For instance, it is ok that I have our company's name and address or do I have to prefix it with "Name and Address of the Manufacturer:"?? Thanks in advance for any help you can provide. Because of the time it takes to change the DoC format and the cost of translations, we try to keep the unnecessary text to a minimum. The Other Brian ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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