Hello all,

 

I'm working with a company who are importing some IT products from China to
the EU. The Chinese manufacturer is taking a very much "hands off" approach
to approvals, expecting the importer to draw up the DoC and perform much of
the testing. However access to the parts of the Technical File that detail
product construction are being held by the manufacturer and getting access
to these is not straightforward.

 

My question is: provided that all the documentation boxes are ticked and the
product has been sufficiently assessed, can one reasonably take on
responsibilities for other actors in the supply chain in this manner?

 

I'm undecided if this is acceptable. My feeling is that whilst it is not to
the letter of the law, it is to the spirit and would be acceptable depending
on the importers tolerance to risk. However the letter of the directives is
explicit in determining responsibilities e.g. that the manufacturer shall
draw up the DoC.

 

I would be interested to hear your thoughts on the matter.

 

Thanks and all the best

James


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