You may if under RED and the manufacturer is not in the EU. The Blue Guide is helpful in this regard.
Dan On Thu, Mar 21, 2019 at 10:29 AM Scott Xe <scott...@gmail.com> wrote: > Only require mfr/importer name and address apart from trade mark. Do we > need EU AR too? > > > > Rgds, > > > > Scott > > > > *From:* Dan Roman <00000d75e04ed751-dmarc-requ...@listserv.ieee.org> > *Sent:* Thursday, 21 March 2019 10:28 AM > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* Re: [PSES] Postal address on product labelling... > > > > Feel the pain like everyone else. Gets to be even more fun when you are > under RED and the manufacturer, importer, and authorized rep are all needed > on the label because the tax laws in Europe do not line up with the > Directives and Legal picks different company entities for each. Now throw > in Brexit and I’ll probably have a fourth address! Legitimately running > out of room!!! > > > > Dan > > > > *From:* Brian Kunde [mailto:bkundew...@gmail.com <bkundew...@gmail.com>] > *Sent:* Wednesday, March 20, 2019 10:19 AM > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* Re: [PSES] Postal address on product labelling... > > > > The companies I have worked for over the last 40 years have relied heavily > on international sales, so having your company's name and address on the > product is just part of doing business. I'm not sure what the argument is > with having your address on the product. My questions to those who > complain would be, "Why Not?". > > > > As far as the requirements of EU Directives go, keep in mind that what > they are asking for is the name and address of the responsible party for > the compliance of the instrument. The Directive refers to this legal person > or entity as the "Manufacturer", but that does not mean it is the company > who actually builds the product, thou in most cases they are one and the > same. > > > > Personally, I'm surprised that the writers of the EU Directives, the > Commission, Legal Authorities in all Countries, etc. don't require some > type of information on ALL PRODUCT, be it an address, phone number, fax > number, email address, website, etc. that provides IMMEDIATE RESPONSE from > the responsible party or at least within 48 hours. AND the system, > whatever it is, must always be active, and only used by authorities and/or > anyone regarding a Compliance Issue or Question. Kind of like a reverse > 911 (emergency number in the States). > > > > For those of you who deal in Product Safety and RoHS where you need to > contact component manufacturers for supporting documentation knows what I'm > talking about. I hate it when you go to a company's website, fill out a > three-page on-form requesting compliance information, and then never EVER > getting a reply. OR, you call the "corporate office" for the address that > is labeled on the Nameplate of the product and IF you can get through to a > Real Live Person, you asked for the Compliance Department and the person > has no idea who to transfer you to. After being transferred to 5 potential > people you finally get ahold of something who says their products are built > in another country somewhere and they "THINK" compliance is handled by > them. Does this sound at all familiar to anyone? > > > > Once again, I'm glad I'm over the hill and gaining speed for a head-first > collision into the wall call retirement. Let you young pups figure out how > to resolve all the problems of the world. > > > > The Other Brian > > > > > > > > On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham < > char...@sulisconsultants.com> wrote: > > Matthew > > > > “But Sir, they’re not doing it” isn’t a defence in court or when you’re > equipment is stuck in customs, or a competitor has pointed market > enforcement authorities in your direction > > > > The key phrase is “…or, *where that is not possible,* on its packaging or > in a document accompanying the apparatus…..” > > > > To my knowledge there’s no guidance anywhere as to “what is possible”, so > it’s probably up to you and your lawyers 😊 > > > > Regards > > Charlie > > > > *Charlie Blackham* > > *Sulis Consultants Ltd* > > *Tel: +44 (0)7946 624317 <+44%207946%20624317>* > > *Web: **www.sulisconsultants.com* > <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> > > Registered in England and Wales, number 05466247 > > > > *From:* Matthew Wilson <matthew.wil...@gbelectronics.com> > *Sent:* 20 March 2019 13:06 > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* [PSES] Postal address on product labelling... > > > > Does anyone else have endless arguments about the need to put a postal > address on products as per the EMC and LVD requirements? The EMC directive > obliges the following (article 7.6 of 2014/30/EU). The LVD also had the > exact same obligation (article 6.6 of 2014/35/EU); > > ?Manufacturers shall indicate, on the apparatus, their name, registered > trade name or registered trade mark and the postal address at which they > can be contacted or, where that is not possible, on its packaging or in a > document accompanying the apparatus. The address shall indicate a single > point at which the manufacturer can be contacted. The contact details shall > be in a language easily understood by end-users and market surveillance > authorities.? > > Manufacturer is, of course, meaning the entity responsible for the product > denoted by the brand name present on the apparatus. > > And every time I encounter this advice being questioned someone always > says 'But [some large entities/corporations supplying consumer products - > you can pick your own example] don't put their address on their products.' > Well they should! Maybe those devices with screens allow you to look up > the address somewhere in the operating system? > > Humph! > > Sorry just letting off steam :-) > > > ------------------------------ > > *Matthew* *Wilson* > Technical Director > > [image: Image removed by sender. GBE] <https://gbelectronics.uk> > https://gbelectronics.uk > > T: > > +44 (0)1903 244500 <+44%201903%20244500> > > F: > > +44 (0)1903 700715 <+44%201903%20700715> > > Ascot House // Mulberry Close // Woods Way > Goring-by-Sea // West Sussex // BN12 4QY // UK > > *Electronics Design // Manufacturing // Component Distribution* > > [image: Image removed by sender. ISO 9001 | ISO 14001] > <https://gbelectronics.uk/quality/standards> > > Want to send us a file? https://www.mailbigfile.com/gbelectronics > ------------------------------ > > GB Electronics (UK) Limited is a company registered in England and Wales > Company Registration No: 06210991 > VAT Registration No: GB 925 1744 25 > > Registered Office: > Ascot House, Mulberry Close, Woods Way > Goring by Sea, West Sussex, BN12 4QY > > Disclaimer: This email and any files transmitted with it are confidential > and intended solely for the use of the individual or entity to whom they > are addressed. If you have received this email in error please delete it > from your system, do not use or disclose the information in any way and > notify the sender immediately. > > The contents of this message may contain personal views which are not the > views of the company, unless specifically stated. > > - > ---------------------------------------------------------------- > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > > - > ---------------------------------------------------------------- > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > > - > ---------------------------------------------------------------- > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > > - > ---------------------------------------------------------------- > > This message is from the IEEE Product Safety Engineering Society emc-pstc > discussion list. To post a message to the list, send your e-mail to < > emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > Website: http://www.ieee-pses.org/ > Instructions: http://www.ieee-pses.org/list.html (including how to > unsubscribe) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > -- Dan Roman, N.C.E. IEEE Senior Member PSES/EMCS/CES dan.ro...@ieee.org - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
