RE: C-Tick importer variation
Koh, To expand on Dick Shultz's comments, the importer is ultimately responsible for ensuring compliance with EMC in Australia (Compliance Folder, DoC etc). You can work in both ways you outlined in your original questions: a) leave the original N555 label on providing you take certain measures; or b) have the N123 label put on. For a) above you would need to follow the basic procedure outlined by Dick but I would clarify this by the following. Providing agreement is gained, in writing, from another organisation already importing the same product into Australia that they will act as agent for your organisation in terms of responsibility for EMC compliance of the product (maintain the Compliance Folder, sign the DoC etc) this is acceptable. You need to keep a copy of the written agreement. You are not required to complete a DoC. Any changes to the product (brand name, model etc or change in engineering design) are acceptable PROVIDING those changes are clearly addressed (explained and continued compliance justified) in the Agent's Compliance Folder AND DoC. If the name change of model change or engineering change is not specifically covered by the test reports etc then the normal method is as Dick suggested, ie provide a signed attestation confirming your product is the same etc. This would also be done by the Agent. As you can see, by agreement to act as Agent that organisation is assuming full responsibility for that product's compliance in Australia, when sold by your organisation. For b) above, your organisation would be responsible for all compliance issues if your label is on the product (ie N123). This means the Compliance Folder, DoC etc. These must all be established and maintained by your organisation. In this instance you would normally gain agreement from the supplier/manufacturer that they can provide you with test reports etc for inclusion in your Compliance Folder. If because a a name change for your particular organisation etc or different model numbers were used to those detailed in the test report then your organisation would require, for inclusion in your Compliance Folder, a signed attestation from the supplier/manufacturer that the products you will be selling are the same as those tested etc. As with all issues regulatory, everywhere, it is always the finer points and subtleties of the legislation/regulation which give rise to questions! Product Variations The documentation in the Compliance Folder must identify the product in question. As such, if the product name or model number is different to that detailed in the test report or the product is modified etc AND providing those changes do not adversely impact the EMC characteristics of the device, a signed attestation to that effect is all that is required to be included in the Compliance Folder. Hope this helps. Best regards, Kevin Sender: owner-emc-p...@majordomo.ieee.org Received: from ruebert.ieee.org (ruebert.ieee.org [199.172.136.3]) by hil-img-3.compuserve.com (8.8.6/8.8.6/2.18) with ESMTP id PAA15217; Tue, 2 Mar 1999 15:52:20 -0500 (EST) Received: by ruebert.ieee.org (8.8.8/8.8.8) id PAA25508; Tue, 2 Mar 1999 15:49:58 -0500 (EST) Message-Id: 9903022053.aa18...@ibmserver.admin.brooktrout.com Subject: RE: C-Tick importer variation Date: Tue, 2 Mar 1999 15:51:24 -0500 X-Sender: r...@nhmail1.brooktrout.com X-Mailer: Claris Emailer 2.0v3, January 22, 1998 From: Dick Shultz r...@brooktrout.com To: koh...@cyberway.com.sg, emc-p...@ieee.org Mime-Version: 1.0 Content-Type: text/plain; charset=US-ASCII Sender: owner-emc-p...@majordomo.ieee.org Precedence: bulk Reply-To: Dick Shultz r...@brooktrout.com X-Resent-To: Multiple Recipients emc-p...@majordomo.ieee.org X-Listname: emc-pstc X-Info: Help requests to emc-pstc-requ...@majordomo.ieee.org X-Info: [Un]Subscribe requests to majord...@majordomo.ieee.org X-Moderator-Address: emc-pstc-appro...@majordomo.ieee.org Koh, You can continue to import product with the N555 code on it if your importer (N123) has a written agreement with importer N555 to do so. Your importer will need to maintain this letter in his files for ACA audits. I know that this has come up recently and that the ACA has accepted this procedure, in fact they have required it. Check with them. Dick Shultz On 3/2/99 8:36 AM WOODS, RICHARD wo...@sensormatic.com said OEM devices may be imported by more than one company. Each importer is responsible for filing their own application, having their own approval, applying the c-tick mark, and issuing a DoC. One importer cannot use the markings of another importer. Either the OEM or the importer may apply the label. Each importer can use the test data from the OEM. If the model number on the product differs from the one on the test report, the OEM should issue a declaration of identity stating that the two products are identical. -- From: kohscp [SMTP:koh
C-Tick importer variation
Hi, I have a doubts here regarding the Australia EMC framework. Electronic products importing into AS/NZ requires to comply to EMI (emission) requirement and the respsonble party need to declare the DoC. He would need to hold the DoC with supporting documents. Test reports from recognise test house would be preferred. Let narrow down to the following assumption. The electronic product does not have connection to telephone network and no AC power input. The responsible party be an importer. And all products from my company is imported thru them. The test house is either NATA accredited or having MRA with NATA accreditation. The C-Tick mark is having supplier code used on the label. Now the situation is that our importer has registered with ACA(say having N123). We are purchasing/OEM products from supplier A. The supplier A is having their Australian importer (say N555) on the product label. What are my options for importing the product into AS/NZ in respect to which supplier code to use. Questions: 1) Are we allow to use N555? If yes, what documents, proof or/and letters do we need from the supplier? 2) Do our importer needs to declare the DoC? 3) If we are requesting the supplier to change the brandname on the product label, is N555 still applicable? How about change of model # too? 4) If we are to remove N555 on the product and use N123, is re-testing required? 5) If there's product non-conformance found in the market, who will be the responsible one? Who would be audited, and for worst case, who would be fine? Your feedback/advice is much appreciated. Regards Koh - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
RE: C-Tick importer variation
Koh, You can continue to import product with the N555 code on it if your importer (N123) has a written agreement with importer N555 to do so. Your importer will need to maintain this letter in his files for ACA audits. I know that this has come up recently and that the ACA has accepted this procedure, in fact they have required it. Check with them. Dick Shultz On 3/2/99 8:36 AM WOODS, RICHARD wo...@sensormatic.com said OEM devices may be imported by more than one company. Each importer is responsible for filing their own application, having their own approval, applying the c-tick mark, and issuing a DoC. One importer cannot use the markings of another importer. Either the OEM or the importer may apply the label. Each importer can use the test data from the OEM. If the model number on the product differs from the one on the test report, the OEM should issue a declaration of identity stating that the two products are identical. -- From: kohscp [SMTP:koh...@cyberway.com.sg] Sent: Tuesday, March 02, 1999 12:08 AM To: emc-p...@ieee.org Subject: C-Tick importer variation Hi, I have a doubts here regarding the Australia EMC framework. Electronic products importing into AS/NZ requires to comply to EMI (emission) requirement and the respsonble party need to declare the DoC. He would need to hold the DoC with supporting documents. Test reports from recognise test house would be preferred. Let narrow down to the following assumption. The electronic product does not have connection to telephone network and no AC power input. The responsible party be an importer. And all products from my company is imported thru them. The test house is either NATA accredited or having MRA with NATA accreditation. The C-Tick mark is having supplier code used on the label. Now the situation is that our importer has registered with ACA(say having N123). We are purchasing/OEM products from supplier A. The supplier A is having their Australian importer (say N555) on the product label. What are my options for importing the product into AS/NZ in respect to which supplier code to use. Questions: 1) Are we allow to use N555? If yes, what documents, proof or/and letters do we need from the supplier? 2) Do our importer needs to declare the DoC? 3) If we are requesting the supplier to change the brandname on the product label, is N555 still applicable? How about change of model # too? 4) If we are to remove N555 on the product and use N123, is re-testing required? 5) If there's product non-conformance found in the market, who will be the responsible one? Who would be audited, and for worst case, who would be fine? Your feedback/advice is much appreciated. Regards Koh - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). - This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: unsubscribe emc-pstc (without the quotes). For help, send mail to ed.pr...@cubic.com, j...@gwmail.monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).