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
