Re: [PSES] CE marking - mixture of responsibilities

[Lauren Crane]

James,

Also review current version of directives redone for the NLF (which currently 
has not touched the Machinery Directive), they all take the same approach in 
putting direct obligations on importers for issues the oem has not covered.

e.g., in EMCD






Article 9

Obligations of importers

1. Importers shall place only compliant apparatus on the market.

2. Before placing apparatus on the market importers shall ensure that the 
appropriate conformity assessment procedure referred to in Article 14 has been 
carried out by the manufacturer. They shall ensure that the manufacturer has 
drawn up the technical documentation, that the apparatus bears the CE marking 
and is accompanied by the required documents, and that the manufacturer has 
complied with the requirements set out in Article 7(5) and (6).
Where an importer considers or has reason to believe that apparatus is not in 
conformity with the essential requirements set out in Annex I, he shall not 
place the apparatus on the market until it has been brought into conformity. 
Furthermore, where the apparatus presents a risk, the importer shall inform the 
manufacturer and the market surveillance authorities to that effect.

…etc


-Lauren Crane

From: Scott Xe 
Sent: Tuesday, September 04, 2018 5:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

Hi James,

It is quite normal attitude for an oem or odm manufacturer.  They have over 
hundred buyers to keep their business alive and lack of resource to meet all 
standards of their buyers.  In order to meet your requirements, you have to 
actively educate them for what they have to supply in order to fulfillment of 
business contract.

In your 2nd para, for the product design, Yes.  In terms of production units, 
you have to verify by yourselves or hire a 3rd party body upon your behalf to 
verify if they have a good quality assurance system to maintain the production 
units within the tolerance of approved sample.  If you act as a retailer only, 
the product under their brand and their contact, you may have limited 
responsibilities, otherwise, you actually act as a manufacturer in EU.  For 
example, if your product is picked up by the market surveillance for validation 
of compliance with applicable regulations, do they contact your supplier or you?

Hope it is useful to your consideration!

Scott

On Thu, 30 Aug 2018 at 15:55, James Pawson (U3C) 
mailto:ja...@unit3compliance.co.uk>> wrote:
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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Re: [PSES] CE marking - mixture of responsibilities

[Scott Xe]

Hi James,

It is quite normal attitude for an oem or odm manufacturer.  They have over
hundred buyers to keep their business alive and lack of resource to meet
all standards of their buyers.  In order to meet your requirements, you
have to actively educate them for what they have to supply in order to
fulfillment of business contract.

In your 2nd para, for the product design, Yes.  In terms of production
units, you have to verify by yourselves or hire a 3rd party body upon your
behalf to verify if they have a good quality assurance system to maintain
the production units within the tolerance of approved sample.  If you act
as a retailer only, the product under their brand and their contact, you
may have limited responsibilities, otherwise, you actually act as a
manufacturer in EU.  For example, if your product is picked up by the
market surveillance for validation of compliance with applicable
regulations, do they contact your supplier or you?

Hope it is useful to your consideration!

Scott

On Thu, 30 Aug 2018 at 15:55, James Pawson (U3C) <
ja...@unit3compliance.co.uk> wrote:

> 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
> -
> 
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

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Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 Dave,My experience is that products which are certified to worldwide 
harmonized standards - eg 60950 or 61010 - are evaluated for the full voltage 
and frequency as stated on the product nameplate and reported in both the NRTL 
cert report as well as the CB report.  If you are not asking for both reports 
you are not taking full advantage of the evaluation available.   Are you using 
a standard that is harmonized worldwide? are you requesting full certification 
to the standard as part of your NRTL evaluation project?  



I agree (and did say so earlier) that this strategy does not cover 
everything but will provide regular factory construction inspections to 
maintain the safety features of the design as certified  As your mother would 
say: half a loaf is better than none.  



:>)br,Pete
p.perk...@ieee.org

 

 

-Original Message-
From: Nyffenegger, Dave 
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 12:24 pm
Subject: Re: [PSES] CE marking - mixture of responsibilities



Not true in my experience.  The same lab may do certification reports for EU 
declarations in addition to NRTL certification/report.  The NRTL listing report 
is specific to US and/or Canadian standards.  We put a 50Hz input rating on the 
nameplate but that’s never been included in the NRTL report.  The NRTL factory 
inspectors only inspect to the NRTL listing report.  And as John said there is 
much more to EU i.e. EMC, RoHS, WEEE, then what NRTL covers.
 
-Dave
 

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, August 30, 2018 2:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
 
A NRTL tests to ALL the equipment ratings even if they include EU ratings.
Rich
 

From: John Woodgate 
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
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Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 

 John,Yes, there are many very clever ways to cheat in life.  In this case 
no NRTL mark invalidates the acceptability of the CE marking downstream; the 
importers QA inspection is needed.  My suggestion only works if the folks 
downstream who are on the hook legally for the Euro conformity are paying 
attention to the details and watching for completeness and forgeries.  
Vigilance is the price of freedom.  or, as President Reagan emphasized, trust 
but verify.  



:>)br,Pete

 

-Original Message-
From: John Woodgate 
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 11:44 am
Subject: Re: [PSES] CE marking - mixture of responsibilities



But I can think of a few work-arounds thatwould invalidate that, with 
NRTL on the EU product initially,but made in a different factory with 
no NRTL inspection and lessidentical later. It's been done.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:37, John Woodgate  wrote:



Ah! To maximize revenue, no doubt.
  
  
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
  
On 2018-08-30 19:05, Richard Nutewrote:
  
  

  
 
  
A NRTL  tests to ALL the equipment ratings even if they include EU  
ratings.
  
Rich
  
 
  

  
From: John Woodgate   

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Re: [PSES] CE marking - mixture of responsibilities

[Nyffenegger, Dave]

Not true in my experience.  The same lab may do certification reports for EU 
declarations in addition to NRTL certification/report.  The NRTL listing report 
is specific to US and/or Canadian standards.  We put a 50Hz input rating on the 
nameplate but that’s never been included in the NRTL report.  The NRTL factory 
inspectors only inspect to the NRTL listing report.  And as John said there is 
much more to EU i.e. EMC, RoHS, WEEE, then what NRTL covers.

-Dave

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, August 30, 2018 2:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


A NRTL tests to ALL the equipment ratings even if they include EU ratings.
Rich

From: John Woodgate 
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
-


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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

But you are honest.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:43, Greg McClure wrote:


Actually we certify all of our products for both 110-127 V and 220-240 
V 50/60 Hz with a NRTL.


And we do sell the 220-240 V models to the US government. (FAA and 
military)


Gregory H. McClure

Lexmark Product Safety

Product Safety Team Lead

859-232-3240 office

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 2:38 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-08-30 19:05, Richard Nute wrote:

A NRTL tests to ALL the equipment ratings even if they include EU
ratings.

Rich

*From:*John Woodgate  <mailto:j...@woodjohn.uk>
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
    *Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains,
so the NRTL won't cover safety test with 230 V 50 Hz input. There
may be issues with different EMC standards, as well.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

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<http://www.ieee-pses.org/emc-pstc.html>

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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

But I can think of a few work-arounds that would invalidate that, with 
NRTL on the EU product initially, but made in a different factory with 
no NRTL inspection and less identical later. It's been done.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:37, John Woodgate wrote:


Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-08-30 19:05, Richard Nute wrote:


A NRTL tests to ALL the equipment ratings even if they include EU 
ratings.


Rich

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so 
the NRTL won't cover safety test with 230 V 50 Hz input. There may be 
issues with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
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Jim Bacher:  
David Heald: 

Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:05, Richard Nute wrote:


A NRTL tests to ALL the equipment ratings even if they include EU ratings.

Rich

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so 
the NRTL won't cover safety test with 230 V 50 Hz input. There may be 
issues with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
-


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Re: [PSES] CE marking - mixture of responsibilities

[Richard Nute]

 

A NRTL tests to ALL the equipment ratings even if they include EU ratings.

Rich

 

From: John Woodgate  
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the 
NRTL won't cover safety test with 230 V 50 Hz input. There may be issues 
with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 17:46, Peter E Perkins wrote:

James & PSnet folks,

    I could envision a scenario that could be more comfortable for 
all.  If the same product was sold worldwide and bore a US NRTL (UL, 
etc) mark along with the CE marking then the importer would know that 
the factory was having quarterly construction inspections.  At the 
Euro end just audit the incoming and ensure that the US NRTL mark 
continues to appear on the product.  there are still outstanding 
issues but the largest exposure is covered.


:>)    br,    Pete


-Original Message-
From: John Allen <09cc677f395b-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 6:34 am
Subject: Re: [PSES] CE marking - mixture of responsibilities

Head in hands – and liability insurance paper in back pocket (hopefully)!
*From:*James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk 
<mailto:ja...@unit3compliance.co.uk?>]

*Sent:* 30 August 2018 13:18
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:p...@listserv.ieee.org>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Charlie, John, thanks for the insightful feedback as always.
The latest email from the manufacturer doesn’t do much to inspire 
confidence!

James
*From:*Charlie Blackham <mailto:char...@sulisconsultants.com>>

*Sent:* 30 August 2018 10:29
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:p...@listserv.ieee.org>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Completely agree
The importer can do all the testing on the 1^st sample, but then the 
manufacturer can make whatever they like with impunity and the 
importer takes on all the manufacturer change control risk for ongoing 
compliance without any means of controlling or monitoring it.

Barge pole at the ready
regards
Charlie
*Charlie Blackham*
*Sulis Consultants Ltd*
*Tel: +44 (0)7946 624317*
*Web: *** 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>*www.sulisconsultants.com 
<http://www.sulisconsultants.com>*

Registered in England and Wales, number 05466247
*From:*John Woodgate mailto:j...@woodjohn.uk>>
*Sent:* 30 August 2018 10:01
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Run, do not walk, away from this manufacturer. Either they are 
dangerously unaware of the EU requirements, or they are deliberately 
avoiding commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2018-08-30 08:48, James Pawson (U3C) wrote:

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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emc-pstc discussion list. To post a message to the list, send your
e-mail to mailto: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/
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List rules: http://www.ieee-pses.org/listrules.html
For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcan

Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 James & PSnet folks,


I could envision a scenario that could be more comfortable for all.  If the 
same product was sold worldwide and bore a US NRTL (UL, etc) mark along with 
the CE marking then the importer would know that the factory was having 
quarterly construction inspections.  At the Euro end just audit the incoming 
and ensure that the US NRTL mark continues to appear on the product.  there are 
still outstanding issues but the largest exposure is covered.  



:>)br,Pete

 

 

-Original Message-
From: John Allen <09cc677f395b-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 6:34 am
Subject: Re: [PSES] CE marking - mixture of responsibilities



Head in hands – and liability insurance paper in back pocket (hopefully)!
 

From: James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk] 
Sent: 30 August 2018 13:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Charlie, John, thanks for the insightful feedback as always.
The latest email from the manufacturer doesn’t do much to inspire confidence!
James
 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Completely agree
 
The importer can do all the testing on the 1st sample, but then the 
manufacturer can make whatever they like with impunity and the importer takes 
on all the manufacturer change control risk for ongoing compliance without any 
means of controlling or monitoring it.
 
Barge pole at the ready
 
regards
Charlie
 

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: www.sulisconsultants.com
Registered in England and Wales, number 05466247

 

From: John Woodgate  
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Run, do not walk, away from this manufacturer. Either they are dangerously 
unaware of the EU requirements, or they are deliberately avoiding commitment.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

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
-

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 

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 
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Scott Douglas 
Mike Cantwell  
For policy questions, send mail to:
Jim Bacher 
David Heald  

 
-

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All emc-pstc postings are archived and searchable on the web at: 
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-

This message is from the IEEE Product Safet

Re: [PSES] CE marking - mixture of responsibilities

[John Allen]

Head in hands - and liability insurance paper in back pocket (hopefully)!

 

From: James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk] 
Sent: 30 August 2018 13:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Charlie, John, thanks for the insightful feedback as always.

The latest email from the manufacturer doesn't do much to inspire
confidence!

James

 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Completely agree

 

The importer can do all the testing on the 1st sample, but then the
manufacturer can make whatever they like with impunity and the importer
takes on all the manufacturer change control risk for ongoing compliance
without any means of controlling or monitoring it.

 

Barge pole at the ready

 

regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f
5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: John Woodgate  
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Run, do not walk, away from this manufacturer. Either they are dangerously
unaware of the EU requirements, or they are deliberately avoiding
commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

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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discussion list. To post a message to the list, send your e-mail to


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 
Mike Cantwell  

For policy questions, send mail to:
Jim Bacher 
David Heald  

 

-


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discussion list. To post a message to the list, send your e-mail to


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 
Mike Cantwell  

For policy questions, send mail to:
Jim Bacher 
David Heald  

-


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


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:

Re: [PSES] CE marking - mixture of responsibilities

[James Pawson (U3C)]

Charlie, John, thanks for the insightful feedback as always.

The latest email from the manufacturer doesn't do much to inspire
confidence!

James

 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Completely agree

 

The importer can do all the testing on the 1st sample, but then the
manufacturer can make whatever they like with impunity and the importer
takes on all the manufacturer change control risk for ongoing compliance
without any means of controlling or monitoring it.

 

Barge pole at the ready

 

regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f
5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Run, do not walk, away from this manufacturer. Either they are dangerously
unaware of the EU requirements, or they are deliberately avoiding
commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

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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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >

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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
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List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org> >
Mike Cantwell mailto:mcantw...@ieee.org> > 

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org> >
David Heald mailto:dhe...@gmail.com> > 

 

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discussion list. To post a message to the list, send your e-mail to
mailto: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
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David Heald mailto:dhe...@gmail.com> > 

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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >

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Attachments are not permitted but the

Re: [PSES] CE marking - mixture of responsibilities

[Charlie Blackham]

Completely agree

The importer can do all the testing on the 1st sample, but then the 
manufacturer can make whatever they like with impunity and the importer takes 
on all the manufacturer change control risk for ongoing compliance without any 
means of controlling or monitoring it.

Barge pole at the ready

regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
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: John Woodgate 
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


Run, do not walk, away from this manufacturer. Either they are dangerously 
unaware of the EU requirements, or they are deliberately avoiding commitment.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-08-30 08:48, James Pawson (U3C) wrote:
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
-


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 
mailto: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 
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

Run, do not walk, away from this manufacturer. Either they are 
dangerously unaware of the EU requirements, or they are deliberately 
avoiding commitment.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:


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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