In message <[email protected]> [email protected] writes: > > --Boundary (ID k8XR0QxIiidPFm5ZhF0PpQ) > Content-type: TEXT/PLAIN > > Our headquarters, and the majority of our product shipments, are out of Ann > Arbor, MI. However, we own a facility in The Netherlands. This facility > consists primarily of a sales office, wharehouse, service depot, and a > facility > for some value-added type production. In other words, we ship products out > of our headquarters here in the US, to this facility. My counterparts in our > European facility tell me that I do not need the CE Mark on the products for > intra-company shipments like this. > > My questions is..............what does the > directives say about intra-company shipments..........? I am looking for as > much information on this subject as possible........if anyone has any insight, > please let me know!
Robert, I'm not in my office for a few days, and don't have the texts of the directives immediately to hand. But I feel strongly the advice you have been given is right. The requirement for CE marking crystallises at the moment the product is "placed on the market". Shipping to your own facility in the Netherlands is _not_ "placing on the market". This is not a customs regulation. The draft New EMC European Guidelines Document which I do happen to have with me for example states: "The placing of a product on the market does not concern: - the disposal of the product from the manufacturer to his authorised representative established in the Community who is responsible for the manufacturer for ensuring compliance with the Directive;" etc (too long to quote). As far as I know, none of the Directives specifically refer to intra- company shipment, but the definition of an authorised representative clearly covers an overseas subsidiary or affiliate. Hope this helps. Bill. -- Bill Lyons - [email protected] / [email protected]
