Thanks for the replies. There is general agreement that one route is to have the customer do his own DofC and apply the CE Mark. I guess the unstated assumption behind my questions was that the customer doesn't want to take on the responsibility for the CE Mark, technical documentation, keeping records for 10 yrs, etc. In that case, the option in Gabriel Roy's response below is not an option, and the issues raised in item b) from the un-named response below become of interest.
Maybe a third question is needed: is there anything in the Directives that insists on traceability to the original "declarer" once the product is in service? When a product is at customs, in a warehouse, or on a store shelf, a copy of the DofC will be in the box with it. Once the customer starts using the product though, there will be no traceability from it to us (unless they keep the DofC with it which is highly unlikely). Thanks, Jim Eichner Statpower Technologies Corporation [email protected] The opinions expressed are those of my invisible friend ____________________________________________________ ...Let me know what you find out. I've asked this question a few times over the last three years and never gotten a satisfactory answer. It seems their is nothing equivalent to the UL multiple listing process. a) One option was the third party generating and signing the DofC based on your technical data file and applying their identification label and CE marking in their warehouse. The third party becomes the party responsible for placing the equipment on the EU market. b) Another option was the original mfg filling out a separate Mfg DofC based on model and serial information provided by the third party and the original mfg applying the identification label of the third party and CE Marking at the original manufacturer's facility. The DofC would be traceable to the original manufacturer but not the equipment label. Other inputs were this was not an acceptable approach because nothing on the product or in the literature was traceable to the original manufacturer. ---------- From: TFredrik@anetMHS (Tony Fredriksson){MHS:[email protected]} To: GRoy@anetMHS (Gabriel_Roy){MHS:[email protected]}; ; JEichner@anetMHS (JEichner){MHS:[email protected]}; JEichner Cc: emc-pstc@anetMHS (emc-pstc){MHS:[email protected]} Subject: Re: Who can apply the CE Mark? List-Post: [email protected] Date: Monday, April 29, 1996 1:39PM Note that it behooves the customer to do the following things: 1. Keep a copy of all data verifying compliance on file. 2. Work out a system with the vendor that allows verification of ongoing quality, compliance, and testing (modifications, upgrades, options). This usually involves having access to activity of the ECO process which is far from trivial. It's their butt that's on the line if they declare. Regards, [email protected] ---------- From: Gabriel_Roy To: JEichner Cc: emc-pstc Subject: Re: Who can apply the CE Mark? List-Post: [email protected] Date: Monday, April 29, 1996 2:58PM The solution appears simple to me, your customer prepares his own Declaration, based on reviewing your data, uses his own model numbers, and puts his own CE mark on his equipment. Gabriel Roy Hughes Network Systems Maryland _____________________________________ To: emc-pstc @ ieee.org @ SMTPGW cc: From: JEichner @ statpower.com @ SMTPGW ..."I am being asked if we can sell products to customers who want their name only to appear on the product, not ours, and so order products with no labelling on them at all, in plain white boxes. These customers need the CE mark, and would like us to ship a DofC in our name, but would like to incorporate the CE Mark into their labels, or apply our CE Mark label at their factory... "...1. Is there any problem with the customer applying the CE Mark instead of our factory? 2. Is there any problem with shipping a product with one name on it (the customer's) when the DofC has a different name on it (not to mention model numbers - some of these customers don't use our model numbers)? ..." Jim Eichner Statpower Technologies Corporation [email protected] The opinions expressed are those of my invisible friend
