The way I understand it.... Each directive is written differently. The Machinery and EMC directives are structured so that supporting data must be made available in a reasonable amount of time. This allows the data to reside in the U.S. for U.S. manufacturers. However, the Low Voltage Directive requires the data to reside within the EU. This has been re-enforced by the recent guide to interpretting the LVD published by the European Commission.
See, for example, Directive 93/68/EEC which ammends many of the "CE" directives. Article 13 ammends the LVD. In part it creates an Annex IV which says in clause 2, "The manufacturer must establish the technical documentation described in point 3 and he or his authorized represntative established within the Community must keep it on Community territory at the disposal of the relevant national authorities....." The July 1997 guide to the LVD summarizes the requirement in point 23 where it says "This technical documentation must be kept within the Community." Lauren Crane Compliance Engineer Eaton Corporation. > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: Saturday, October 24, 1998 3:53 PM > To: [email protected]; [email protected] > Subject: Re: DoC > > Barry Hi! > > I still think "it is best" is the most appropriate answer. If > manufacturer has a European office, there is no problem in holding > the technical file at both the manufacturer and European office. > However, many of the foreign manufacturers do not have a > European office and use distributors or market under co-licensing > Agreements with other manufacturers. Under this circumstance, I > do not think it is a good idea to keep one's file in Europe, since the > > file consists of proprietary information (schematics, drawings, etc.). > > I believe the Directives specify the delivery of the files to the > responsible Authorities within 10 days. With today's courier > services, there should be no problem meeting the deadline. With > the Year 2000 Bug problem, there could be havoc! > > I summarize to state that there is no problem in keeping the Doc at > both the manufacturer's site and in Europe. However, be aware that > if manufacturer has no office of its own in Europe, keeping the > technical file there can cause "leakage" of information. > > [snip] > --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
