Lauren and Bailin, Thank you for updating us on this trivial yet complex issue.
Date sent: Mon, 26 Oct 98 14:35:11 PST To: <[email protected]>, "Crane,Lauren" <[email protected]> From: <[email protected]> "Bailin Ma" Subject: RE: DoC Send reply to: <[email protected]> "Bailin Ma" > I second what Lauren said. People usually don't include proprietary > information (schematics, drawings, etc.)in their CE compliance technical > documentation that must be kept within the Community. --Barry Ma > > > ------------- > Original Text > From: "Crane, Lauren" <[email protected]>, on 10/26/98 12:01 PM: > 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). > > > > --------- > 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). > PETER S. MERGUERIAN MANAGING DIRECTOR PRODUCT TESTING DIVISION I.T.L. (PRODUCT TESTING) LTD. HACHAROSHET 26, P.O.B. 211 OR YEHUDA 60251, ISRAEL TEL: 972-3-5339022 FAX: 972-3-5339019 E-MAIL: [email protected] Visit our Website: http://www.itl.co.il --------- 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).
