My understanding to this situation with respect to the UL, FM, CSA
agencies, is the True manufacturer is best to put the file number on the
product label.  The file number identifies the real manufacturer without
showing their name.  The name is available if you call the approval
agency and give them the file number on the product though.  

Within this file, resides other names such as Company A's.  They are
considered what is called a "Multiple Listee".  Therefore, if you have
several OEM's selling your product, Each OEM's name is listed in the
approval file.  The act of putting the file number on the product,
allows the true manufacturer not to place his/her name on the label, but
instead any other name on the multiple listing.  Without the File number
on the product label, then the real manufacturer has to identify
themselves on the product.  This is my version as it relates to third
party safety approvals.  

A great example of this is the "Opto 22 style" solid state relays
(ODC5,IDC5 relays).  hundreds of OEM's sell these but there are only a
couple of manufacturer's of the product.

Best Regards,

Gary Labadie
Approvals Coordinator

Acromag, Inc.
30765 Wixom Rd.            Ph: (248)624-1541 ext. 205
P.O. Box 437                   Fax:(248)624-9234
Wixom, MI 48393            Email: [email protected]


-----Original Message-----
From: Douglas Mckean [mailto:[email protected]]
Sent: Monday, July 13, 1998 11:29 PM
To: [email protected]
Subject: Re: Dual names on regulatory labels


[email protected] wrote:
> 
> Hello!!
> 
> I have a question regarding dual manufacturers names on a regulatory
> label.
> 
> >From an EMC perspective:
> 
> The situation is that Company A wishes to buy product from  Company B
> and resell using Company As name and model number.
> 
> In order to save time, Company A wishes to use BOTH sets of
> model numbers on the SAME label as well as using company
> B licence numbers etc.
> 
> Is this legally acceptable??

Yes, as long as the appropriate paperwork 
from the agencies concerned shows both company 
names and both model numbers in the reports. 

If Company B did the testing, then Company A 
must make arrangements with Company B to 
have the documentation changed accordingly. 

It gets trickier if Company A doesn't want any 
reference or mention of Company B in any of the 
documentation to include Company B's model numbers. 
For instance, FCC Part 15 Class A reports may be 
changed to reflect only Company A's name and model 
numbers.  The change only requires a change to 
documentation fee.  But, FCC Part 68 reports require 
a registration on the part Company A with the FCC.  
I think I have that correct ...

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