[Sorry. Failed to identify myself in original note.]
Here's a simple version of my understanding of the EU DoC process.....
1 Understand the requirement options of the relevant Directives
2 Test to acceptable requirements (proof of compliance)
3 Issue EU DoC for the product (statement of compliance)
4 Place CE marking on the product
5 Place CE marking on final packaging (the "pretty" box)
5 Place EU DoC in user's documentation
6 Be prepared to provide copy of signed EU DoC on request
7 Be prepared to provide test reports (proof of compliance)
e.g. CB Report and EMC Test Reports
If products reach EU borders in bulk packaging, or on pallets, and CE
marking is not visible, it is reasonable to expect that border customs
officials will need to require some documentation on the bulk shipments.
Otherwise, they would have to break down the bulk shipment to determine
if the product(s) meet the CE marking requirements.
The EU DoC is no more "proof" of compliance than the CE marking. Only
the test reports (assuming they are acurate) are proof of compliance.
Therefore, it is reasonable that external CE marking on bulk shipments
may be required, but the EU DoC would serve no additional purpose.
George Alspaugh
Coporate Product Safety
Lexmark International Inc.
---------------------- Forwarded by George Alspaugh/Lex/Lexmark on 07/15/99
02:23 PM ---------------------------
peperkins%[email protected] on 07/15/99 01:35:52 PM
Please respond to peperkins%[email protected]
To: harrisk%[email protected]
cc: emc-pstc%[email protected]
Subject: French Customs demand EC Declaration!
PS Net et al,
It has been my understanding from the beginning that the MDofC was
the proof of conformity in meeting the CE requirements and that the CE
marking on the equipment was a convenience, but not the formal proof. The
MDofC is the place where the inquirer can see specifically what Directives
are claimed and what specific Standards are claimed for conformity.
As a consultant in this area I have consistantly encouraged my
clients to reproduce the MDofC in the manual rather than provide a separate
document with the shipment. This simplifies these types of questions.
Further, it is true that outside manufacturers are at a
disadvantage in this process because Customs is the primary gatekeeper for
this process. Since the internal borders have been taken down, the Euro
manufacturers don't have to jump the same hurdles... Guess I've never
expected this to be a level playing field.
- - - - -
Peter E Perkins
Principal Product Safety Consultant
Tigard, ORe 97281-3427
+1/503/452-1201 phone/fax
[email protected] email
visit our website:
http://ourworld.compuserve.com/homepages/peperkins
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