<EDFA411E5E4AD2118D6F00A0C99E4BAC0386AD75@FLBOCEXU02>,
[email protected] wrote:
>You said that placing on
>the market took place when the products were transferred from the
>manufacturing plant to the warehouse even if both locations were owned by
>the same company. I had said that the warehouse could not be under the same
>control. 

I believe that you are right.

>I went back to review the "Guide to the implementation of
>directives based on the New Approach and the Global Approach" and found that
>you are correct. Clause 2.3.1 defines "placing on the market" and footnote
>31 says "the distribution chain can also be the commercial chain of the
>manufacturer."
Remember that these Guidelines are NOT definitive of the law. In this
case, a manufacturer could very easily evade requirements by shipping
product around between his own warehouses. I don't believe that would
withstand a legal challenge.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?

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