Nick, Unfortunately, regarding the last para, you have not followed your own good advice of checking with the specific EU Directives concerned.
Annex IV section 2 of the LVD requires: "The manufacturer must establish the technical documentation described in point 3 and he or his authorized representative established within the Community must keep it on Community territory at the disposal of the relevant national authorities for inspection purposes for a period ending at least 10 years after the last product has been manufactured." Not surprisingly, the Commission's Guide to the LVD (2001 edition) states: "This technical documentation must be kept within the Community." On the other hand, the R&TTED does not state that the technical documentation must be kept within the Community. The corresponding para to the above (Annex II section 2) requires that: "The manufacturer must establish the technical documentation described in point 4 and he or his authorised representative established within the Community must keep it for a period ending at least 10 years after the last product has been manufactured at the disposal of the relevant national authorities of any Member State for inspection purposes." Note that the part requiring that the technical documentation be kept "on Community territory" is absent. Equally, the LVD and the R&TTED have different requirements regarding the provision of a DoC. See Article 6(3) of the R&TTED. Own opinions as always, Richard Hughes -----Original Message----- From: Nick Williams [mailto:[email protected]] Sent: 11 December 2002 00:12 To: Stephen Irving Cc: [email protected] Subject: Re: Location of CE DoCs These are indeed rumors. Different Directives have different requirements in this regard, and although the general rules of thumb that documentation should be kept in the EU and a copy of the DofC should be supplied with the product provide a good working basis for compliance with the Directives, they are by no means mandatory for all equipment under all New Approach directives. If it really matters to you, you should read the text of the specific directives which apply to your products in order to find out what is required. As examples, neither the LVD nor the EMC Directives require a copy of the EC declaration to be shipped with the product, although the Machinery Directive does. None of these three directives require the appointment of an Authorised Representative (only the medical devices directives do this) and ergo there is no requirement for the technical file to be 'kept on EU soil'. Regards Nick.
