Nick
I can see your viewpoint, but I don't think I agree with you - I believe
that b(i) and b(ii) are alternatives - not additive.
In Clause 3 "Intepretations" of the UK EMC Regs Regulations (SI 99 No 2372)
it defines the responsible person as follows:
"
"responsible person " in relation to relevant apparatus means-
(a) the manufacturer thereof;
(b) the manufacturer's authorised representative; or
(c) where the manufacturer is not established in the Community and he has
not appointed an authorised representative, the person who supplies the
relevant apparatus;"..........
>From the "or" at the end of (b)I take these to mean that (a), (b) and (c)
are alternatives - not an additive list.
See also my separate response today to John Woodgate's point about the
Commission's probably attitude to multiple signatories.
Regards
John Allen
Technical Consultant
Electromagnetics, Safety and Reliability Group
ERA Technology Ltd
Cleeve Rd
Leatherhead
Surrey KT22 7SA
Tel: +44 (0) 1372-367025 (Direct)
+44 (0) 1372-367000 (Switchboard)
Fax: +44 (0) 1372-367102 (Fax)
-----Original Message-----
From: Nick Williams [mailto:[email protected]]
Sent: 07 November 2002 21:54
To: John Allen
Cc: [email protected]
Subject: RE: EU DoC
...but for an alternative view, Regulation 40 (2) of the UK's The
Electromagnetic Compatibility Regulations 1992 (SI 1992:2372) says:
An EC declaration of conformity to which this regulation applies shall-
(a) be in English;
(b) give the name and address-
(i) of the responsible person;
(ii) where that person is not the manufacturer, of the manufacturer;
which I took to mean that both the manufacturer and their authorised
representative should sign where the manufacturer is not resident in
the EU.
Rgds
Nick.
At 16:55 +0000 7/11/02, John Allen wrote:
>Hi Folks
>
>Whilst investigating something else today, I came upon the Commission
>Guidance Notes for the implementation of the ATEX Directive :
>
>http://europa.eu.int/comm/enterprise/atex/guide/guide_en.pdf
>
>On Page 112 in reply to Question 13 (about something else), Case 1, 2nd
>paragraph, states the following:
>
>"The EC declaration of conformity and the application of the CE marking may
>be effected either by the manufacturer or his authorised representative,
but
>not by both. ....."
>
>Whilst this is ATEX-specific, I think it would appear reasonable to assume
>that the Commission takes a similar line with the other CE Marking
>directives.
>
>The document does also contain more background and explanatory information
>on this point and the Directive in general.
>
>Regards
>
>John Allen
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