>>>>>Greg

I think your statement needs some clarification.

Even if it is produced by Company A, the DoC must clearly state the name and
model number of the Company B which sells the product in question in the EU,
so that the document is clearly and specifically associated with that
product as sold in the EU..<<<<<

I agree.  The authorities have to be able to tie the product to the DoC.   I 
was going to go into that, but it seems like it would stand to reason. 


> Therefore I believe that many of the former would prefer to produce their
> own DoCs which made no mention of Company A - which should be OK as the
> Company B's are legally required to hold the supporting technical
> files/documentation prepared by Company A.


Agreed again.  From the standpoint of the authorities, it's probably better 
that company B issues the DoC.  However, from the standpoint of company B, 
who may not have as much control over production QC as they'd like, a 
declaration issued by Company A might be preferable.  I've seen joint declarat
ions, also, although I don't know what the Commission thinks about that.


Greg Galluccio
www.productapprovals.com

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