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..

By comparison, if it were only to reference only the brand name and model
number of Company A, the document would have no obvious relationship to the
markings on the product itself. This would not go down well with inspecting
authorities such as UK Trading Standards Officers, who could reasonably
argue that the DoC - and thus the CE Marking - was of dubious provenance.

Furthermore, I think that some "Company B's" might be somewhat unhappy from
a marketing perspective to offer DoCs which clearly show that the product
was manufactured by someone else (Company A)  - and if multiple Company B's
sell exactly the same product from Company A (especially if they charge
different prices for it!).

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.

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)
(sent from my home email address)

----- Original Message -----
From: <[email protected]>
To: <[email protected]>
Sent: Wednesday, November 06, 2002 7:10 PM
Subject: Re: EU DoC


>
> <<<Company A builds a device for company B which sells the device in the
EU
> under their own brand name. The device is subject to a Declaration of
> Conformity, and both companies are located within the EU. Must both
> companies issue a Declaration?<<<
>
> No. A declaration from either company will suffice.
>
>
>
> Greg Galluccio
> www.productapprovals.com
>
>
>
>
> -------------------------------------------
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