For the European law, company B is considered as "manufacturer" and shall
issue the DoC. No point company A issues its own DoC.

The text of the EMC Directive reads "the manufacturer
may subcontract certain operations, e.g., apparatus design or production,
provided that he retains overall control and responsibility for the
apparatus as a whole. By the same token, he may use ready-made items or
components, CE marked or not, to produce the apparatus without losing his
status as a manufacturer."

There are two ways company B ensures compliance with EU Directives:
1. Company B shall request from company A all necessary proof of compliance
with the relevant standards.
2. Company B qualifies the product and prepares supporting documentation.
Company B will do QA, audits and inspections at company A to ensure
consistency of all products with the test sample(s).

Alexandru Guidea
CAE Inc.
Montreal, CANADA 


-----Original Message-----
From: [email protected] [mailto:[email protected]]
Sent: Wednesday, November 06, 2002 1:22 PM
To: [email protected]
Subject: 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?

Richard Woods
Sensormatic Electronics
Tyco International


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