John, You have hit the nail on the head. My question should have been, if a manufacturer is not established in the EEA, should the signatory be within the EEA? I thought the whole point behind the DoC was that in the event of a problem with a product the authorities would have someone they could contact within the boarders of the EEA. Kind regards, Chris. John Woodgate <[email protected]> on 25/02/2004 14:04:39 Please respond to John Woodgate <[email protected]> Sent by: John Woodgate <[email protected]> To: [email protected] cc: (Chris Allen/GB/3Com) Subject: Re: DoCs - where must the signatory reside? I read in !emc-pstc that Smith, Paul J. <[email protected]> wrote (in <[email protected]>) about 'DoCs - where must the signatory reside?' on Mon, 23 Feb 2004: >identification of the signatory empowered to bind the manufacturer or >his authorised representative, established within the EEA > >Referring to website >http://www.tukes.fi/englanti/electricity_elevators/instructions/vaatimus >tenmukaisuusvakuutus_eng.html , please note the following text. >"........Signature with clarification and identification of the >signatory who has been empowered to enter into commitments on behalf of >the manufacturer or his authorised representative established within the >Community". Both of the above statements are in fact ambiguous. Before enlarging on that, I would say that no action is likely to be taken just on the matter of the residence of the signatory (which could, in fact, change within the life of the product, let alone in the ten years after manufacture has ceased). The texts are ambiguous because it is not clear whether the phrase 'established within the EEA' applies to 'the manufacturer', as well as to 'his authorised representative'. Common sense indicates that it can't, because the manufacturer may NOT, in fact, be 'established within the EEA'. The second text, without the comma after 'representative' is somewhat less ambiguous than the first. I would like to see the text formatted thus: Signature with clarification and identification of the signatory who has been empowered to enter into commitments on behalf of: o the manufacturer or o his authorised representative established within the Community". This is still not entirely OK. By 'clarification' is meant that **the name of the signatory must be *printed* on the form**, as well as the facsimile signature, which will, of course, usually be quite illegible and useless for discovering (as opposed to identifying) the signatory. -- Regards, John Woodgate, OOO - Own Opinions Only. The good news is that nothing is compulsory. The bad news is that everything is prohibited. http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ieee-pses.org/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ieee-pses.org/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
