hello Group, If a manufacturer of a product in the USA sells it to another company in the USA, who is NOW the owner of that product. Who is the responsibilty party in meeting any EU directive? the original manufacturer or the new owner who bought the product and then shipped to the EU.....
with that, does it have any effect if the new owner puts their logo on the box? I am curious at the responsibilties of each party in a tranaction like this. I ask for two reasons: 1. just a general question 2. what is a directive changes in the time between when the orignal manufacturer got compliance on the product before it was sold to company B within the USA, then say 3 months later, the directive changed and company B doesnt do compliance. thanks for your time... Richard From: [email protected] [mailto:[email protected]]On Behalf Of Chris Maxwell Sent: Wednesday, February 22, 2006 10:02 AM To: Nick Williams; [email protected] Cc: Emc-Pstc Subject: RE: 'Evaporation' of compliance certification with time? I don't understand how looking at the age of a Declaration of Conformity will tell you anything. The only reason that a DOC should change is because of a change in the applicable standards. A DOC that's two weeks old could be garbage if the applicable standards hsve changed within those two weeks. On the other hand, a 10 year old DOC may be perfectly fine if there haven't been standard changes during that time. This is just another one of those rules that panders to "ease of inspection" while being meaningless. Anybody who looks for the age of a DOC is pretty much admitting that they have no idea of what the applicable standards are. Chris Maxwell Nettest, a division of Anritsu From: [email protected] [mailto:[email protected]] On Behalf Of Nick Williams Sent: Wednesday, February 22, 2006 9:17 AM To: [email protected] Cc: 'Emc-Pstc' Subject: Re: 'Evaporation' of compliance certification with time? Chris You've dropped into a big debate which is going on in the higher echelons of the EU's enterprise directorate. At present, I don't think any of the new approach directives place an upper limit on the life of a conformity certificate, but there is pressure to include this in some of the Directives (e.g. Machinery) when they are revised, and also to make the certificate issuing bodies responsible for telling their customers when the standards and regulations which affect their products change. The Notified Body groups are (by and large) resisting this change. In my experience, for consumer durables most UK high street retailers want to see a certificate which is no more than 2 years old. Some of the bigger test houses put a 5 year life on their certificates, but this is not done with any authority from the Directives, although I think this is likely to be the upper limit if/when this is introduced in the directives in due course. Of course, this assumes that the product which was originally certified is the one you are still selling. If you make changes to the product, you and your certification body have to agree between you whether or not the original certificate is still valid. That's a whole new can of worms! If you're really interested in this, get yourself added to the DTI's ConCASS mailing list - mail me direct for contact details. Nick. At 12:05 pm +0000 22/2/06, [email protected] wrote: >Gentlemen, and ladies, and others..... > >Does anyone have an opinion on the longevity of a Compliance Certificate? > >Take the situation..... > >If we make a product, test it, certify it, and sell this in the normal way, >how long can we carry on selling this product (assuming that there are no >design changes, but changes due to obsolescent parts or 'more modern' >parts) relying on the original test results and certificate to provide >evidence of Compliance? > >My own gut feeling is that three years is perfectly OK, and 20 years is too >long, so somewhere in between those two figures may be about right I >suppose. > >Does anyone have an opinion, a precedent, or rationale for this subject? > >Thankyou for your attention. > >Chris Dupres. > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [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 Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [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 Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
