John and Dennis,

Thank you for resetting my wrong assumptions.

Few years ago, when I was first time learning how CE marking works reading 
something (?) I understood, that all legal actions for the out of EC 
manufacturer must be done by his authorised representative in the Community. 
I was 100% sure of it, so later I have never point enough attention to exact 
wording to notice my misunderstanding.

So if the manufacturer has the authorised representative in the Community 
and I wont to be an importer I have nothing to do with DoC (even not see it, 
because it is manufacturer and his representative responsibility to have DoC 
for every product he sends to EC) ?
It looks to simply to be true.

Do my assumption that regarding WEEE the importer will have more tasks to do 
is also wrong ?

Thank you once more for your help.

Regards

Piotr Galka


----- Original Message ----- 
From: "John Woodgate" <[email protected]>
To: <[email protected]>
Sent: Saturday, September 15, 2007 12:24 PM
Subject: Re: Another DofC and CE basic question.


> In message <00ca01c7f77d$0a27ed70$154d4d0a@MmPc21>, dated Sat, 15 Sep 
> 2007, Piotr Galka <[email protected]> writes:
>
>>The out of EU manufacturer must have the authorised representative 
>>established in the Community and it is that representative who has the 
>>right to write DoC and to affix the CE mark (that manufacturer is not 
>>allowed to do it).
>
> That is not so. The detailed wording on this no doubt varies between 
> Directives, but see, for example, Article 8 1 of the new EMC Directive 
> 2004/108/EC, and Annexes II to IV. In each case, we see 'manufacturer OR 
> authorized representative'.
>
> There is an implied difference between 'authorized representative' and 
> 'importer'. The latter might very well be a non-technical company, unable 
> to deal with conformance issues. The 'authorized representative', however, 
> might be more like the European Division of a multinational company, 
> marketing products from another Division, outside the EC.
> -- 

-

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