Hi Doug,

 

I believe your client is in error.  The Blue Guide
<http://ec.europa.eu/enterprise/policie
/single-market-goods/files/blue-guide/guidepublic_en.pdf>  only indicates that
a person residing the EU is required to sign a DoC if required by a specific
CE marking directive.  The relevant information starts on page 34 of the Blue
Guide <http://ec.europa.eu/enterprise/p
licies/single-market-goods/files/blue-guide/guidepublic_en.pdf> .  Note 103 on
page 35 states “It is not necessary for the signatory to be domiciled in the
Community. A manufacturer established  outside the Community is entitled to
carry out all the certification procedures at his premises and, therefore, to
sign the declaration of conformity, unless otherwise provided for in the
directive(s).”

 

The EMC, LVD and R&TTE Directives do not require somebody domiciled within the
EC to sign the DoC.  The new Machinery Directive is slightly  different. 
Annex II section A bullet 2 requires that the DoC include the “name and
address of the person authorized to compile the technical file, who must be
established in the Community”.  However, bullet 10, which stipulates the
signatory, does not require that signatory to reside within the EU.

 

Regards,

Ted Eckert

Compliance Engineer

Microsoft Corporation

[email protected] <mailto:[email protected]> 

 

The opinions expressed are my own and do not necessarily reflect those of my
employer.

 

 

 

From: Doug Nix [mailto:[email protected]] 
Sent: Tuesday, December 21, 2010 7:45 AM
To: [email protected]
Subject: Need for a EU Signature on a Declaration of Conformity??

 

Colleagues,

I have recently heard from a client in the UK, that a Declaration of
Conformity is not valid without a signature from an EU entity. I cannot find
any legal basis that supports this. Can anyone enlighten me on this?
--
Doug Nix

Office: (519) 650-4753
Mobile (519) 729-5704
Skype: cic-inc

[email protected] 

 

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