I think John is correct – just the “distributor” providing that the new entity didn’t change the product. The manufacturer is the designer and they should be completely responsible for all of the technical aspects of the product: performance, safety and EMC compliance. They are the only ones to be able to change all of those parameters. The distributor should have a handy trail back to the designer, but shouldn’t have to retest everything to confirm. I have more than once asked for and obtained a copy of the test reports if and when I had a deep concern about something that we were purchasing. (It can take a while to find the folks that have the data inside any company but eventually it is obtainable) A lot of companies sell products to many different distributors I can’t image that any regulatory agency would demand that every distributor of every product repeat all of the tests and incur the time and costs associated with that – especially since the governments don’t make any money, directly, off the tests so they are less “incentivetised” to do so. Before self certification for ITE equipment the US’s FCC had a control number on the product which identified the actual manufacturer regardless of what the shipping box said. It was coded so that you couldn’t immediately tell who it was, but the products we built for HP carried only the HP name, but if there was a problem the FCC could come directly to us.
Further we Gary McInturff 208 635 8306 ________________________________ From: Robert Heller [mailto:[email protected]] Sent: Wednesday, April 28, 2010 2:47 AM To: [email protected] Subject: Re: [PSES] definition of manufacturer Isn't the company that places it on the Market responsible? Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 ========================= <[email protected]> wrote on 04/27/2010 03:38:05 PM: > [image removed] > > Re: definition of manufacturer > > John M Woodgate > > to: > > emc-pstc > > 04/27/2010 05:35 PM > > Sent by: > > <[email protected]> > > In message <[email protected]>, > "[email protected]" <[email protected]> writes > >Suppose company A manufactures, assembles, tests and CE marks a product > >for available sale. As a courtesy to customers, Company B makes the > >product available by giving it a company B part number for the customer > >to order as an accessory to it's main product line. Company B does not > >"brand label" the accessory, but rather leaves all Company A markings > >intact. Who is responsible for meeting the requirements of the EMCD, > >company A or B? > > Company B is just acting as a distributor of a product declared > compliant by Company A. Of course, Company B might think it prudent to > verify the claim of compliance, but has no legal responsibility UNLESS > Company A is outside the EU while Company B is inside it. In that case, > Company B bears joint responsibility. > -- > This is my travelling signature, adding no superfluous mass. > John M Woodgate > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. To post a message to the list, send your > e-mail to <[email protected]> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to that URL. > > Website: http://www.ieee-pses.org/ > 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]> > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]>
