Within the scope of the EMCD, ‘manufacturer’ has been defined as any natural or 
legal person who manufactures a product or has a product designed or 
manufactured, and markets that product under his name or trademark.

 

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?  

 

Gary

 

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