For several years, I have gone through this name-change madness about 2x
per year because of customer mergers.

In general, company marks are in accordance with the requirements of the
NCB/agency that has performed the assessment and whose logos are affixed
to the unit. Look at the file's section general for UL-marked units, or
look at your the general agreement with the agency that you signed.

The purpose of a company mark is to provide tracibility.

And for Mr Monsen, good luck with Oracle... and time for me to ask for a
fork on the MySQL project - just (somewhat) kidding.

R/S,
Brian 


From: [email protected] [mailto:[email protected]]On Behalf Of Dan Roman
Sent: Monday, March 08, 2010 7:17 AM
To: Monrad Monsen; [email protected]
Subject: RE: [PSES] Agency Labels Without Manufacturer Name

Monrad,
 
If it is global product you will run into troubles, particularly in
eastern Asia.  As some list readers have pointed out, some entities such
as UL make allowances to do what you want, but this is not something that
can be achieved globally.  You will find a handful of countries that will
be difficult to deal with.  We re-branded some of our labels after a name
change but did not update the copyright on the PCB silkscreen and were
hassled because it was a different company name.  Just one example.
 
Dan
 
From: Monrad Monsen [mailto:[email protected]] 
Sent: Saturday, March 06, 2010 5:28 PM
To: [email protected]
Subject: [PSES] Agency Labels Without Manufacturer Name
 
Now that "Sun Microsystems, Inc." has been acquired by Oracle (27 January
2010), we are keeping a "Sun" as a brand name for our hardware and using
an Oracle/Sun combination badge on the front of our products.  We would
like to quickly change our products over to the new corporate name, but
there is a cost in updating the agency certificates for all of our
products' worldwide agency approvals.  One proposal is to totally remove
the mention of the manufacturer from our agency labels and just use the
combination Oracle/Sun brand badge on the front as the identification.  If
the agency approval is still tied to the old "Sun Microsystems, Inc.",
then use that name from the front badge.  If the agency approval has been
converted to "Oracle", then use that name from the front badge. 
 
I have always ensured that the manufacturer name is placed on the same
agency label along with the compliance model number and all of the
approval marks.  My purpose was to allow freedom for engineering and
marketing to do anything to the rest of the product since all of the
agency information needed was strictly on that agency label.  However, I
can't find any legal requirement or standard that calls for this, and the
manufacturer-less agency label idea would certainly save money and
expedite the transition away from strictly listing Sun Microsystems as the
manufacturer.  

Are there any legal or regulatory requirements for identifying the
manufacturer on the agency label?   Are there any other drawbacks to
having a manufacturer -less agency label and just using a combination new
& old manufacturer Oracle/Sun logo on the front of the product (agency
labels are normally placed on the back near the power cord or on the
underside)?
 
Note:  You'll see the combination Oracle/Sun logo (old Sun logo is over
the red Oracle logo) in many places on the www.oracle.com web site.
 
Thanks.
 
Monrad Monsen
Oracle

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