I was under the impression that you label the product, not the label. When you put everything on one label, you have to change the label when there is a change to label content. We never expect labels to change but these days acquisitions are happening a lot more often. However, when you brand your product along with a model and serial number, the third party certification is tied to the model number and manufacturer on the product, and as long as you can show that somewhere else on the product you have the associated manufacturer information, you should be okay. I have been through a few acquisitions where labels and certifications need to be changed to reflect the change in the Company name. However, it really doesn’t matter what label you to change, it’s how many product lines need to be changed and how many different certifiers and regulators you need to update.
Best regards, Ron Wellman From: [email protected] [mailto:[email protected]] On Behalf Of IBM Ken Sent: Saturday, March 06, 2010 5:29 PM To: Monrad Monsen Cc: [email protected] Subject: Re: Agency Labels Without Manufacturer Name UL says you have to either identify the company name or put your UL file number on the label. I can't immediately quote where this requirement comes >from though... And this assumes you are concerned only with your North American NRTL certifications. I don't know what the EU requires on the label (I suspect it just has to match your DoC). -Ken A. On Sat, Mar 6, 2010 at 5:27 PM, Monrad Monsen <[email protected]> wrote: 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 <http://www.oracle.com> web site. Thanks. Monrad Monsen Oracle - 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]>
