John, Our DoCs are currently in the manual, but for the last 6 years the manuals are only available in electronic format (on CD). So the customs guys would not be able to see the DoC from what we ship anyway. I'm not aware of any issues this has caused, so far. But who knows what the future holds.
Thanks, The Other Brian -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of John Woodgate Sent: Thursday, July 25, 2013 3:46 PM To: [email protected] Subject: Re: More DoC Questions In message <64D32EE8B9CBDD44963ACB076A5F6ABB0265E1CC@Mailbox-Tech.lecotech.local>, dated Thu, 25 Jul 2013, "Kunde, Brian" <[email protected]> writes: >1. The LVD, MD, and EMCD refer to the DoC in the annex as "EC >Declaration of Conformity". But in the RoHS Directive, it is referred >to as "EU Declaration of Conformity". Is one more correct than the >other or is EC and EU both acceptable as the title of your DoC? The designation changed from EC to EU a few years ago. The Directives haven't caught up yet. > >2. The Machinery Directive states in several locations that the DoC >must "accompany the machinery". Now I get burned by definitions all >the time so your input to the meaning of "accompany" is appreciated. >One might say this means that the DoC has to be in the box when you >ship the product; another's would say the DoC has to be created or >exist or occur at the same time as the product is placed on the market, >but the DoC does not have to physically ship with the hardware. My advice is to interpret it literally and send a copy with the product. That way Herr Zoll or Monsieur Douane can't impound the shipment for a month while he gets round to demanding a copy of the DoC. > >Does the DoC even have to be provided to the customer or can it just be >made available upon request, or make it available for download online? >Can we provide the DoC separately such as via an email to the customer >or as part of the Sales Agreement Documentation? There appears to be no legal requirement for the customer to see the DoC, because it's information intended for Customs and Market Surveillance. But many customers demand to see it anyway. > >We currently provide the DoC in the User's Manual but it has become a >nightmare. Any time a standard or directive number or date changes, we >have to create all new DoCs. This means hundreds of new or revised >prints, part numbers, and ECNs to update thousands of Bill of >Materials. Manual Packs already built have to be reworked. So we really >need to get the DoC out of our BOM system because of how often it changes. Print it on a separate piece of paper, not in the manual, and include it with the shipping documents. That's where Zoll and Douane will look for it. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Why is the stapler always empty just when you want it? John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]> ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
