I too provided on request, however I also provided a condensed version of the DoC in the manual. This was placed on the second and third page in the manual, you might call it a Regulatory page(s). For the CE Declaration potion it would have contact info of the Manufacturer and the European Rep, the model (s) covered, and applicable directives applied. It did not have all the applicable standards and dates or signatory information. If it was held up at customs or by request, I would send an actual copy of the DoC. If the product volumes were low I would just include it in the shipping docs. Not sure what the legal requirements are, although I hear a lot of opinions.
-----Original Message----- From: Wiseman, Joshua E [mailto:[email protected]] Sent: Friday, November 15, 2013 9:31 AM To: [email protected] Subject: Re: [PSES] Rejected Manufacturer Declarations We used to provide them on request and that was pretty much it. Recently I convinced our export group to include a copy with the shipping docs for every shipment that goes to the EU. This seems to be reducing a lot of the questions (delays) we were having. Josh -----Original Message----- From: Kunde, Brian [mailto:[email protected]] Sent: Friday, November 15, 2013 8:20 AM To: [email protected] Subject: [External] Re: [PSES] Rejected Manufacturer Declarations You are referring to the document as a "Manufacturer Declaration" where I would refer to it as an "EU Declaration of Conformity". I've seen declaration documents that say "Manufacturers Declaration", usually for components, but they are not official EU DoCs. Are you sure your rejection was because of the Letter Head or because of the Header on your document? I am very interested in such stories as these because I'm not clear on the current required documentation or the Authority a Customs agent has regarding CE compliance, and the EU-DoC. In your case specific, where did the Customs Agent get your DoC? Though I'm not familiar with all EU Declarations, I believe that shipping the DoC with the product, though becoming more common, is not a requirement. The MD, for instance, says the DoC OR a document calling out the contents of the DoC should be in the manual. But what Customs agent is going to rip open 12 layers of cardboard, vacuum seal, and plastic wrap to search through a 300 page manual? What if it is an E-Manual? Do most people include the DoC with the shipping documentation, provide the DoC only when requested, or just include a copy in the box with each item? What is legally required? Though the CE Marking on the product is required I believe the EU-DoC just has to exist and be made available upon request. Since compliance is assumed, if an Authority requires to see your DoC isn't that a sign that the compliance of your product is in question for some reason? Do the authorities have to provide such a reason? I know the EU is trying to stop counterfeit and non-compliant devices from entering which may be the reason for requiring the DoC in Customs among taking other such steps. So far, our company's products have not been burdened by these additional measures but I would like to be prepared for the future. Thanks for listening to me. The Other Brian - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
