All good points, and kind of what I thought. I know our shipping department does not provide the DoC with their documentation. I don't think our Sales/Marketing wants to give this responsibility to our Shipping Department.
Does anyone just include a document with the shipper that includes the URL to download the DoC off the company website, if needed? Just a thought. Pros? Cons? The Other Brian -----Original Message----- From: John Woodgate [mailto:[email protected]] Sent: Friday, November 15, 2013 9:54 AM To: [email protected] Subject: Re: [PSES] Rejected Manufacturer Declarations In message <64D32EE8B9CBDD44963ACB076A5F6ABB0266DBB8@Mailbox-Tech.lecotech.local>, dated Fri, 15 Nov 2013, "Kunde, Brian" <[email protected]> writes: >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. If there is a suspicion of non-conformity, even 'technical' rather than substantive, i.e. only documentation or marking is incorrect, the product cannot cross the border and is impounded. > >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. No, but it's sensible. If the regulator wants to see the DoC but it isn't there, the product is likely to be impounded until it is there. >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? I advise putting a copy with the shipping documents, which M le Douane has in his hot little hand. > >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? Largely irrelevant: what is required for a quiet life is relevant. >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? Yes. >Do the authorities have to provide such a reason? Not immediately, and if challenged, they will definitely find 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. Be prepared. Go the extra kilometre. Co-operate with Herr Zoll. Don't try to stand on your rights on principle; it is not in your interest. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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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://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]>
