The NLF requires the importer and/or manufacturer name and address on the product. It is effective for the market surveillance to track the responsible party rather than previous trade name/mark that must be registered in EU. In terms of responsibility, the local importer still holds the legal responsibility as before. I am in doubt that the market surveillance will trace the manufactures who most are located in Far East or overseas.
Regards, Scott On 7/6/14 6:08 am, "T.Sato" <[email protected]> wrote: > On Fri, 06 Jun 2014 23:20:06 +0800, > Scott Xe <[email protected]> wrote: > >> Thanks! What is the major impact on own brand labelers? > > NLF directives such as 2014/30/EU defines "manufacturer" as > "any natural or legal person who manufactures apparatus or > **has apparatus designed or manufactured, and markets that apparatus > under his name or trade mark** ;" > > The new Blue Guide has some additional explanation on this: > "The manufacturer may design and manufacture the product himself. > As an alternative, he may have it designed, manufactured, assembled, > packed, processed or labelled with a view to placing it on the market > under his own name or trademark, and thus presenting himself as a > manufacturer (footnote 78). > ... > (footnote 78) Those manufacturers are often referred to as 'own brand > labellers' or 'private labellers'." > > > So, I think they will be required to take all the responsibility as > the manufacturer. > > Regards, > Tom - ---------------------------------------------------------------- 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]>
