Hi Scott,

I think that two important points to consider for anyone re-branding a
product is this:

The new Radio Equipment Directive states:

"The manufacturer, having detailed knowledge of the design and production
process, is best placed to carry out the conformity assessment procedure.
Conformity assessment should therefore remain solely the obligation of the
manufacturer. "

It then states:

"Any economic operator that either places radio equipment on the market
under his own name or trade mark or modifies radio equipment in such a way
that compliance with this Directive may be affected should be considered to
be the manufacturer and should assume the obligations of the manufacturer. "


The Directive effectively also states that any importer who has concerns
about the compliance of the device they import, should get it tested.

"When deemed appropriate with regard to the risks presented by radio
equipment, importers shall, to protect the health and safety of end-users,
carry out sample testing of radio equipment made available on the market,
investigate, and, if necessary, keep a register of complaints, of
non-conforming radio equipment and radio equipment recalls, and shall keep
distributors informed of any such monitoring.

Importers who consider or have reason to believe that radio equipment which
they have placed on the market is not in conformity with this Directive
shall immediately take the corrective measures necessary to bring that radio
equipment into conformity, to withdraw it or recall it, if appropriate.
Furthermore, where the radio equipment presents a risk, importers shall
immediately inform the competent national authorities of the Member  states
in which they made the radio equipment available on the market to that
effect, giving details, in particular, of the non-compliance and of any
corrective measures taken. "


Thanks,   Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-----Original Message-----
From: Scott Xe [mailto:[email protected]] 
Sent: 06 June 2014 16:20
To: [email protected]
Subject: Re: [PSES] New EU Directives

Thanks!  What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, "T.Sato" <[email protected]> wrote:

> On Fri, 6 Jun 2014 00:49:58 +0800,
>   Scott Xe <[email protected]> wrote:
> 
>> Is there any reason behind to have LVD, EMC and R&TTE directives 
>> updated in similar time?
> 
> To align them with NLF, all the new approach directives which were not 
> aligned with NLF were/will be updated even if no other changes were 
> necessary.
> 
> For some directives such as R&TTED (RED), other significant changes 
> were also made.
> 
> NLF itself have big impact, and I guess own brand labelers who 
> supplied completed product from OEMs may have hard time.
> 
> Regards,
> Tom
> 
> -
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