Interesting. I am concerned about adding more country of origin (COO)
laws and rules that apply only to a certain geography. There are too
many ways that such COO laws will conflict. One of the difficulties
already is that each component will have a COO marked plus the fully
assembled system will have a COO. However, it might not be clear which
COO marking is for the component and which is for the fully assembled
system.
Even worse, a computer might be assembled with power supply, fans and
motherboard in one country ... but then receive the customization for an
individual customer of a specific speed CPU, memory DIMMs and hard disk
drive at another country before being shipped to the final customer. I
am not a COO subject matter expert, but I am told that the COO could
change from the first country to the second country (that added the CPU,
DIMMs & HDD) if the value of the product changed more than 40%
(requirement of some customer countries) or the capability of the
product changed (certainly the product couldn't function without a
CPU). Hence, what used to be the COO from the first country would then
be updated with a new COO at the 2nd country. Stretching this
hypothetical example further, this computer could be shipped to a
value-added reseller that adds software, cards and other features to
make the computer's purpose more focused on medical or telecom uses
which may change the system's COO yet again.
I like the ISO graphical symbol for COO that is suggested in this chain
of discussion.
https://www.iso.org/obp/ui/#iec:grs:60417:0:6049
However, I am concerned that this graphical symbol will be seen
everywhere on the product and the customer really won't know any more
information than if COO was not on the product in the first place. I
agree with Brian that COO really doesn't matter for the safety of our
customers. Instead, they need to know the brand name manufacturer and
contact information since that brand name manufacturer takes
responsibility for the design and safety/EMC compliance of the product.
Monrad
Note: /The statements and opinions expressed here are my own and do not
necessarily represent those of any company I work for/.
On 10/3/2014 12:42 PM, Mike Sherman ----- Original Message ----- wrote:
Good summary of what I know is here:
http://www.lexology.com/library/detail.aspx?g=ff7bd38f-0f81-4e5f-94c7-a16d3d05368d
------------------------------------------------------------------------
*From: *"Scott Xe" <[email protected]>
*To: *"EMC-PSTC" <[email protected]>
*Sent: *Friday, October 3, 2014 11:27:33 AM
*Subject: *[PSES] "Made in" labelling in the EU
I have learnt that EP is working on a new law of origin marking
proposed by consumer product safety and market surveillance and going
to be in force next year. There should not be no direct relationship
with product safety but may improve the traceability of products.
Does anyone know when the new law become available?
Thanks and regards,
Scott
-
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