Currently no requirements for labeling "Country of Origin: xxx" or "Made in xxx" under the Machinery Directive, right?
Best regards Amund Fra: Ted Eckert [mailto:[email protected]] Sendt: 8. oktober 2014 21:56 Til: [email protected] Emne: Re: [PSES] "Made in" labelling in the EU "Country of Origin: xxx" and "Made in xxx" generally carry the same meaning. However, they can have different meanings even in the same country. For example, the Buy American Act, 41 U.S.C. 10a-10c requires that a product manufactured in the U.S of more than 50% U.S. parts is to be considered Made in the USA for government procurement purposes. However, the Federal Trade Commission requires products to be "all or virtually all" made in the U.S. to carry the "Made in USA" labeling when sold to the general public. In the U.S., the rules for textiles get even more complicated and labeling may need to indicate both the country of origin of the materials and where the final product is manufactured. In general, each country/region is only going to be concerned about enforcing the "Made in xxx" strictly if you claim your product is made in that country. If final manufacturing/assembly is in a different country than where the product is sold, the county of final assembly can typically be marked as either "Made in xxx" or Country of Origin: xxx". Ted Eckert Compliance Engineer Microsoft Corporation <mailto:[email protected]> [email protected] The opinions expressed are my own and do not necessarily reflect those of my employer. These opionion also do not necessarily reflect the views of the Federal TradeCommision, other U.S. governement agencies or other governments around the world. For all I know, they may not reflect the opinion of anybody else on this list server either. From: Grasso, Charles [mailto:[email protected]] Sent: Wednesday, October 8, 2014 12:19 PM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] "Made in" labelling in the EU Hello - Does "Country of Origin xxx" mean the same as" Made in xxx" ? (The ISO symbol (a factory) implies a manufacturing function.) Best Regards Charles Grasso Compliance Engineer Echostar Communications (w) 303-706-5467 (c) 303-204-2974 (t) [email protected] <mailto:[email protected]> (e) [email protected] <mailto:[email protected]> (e2) [email protected] <mailto:[email protected]> From: Scott Xe [mailto:[email protected]] Sent: Tuesday, October 07, 2014 10:46 AM To: [email protected] <mailto:[email protected]> Subject: Re: [PSES] "Made in" labelling in the EU It may be a political issue to identify the country that does not have a good image or has a good image in customers' mind before they purchase the products. Now all the EEE have the trade mark, model no, importer name and address for traceability. The country of COO does not have power to change the quality but the brands do. Scott On 7 Oct, 2014, at 11:10 pm, Monrad Monsen <[email protected] <mailto:[email protected]> > wrote: 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-a16d3d 05368d _____ From: "Scott Xe" <mailto:[email protected]> <[email protected]> To: "EMC-PSTC" <mailto:[email protected]> <[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 - ---------------------------------------------------------------- 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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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] <mailto:[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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[email protected]> > - ---------------------------------------------------------------- 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]>
