Run, do not walk, away from this manufacturer. Either they are
dangerously unaware of the EU requirements, or they are deliberately
avoiding commitment.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2018-08-30 08:48, James Pawson (U3C) wrote:
Hello all,
I’m working with a company who are importing some IT products from
China to the EU. The Chinese manufacturer is taking a very much “hands
off” approach to approvals, expecting the importer to draw up the DoC
and perform much of the testing. However access to the parts of the
Technical File that detail product construction are being held by the
manufacturer and getting access to these is not straightforward.
My question is: provided that all the documentation boxes are ticked
and the product has been sufficiently assessed, can one reasonably
take on responsibilities for other actors in the supply chain in this
manner?
I’m undecided if this is acceptable. My feeling is that whilst it is
not to the letter of the law, it is to the spirit and would be
acceptable depending on the importers tolerance to risk. However the
letter of the directives is explicit in determining responsibilities
e.g. that the manufacturer shall draw up the DoC.
I would be interested to hear your thoughts on the matter.
Thanks and all the best
James
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