Completely agree The importer can do all the testing on the 1st sample, but then the manufacturer can make whatever they like with impunity and the importer takes on all the manufacturer change control risk for ongoing compliance without any means of controlling or monitoring it.
Barge pole at the ready regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> Registered in England and Wales, number 05466247 From: John Woodgate <[email protected]> Sent: 30 August 2018 10:01 To: [email protected] Subject: Re: [PSES] CE marking - mixture of responsibilities 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<http://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 - ---------------------------------------------------------------- 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]>
