James & PSnet folks,
I could envision a scenario that could be more comfortable for all. If the
same product was sold worldwide and bore a US NRTL (UL, etc) mark along with
the CE marking then the importer would know that the factory was having
quarterly construction inspections. At the Euro end just audit the incoming
and ensure that the US NRTL mark continues to appear on the product. there are
still outstanding issues but the largest exposure is covered.
:>) br, Pete
-----Original Message-----
From: John Allen <[email protected]>
To: EMC-PSTC <[email protected]>
Sent: Thu, Aug 30, 2018 6:34 am
Subject: Re: [PSES] CE marking - mixture of responsibilities
Head in hands – and liability insurance paper in back pocket (hopefully)!
From: James Pawson (U3C) [mailto:[email protected]]
Sent: 30 August 2018 13:18
To: [email protected]
Subject: Re: [PSES] CE marking - mixture of responsibilities
Charlie, John, thanks for the insightful feedback as always.
The latest email from the manufacturer doesn’t do much to inspire confidence!
James
From: Charlie Blackham <[email protected]>
Sent: 30 August 2018 10:29
To: [email protected]
Subject: Re: [PSES] CE marking - mixture of responsibilities
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
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
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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