The responsibilities of importers and authorized representative specified in Directives and Regulations are insufficient to qualify as 'responsible person', because the 'responsible person' has to know that no changes have been made to the product that would affect its compliance. In other words, that person must have access to all the manufacturing data for the product.

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-02-05 09:44, Scott Xe wrote:

Dear Brian,

Thanks for your useful info!  Must the responsible person be in EU/EEA countries?  Otherwise the responsible person will fall into the importers or authorized resprentatives who is in EU/EEA countries?

Regards,

Scott

Scott,

The short answer to your question is, the name and address of the responsible party for placing a product on the EU market is required to be on the products.  EU documents often refer to the responsible party as the “Manufacturer” even though the responsible party may not have manufactured the product.

Read the “Blue Guide” on the implementation of the EU products rules 2016/C 272/01 (unless there is a newer version).  It does a good job explaining the many possible roles and players under the New Legislative Form.

The Other Brian

*From:*Scott Xe [mailto:[email protected]]
*Sent:* Saturday, February 02, 2019 3:19 AM
*To:* [email protected]
*Subject:* [BULK] [PSES] Economical operator name & postal address on EEE products
*Importance:* Low

Regarding the name & address on EEE products in EU market, should they be the manufacturers, importers or authorized representatives and which regulation does call for it?

Thanks and regards,

Scott

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