Nice summary. From: Kunde, Brian [mailto:[email protected]] Sent: Tuesday, February 05, 2019 10:46 AM To: [email protected] Subject: Re: [PSES] Economical operator name & postal address on EEEproducts
Scott, Go to this link: https://ec.europa.eu/growth/content/%E2%80%98blue-guide%E2%80%99-implementation-eu-product-rules-0_en At the bottom of the page, click on “BLUE GUIDE 2016”. It should download the document in .pdf format. Go to page 30 which should be section 3.1 on “MANUFACTURER”. There is a lot of good information in this document. As I said, the word “Manufacturer” is given to the responsible person (natural or legal). As such, the Manufacturer has many responsibilities. “The manufacturer has ultimate responsibility for the conformity of the product to the applicable Union harmonisation legislation, whether he designed and manufactured the product himself or is considered as a manufacturer because the product is placed on the market under his name or trademark.” “The manufacturer is obliged to understand both the design and construction of the product to be able to take the responsibility for the product being in compliance with all provisions of the relevant Union harmonisation legislation. This applies equally to situations where the manufacturer designs, manufactures, packs and labels the product himself, as to situations where some or all of these operations are carried out by a subcontractor. The manufacturer needs to have the relevant information to demonstrate compliance of the product at its disposal.” “Union harmonisation legislation does not require the manufacturer to be established in the European Union. Thus, when placing a product on the Union market, the responsibilities of a manufacturer are the same whether he is established outside the European Union or in a Member State.” Under 3.1 subpart 5 regarding the Name and Address on the product, “The single contact point may not necessarily be located in the Member State where the product is made available on the market;” Also read the section 3.3 on IMPORTER. The importer takes on the role of Manufacturer (and responsibilities of) when they place a product from a “third country” on the EU market. In some cases, the name and address of the Importer should be added to the product in addition to the original third country manufacturer. I also highly recommend reading section 3.2.AUTHORISED REPRESENTATIVE. You will find that having a AR is the choice of the Manufacturer and not required even for Manufacturers outside of the EU. The AR is often mistaken as the “person responsible for compiling the Technical Documents” as required by some Directives such as the Machinery Directive. The ‘person’ can be anyone and does not have to be an AR. Hope this information was helpful. The Other Brian From: Scott Xe [mailto:[email protected]] Sent: Tuesday, February 05, 2019 4:44 AM To: Kunde, Brian; [email protected] Subject: RE: [BULK] [PSES] Economical operator name & postal address on EEEproducts Importance: Low 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]<mailto:[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 - ---------------------------------------------------------------- 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]>> LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- 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]>
