I can’t imagine how the MSAs and customers contact the manufactures outside EU at easy. The MSAs may not have legal entitlement to execute their duties outside EU. Although EU goods have company name and address, the MSAs or customers still often approach the retail stores probably due to the purchase contract relationship.
Regards, Scott From: John Woodgate Sent: Wednesday, 6 February 2019 04:06 PM To: Scott Xe; [email protected] Subject: Re: [PSES] [BULK] [PSES] Economical operator name & postal addressonEEEproducts I think the setting up of EU 'presences' is contingency planning. There will be uncertainties about empowerment and responsibility even if there is a Brexit 'deal', spread out during and after the transition period. Relations with Brussels are bound to be better if there is an EU presence, whether it's absolutely necessary or not. You are right about the Blue Guide in English, but will it be interpreted in exactly the same way in every EU language? Then there is 'subsidiarity'; member states have some freedom to make local laws. You may remember that imported VCRs had to clear customs in Poitiers (in the middle of France) at one time. Similar situations could occur, and an EU presence would then be invaluable. It doesn't have to have a staff of 100. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-02-06 04:37, Scott Xe wrote: Dear Brian & Scott, Thanks for your excellent guides for this matter!! Currently we act as a manufacturer because the product has our own brand although the products are manufactured in China or other third countries outside EU. The technical files are located at our branch offices outside EU but can be retrieved electronically within a short notice. According to the Blue Guide, we do not need to change the name and postal address on the products even thought UK exits EU. However, lots of UK companies are setting up another offices or EU headquarters within EU/EEA such as Sony, Panasonic, Dyson, etc. and leave their UK office for UK market. Is this action of a finance consideration rather than regulation compliance? Regards, Scott From: Scott Aldous Sent: Wednesday, 6 February 2019 12:41 AM To: [email protected] Subject: Re: [PSES] [BULK] [PSES] Economical operator name & postal address onEEEproducts Hi Scott, I echo Brian's recommendation to read the relevant sections of the Blue Guide (2016 version is the latest I believe). You can download it here. See section 4.2 on Traceability. It has a detailed description of obligations of different economic operators with regard to identification for market surveillance authorities. This section references 768/2008/EC, which outlines obligations (see Articles R2, R3 and R4 in Annex I). On Tue, Feb 5, 2019 at 2:15 AM John Woodgate <[email protected]> wrote: 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 - ---------------------------------------------------------------- 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]> 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]> 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]> - ---------------------------------------------------------------- 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]> -- Scott Aldous | Regulatory Compliance Program Manager | [email protected] | 650-253-1994 - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]>
