I believe that is reason why the directives lay down clear obligations of each economic operator. They are not allowed to determine by themselves.
Rgds, Scott From: Nyffenegger, Dave <dave.nyffeneg...@bhemail.com> Sent: Wednesday, 20 March 2019 10:51 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Postal address on product labelling... Been there, done that, heading for the wall. I have seen many products that seem to be commission/distributed by a US or European company but actually manufactured by a third party in China or such which does all the compliance certification. They don’t want to put the actual manufacturer contact info on the product but often these distributors are also not able to provide much for product specifications and compliance information either. -Dave From: Brian Kunde [mailto:bkundew...@gmail.com] Sent: Wednesday, March 20, 2019 10:19 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] Postal address on product labelling... The companies I have worked for over the last 40 years have relied heavily on international sales, so having your company's name and address on the product is just part of doing business. I'm not sure what the argument is with having your address on the product. My questions to those who complain would be, "Why Not?". As far as the requirements of EU Directives go, keep in mind that what they are asking for is the name and address of the responsible party for the compliance of the instrument. The Directive refers to this legal person or entity as the "Manufacturer", but that does not mean it is the company who actually builds the product, thou in most cases they are one and the same. Personally, I'm surprised that the writers of the EU Directives, the Commission, Legal Authorities in all Countries, etc. don't require some type of information on ALL PRODUCT, be it an address, phone number, fax number, email address, website, etc. that provides IMMEDIATE RESPONSE from the responsible party or at least within 48 hours. AND the system, whatever it is, must always be active, and only used by authorities and/or anyone regarding a Compliance Issue or Question. Kind of like a reverse 911 (emergency number in the States). For those of you who deal in Product Safety and RoHS where you need to contact component manufacturers for supporting documentation knows what I'm talking about. I hate it when you go to a company's website, fill out a three-page on-form requesting compliance information, and then never EVER getting a reply. OR, you call the "corporate office" for the address that is labeled on the Nameplate of the product and IF you can get through to a Real Live Person, you asked for the Compliance Department and the person has no idea who to transfer you to. After being transferred to 5 potential people you finally get ahold of something who says their products are built in another country somewhere and they "THINK" compliance is handled by them. Does this sound at all familiar to anyone? Once again, I'm glad I'm over the hill and gaining speed for a head-first collision into the wall call retirement. Let you young pups figure out how to resolve all the problems of the world. The Other Brian On Wed, Mar 20, 2019 at 9:41 AM Charlie Blackham <char...@sulisconsultants.com <mailto:char...@sulisconsultants.com> > wrote: Matthew “But Sir, they’re not doing it” isn’t a defence in court or when you’re equipment is stuck in customs, or a competitor has pointed market enforcement authorities in your direction The key phrase is “…or, where that is not possible, on its packaging or in a document accompanying the apparatus…..” To my knowledge there’s no guidance anywhere as to “what is possible”, so it’s probably up to you and your lawyers 😊 Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com Registered in England and Wales, number 05466247 From: Matthew Wilson <matthew.wil...@gbelectronics.com <mailto:matthew.wil...@gbelectronics.com> > Sent: 20 March 2019 13:06 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] Postal address on product labelling... Does anyone else have endless arguments about the need to put a postal address on products as per the EMC and LVD requirements? The EMC directive obliges the following (article 7.6 of 2014/30/EU). The LVD also had the exact same obligation (article 6.6 of 2014/35/EU); ?Manufacturers shall indicate, on the apparatus, their name, registered trade name or registered trade mark and the postal address at which they can be contacted or, where that is not possible, on its packaging or in a document accompanying the apparatus. The address shall indicate a single point at which the manufacturer can be contacted. The contact details shall be in a language easily understood by end-users and market surveillance authorities.? Manufacturer is, of course, meaning the entity responsible for the product denoted by the brand name present on the apparatus. And every time I encounter this advice being questioned someone always says 'But [some large entities/corporations supplying consumer products - you can pick your own example] don't put their address on their products.' Well they should! Maybe those devices with screens allow you to look up the address somewhere in the operating system? Humph! Sorry just letting off steam :-) _____ Matthew Wilson Technical Director <https://gbelectronics.uk> https://gbelectronics.uk T: +44 (0)1903 244500 F: +44 (0)1903 700715 Ascot House // Mulberry Close // Woods Way Goring-by-Sea // West Sussex // BN12 4QY // UK Electronics Design // Manufacturing // Component Distribution <https://gbelectronics.uk/quality/standards> Want to send us a file? https://www.mailbigfile.com/gbelectronics _____ GB Electronics (UK) Limited is a company registered in England and Wales Company Registration No: 06210991 VAT Registration No: GB 925 1744 25 Registered Office: Ascot House, Mulberry Close, Woods Way Goring by Sea, West Sussex, BN12 4QY Disclaimer: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. 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