Brian — I call this “private labeling.” The EU and presumably the customer want a match between the company name on the product and company name on the declaration, hence the expectation that they be the same. The Blue Guide often has additional detailed guidance on things like this. Mike Sherman Graco Inc.
Sent from XFINITY Connect Mobile App ------ Original Message ------ From: Brian Kunde To: [email protected] Sent: August 15, 2019 at 3:43 PM Subject: [PSES] Branding Products and EU Decision 768 NLF I'm not a Marketing person, so I do not know the official term for it, but there is a method of doing business where one company buy/sells a product made by another company marked with the brand name and trademark of the marketing company.I've always called this "Branding", but like I said it may officially be called something else.Here is the situation in more detail: Company-A designs and manufactures a great Electronic Widget and will produce the Widget in your company's color (Company-B), your company's name on the manual,and with your company's name and trademark on the front of the Widget.Company-A's name and address is on the Nameplate Label on the back of the Widget. Company-A handles everything including the Conformity Assessment, Generating the EU-DoC, Applying the CE marking, audits, inspections, etc.. All you have to do is market and sell it. Here is the Problem:According to the EU Decision 768 document also known as the New Legislative Format, paragraph 26, "Any economic operator that either places a product on themarket under his own name or trademark ....should be considered to be themanufacturerand should assume the obligations of the manufacturer." Company-B accepts the responsibility and liability of the Widget but there are many tasks called out that the "Manufacturer" must do that Company-B cannot do, such as the conformity assessment. Paragraph 21 states, "The manufacturer, having detailed knowledge of the designand production process, is best placed to carry out the complete conformity assessment procedure. Conformity assessment should therefore remain the obligation of the manufacturer alone." Company-B can be responsible for the conformity assessment, but they cannot carry out the procedure because they do not possess the required detailed knowledge of the design or production process. A customer purchasing the Widget from Company-B asked for a copy of the EU-DoC. The customer would not accept the EU-DoC because it was generated by Company-A.The customer insisted that Company-B generates the EU-DoC because per the NLF, Company-B is the "Manufacturer" and so all documentation should be in the letterhead of Company-B.Does Company-B have the credentials necessary to generate the DoC? Must the DoC be in the letterhead of Company-B or should the customer accept the DoC generated by Company-A? Thanks to all. The Other Brian - ---------------------------------------------------------------- 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 athttp://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]>
