Hi The Other Brian:
“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 of the other markings and stuff are just fluff. They don’t count for
compliance. They don’t have to be there for compliance. The Widget “belongs”
to Company A despite the Company B markings and stuff.
"Any economic operator that either places a product on the
market under his own name or trademark .... should be considered to be
the manufacturer and should assume the obligations of the manufacturer."
The key word is “should,” which is NOT “must.” In this case, Company B, while
placing the Widget on the market is NOT the manufacturer. Company A has the
obligations of the manufacturer.
“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.”
Call your customer’s attention to Company A’s nameplate. The nameplate is the
only valid data; what Company B marks on the Widget (including the Company B
name), from a regulatory point of view, is simply fluff. I suppose you could
ask Company A to include a statement on the DoC to the effect that the Widget
is also marketed as a Company B Widget.
Best regards,
Rich
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