I absolutely agree with Charlie because many “small importers” often have absolutely “no idea” of their responsibilities in law. “Been there, done that” as a private purchaser of electronic “stuff” from the Far East” from such importers in the UK that had supplied “non-compliant” kit – and so had to point out to them “the error of their ways”, and that was even before Brexit!
OTOH, when I was in “gainful employment” I used to (or try to!) teach both my employers and “general industry” (designed and ran “CE compliance” courses at reputable consulting and certification companies) and tried to emphasise and reinforce the need for compliance with their legal obligations – and thus the need for written, solid and enforceable & legally-binding agreements and documentation . John E Allen W. London, UK From: Charlie Blackham <char...@sulisconsultants.com> Sent: 06 May 2021 21:09 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU Authorized Representative service for Market Surveillance Regulation (EU) 2019/1020 Strictly speaking the manufacturer doesn’t need a formal agreement with the Importer, the importer take on that responsibility under the Directive as soon as they import something from manufacturer who is not in the EU The problem is that many “companies who import” don’t know that they are “importers” with responsibilities as defined in the directive The obligations on the importer are clear (in the Directive) and should be the responsibility of the importer alone, but experience of market enforcement is that these “companies who import” are doing what is required (and probably don’t know they need to as they may be importing products falling under multiple directives) and of course the “manufacturer” has their name on the product and packaging and is easy to identify Reality and best practice may well dictate that a written agreement is best way forward. Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton <emcl...@gmail.com <mailto:emcl...@gmail.com> > Sent: 06 May 2021 20:43 To: Charlie Blackham <char...@sulisconsultants.com <mailto:char...@sulisconsultants.com> >; EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU Authorized Representative service for Market Surveillance Regulation (EU) 2019/1020 Yes Charlie. I used the AR term loosely. There are five types of operator that qualify. Manufacturers still need a formal agreement with one of them. Best regards, Carl On 5/6/2021 2:33 PM, Charlie Blackham wrote: You don’t have to have an Authorised Representative as long as you have an importer who is prepared to act as an importer as defined in the NLF aligned Directives (such as current RoHS, EMC, LVD, RED etc.) Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton <mailto:emcl...@gmail.com> <emcl...@gmail.com> Sent: 06 May 2021 16:31 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] EU Authorized Representative service for Market Surveillance Regulation (EU) 2019/1020 Can anyone in the group offer one or more references for an Authorized Representative service within the EU that will satisfy the requirements mandated within Market Surveillance Regulation (EU) 2019/1020? This comes into effect on July 16. Please feel free to contact me directly at the CC email address above if you prefer. Thanks very much, Carl - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <emc-p...@ieee.org> 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
