Well said Charlie. In my case I have to cover those circumstances where
there is no "importer" in the chain.
Thanks,
Carl
On 5/6/2021 4:09 PM, Charlie Blackham wrote:
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/ <https://sulisconsultants.com/> *
Registered in England and Wales, number 05466247
*From:*Carl Newton <[email protected]>
*Sent:* 06 May 2021 20:43
*To:* Charlie Blackham <[email protected]>;
[email protected]
*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/ <https://sulisconsultants.com/> *
Registered in England and Wales, number 05466247
*From:*Carl Newton <[email protected]> <mailto:[email protected]>
*Sent:* 06 May 2021 16:31
*To:* [email protected] <mailto:[email protected]>
*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
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