CMC Decision 3 - Manufacturers Address Content Requirements

pkost

Trusted Information Resource
#1
The CMC has issued a decision stating that the manufacturers address should contain the following information:

street/road,
number/house/floor,
postal code
city
state/region and
country

Although I fully understand the reasoning behind the decision I can see that it leave very little room for exceptions, however justifiable.

I've spoken to notified bodies and a couple of competent authorities. The general concensus is that this is going to be forced through (even though it goes against the harmonised standard - apparently CMC have requested a change)

How are other companies handling this? This isn't going to be cheap for us to do, we've estimated close to 1,000,000 GBP to comply.
 
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Ronen E

Problem Solver
Staff member
Moderator
#2
The CMC has issued a decision stating that the manufacturers address should contain the following information:

street/road,
number/house/floor,
postal code
city
state/region and
country

Although I fully understand the reasoning behind the decision I can see that it leave very little room for exceptions, however justifiable.

I've spoken to notified bodies and a couple of competent authorities. The general concensus is that this is going to be forced through (even though it goes against the harmonised standard - apparently CMC have requested a change)

How are other companies handling this? This isn't going to be cheap for us to do, we've estimated close to 1,000,000 GBP to comply.
Thanks for that.

The decision text: http://www.cmc-md.eu/mediapool/97/978504/data/Decision_3_COEN-1.pdf
 
M

MIREGMGR

#3
How are other companies handling this?
Our past and current practice on our-responsibility products already complies, so no changes needed.

We will change our explanations to the occasional new customer that wants us as a contract manufacturer with their own label spec, but doesn't know the rules well.

We used to explain that the allowed minimums were less than what we considered best practice. Now we can skip over that sub-topic, since the minimums and our view of best practice are aligned.
 

pkost

Trusted Information Resource
#4
MIREGMGR - be careful in your interpretation - the minimums are not aligned.....the CMC decision has no legal standing in the EU and cannot issue requirements. The point here is that they are trying to force their decision on everyone (I'll accept that it may be beneficial).

They are trying to get EN 1041 ammended to align with their decision but even then harmonised standards are not a requirement!
 
M

MIREGMGR

#5
It doesn't really matter much if our understanding of acceptable minimums is in error, because without recent exception such customers accept our suggestion as to best practice, which will satisfy any requirement put forth so far.
 
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