On June 29, 2022, the European Union published the newly revised Blue Guide, guidelines for products covered by EU harmonized legislation (I. e. CE-certified products).
Compared with the 2016 edition of the Blue Guide, the new revision in 2022 has not made any major adjustments in the overall framework, and only some chapters and some details have been modified.
This also means that products imported or manufactured by employers for their own use need to comply with EU specific product regulations and require the attention of manufacturers.
The guidance also notes that the actual fulfillment of an order for a product sold to an EU end-user by an online seller (including a fulfillment service provider) located outside the EU provides clear confirmation that the product has been placed on the EU market, regardless of whether the seller is in or outside the EU.
This means that the products that trigger "put to market" on online platforms and markets include C2C products.
At the same time, it is also clarified that the manufacturer of the final product can refer to the conformity assessment document of the component manufacturer when conducting the conformity assessment of the final product.
When the product is qualified, the manufacturer of the final product is obliged to evaluate the possible risks of the software integrated into the product when the product is put on the market., including "network risks" and "risk of loss of connection with the device.
In practice, the same version of the DoC may apply to many individual products manufactured in a series. Once the relevant content of the DoC changes, the DoC version of the product that has been put on the market must be updated for the change.
The 2022 edition of the Blue Guide points out that unless specified by specific legislation, security information still needs to be provided in paper form, and other random information of instructions can be provided in an easily accessible way through websites, electronic labels or two-dimensional codes, which means that random instructions also accept the form of websites, which will greatly reduce the presentation cost of manufacturer's instructions.
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