Paul, Thank you for your observation. The situation in many sectors is as you say. There are exceptions and the requirements are stated to cover those times when there is a lag between declaring the product compliant and taking it to market. The other reason why you should not mix the use of 'dates and digits' is more pragmatic. If you do not separately identify the last two digits then you are in breach of the requirements of the Directive. This then means that you could be prosecuted, although, it is unlikely that much of a case could be made out of this. The enforcement person could, however, use this to start an investigation into your other documentation and ultimately your equipment on the basis of 'reasonable doubt'. This then involves a significant amount of activity and in most cases cost. The enforcement officer could, as a precautionary measure, prevent all shipments of your products to Europe until the issues is resolved. My experience working for many enforcement agencies in the UK is that this is a people business. The career prospects for junior Trading Standards and Health and Safety Executive officers only improve if they can demonstrate a keen interest in obtaining cautions or prosecutions. The advice that I have always passed on, and which I received from a senior Trading Standards Officer, is never invite investigation unless you have a reason to do so.
> -----Original Message----- > From: Paul J Smith [SMTP:paul_j_sm...@notes.teradyne.com] > Sent: Thursday, August 05, 1999 6:10 AM > To: Alan Brewster > Cc: 'Chuck Seyboldt'; EMC-PSTC Discussion Group > Subject: RE: year in which the CE mark was affixed" marked on > Declaration of Conformity > > Alan, > > Why not use the dated signature of the authorized senior personnel on > the D of C > meet this year code specification on the document? It would seem > correct to > use that date since it generally is the first time that the product is > CE marked > to be placed on the EU market. Please comment > > Paul J. Smith > Compliance Engineer > Teradyne, Inc. > Boston > > > > > Alan Brewster <abrews...@ccsemc.com> on 08/04/99 05:51:38 PM > > Please respond to Alan Brewster <abrews...@ccsemc.com> > > To: "'Chuck Seyboldt'" <cbo...@nlis.net>, EMC-PSTC Discussion Group > <emc-p...@ieee.org> > cc: (bcc: Paul J Smith/Bos/Teradyne) > Subject: RE: The meaning of "Affixed" > > > > > > Greetings, > > The need to have "the last two digits of the year in which the CE mark > was affixed" marked on the Declaration of Conformity is simply to make > the job of enforcement officers simpler. It is bourne out of the very > nature and application of the LVD in that there are many electrical > products that have been in serial production since the introduction of > the Directive in the early seventies. During my four years as a > Notified > Body signatory in the UK, I saw many products that also followed a > fashion cycle. It is not unusual for items such as lighting products > to > lie dormant for a number of years e.g.: the Lava Lamp. > There is some confusion about the format of the use of the last two > digits. my advice has always been to find space in the middle of the > page and put "99". Whilst this looks odd it follows, to the letter, > the > requirement and again it is worth remembering that the intended > audience > for D of C's are the enforcement folks. > The D of C should not be changed from year to year. The only reason > for > doing this would be if the product was revised, or the source of > manufacture was changed to sufficiently need the re-definition of the > product. This might be the case for a retailer who was sourcing an > item > from a new factory each season. > I hope that this is of interest. > > > Alan > ______________________________________________________________________ > __ > _ > Alan Brewster > Compliance Certification Services > 1366 Bordeaux Drive > Sunnyvale, CA 94089-1005 > Tel: 408-752-8166 ext. 122 > Fax: 408-752-8168 > e-mail: abrews...@ccsemc.com > http://www.ccsemc.com > > > > > -----Original Message----- > > From: Chuck Seyboldt [SMTP:cbo...@nlis.net] > > Sent: Tuesday, August 03, 1999 10:54 AM > > To: EMC-PSTC Discussion Group > > Subject: The meaning of "Affixed" > > > > > > > > The requirements for the contents of a Declaration of > > Conformity under the Low Voltage Directive were amended by > > Directive 93/68/EEC. > > > > Directive 73/23/EEC is hereby amended as follows: > > . . . > > ANNEX III > > CE CONFORMITY MARKING AND EC DECLARATION OF CONFORMITY > > . . . > > B. EC declaration of conformity > > The EC declaration of conformity must contain the following > > elements: > > . . . > > - the last two digits of the year in which the CE marking > was > > affixed. > > > > > > I recognize that this requirement is a "formality" but I > > am interested in understanding how to comply, particularly when > > the goods are produced substantially unchanged, year after year. > > > > One could argue that "affixing of the CE mark" means > > affixing the CE mark to the goods, and that a new declaration is > > to be prepared at least once per year, in order that the proper > > year is recited on the declaration. > > > > But, I have seen DofC's that clearly are not done in this > > fashion. For example, Allen Bradley keeps a series of DofC's > > online - and for currently produced goods, the latest year > > appearing on one DofC is 1995. > > > > Obviously, it is easier to NOT revisit the DofC in the > > case of series production. Naturally, a freshly prepared and > > dated DofC can be expected when a new model is introduced, or a > > change in an existing model is made that requires a technical > > re-evaluation (e.g. a design change that warrants updating the > > design justification in the Technical File), but is it the > > intent of the subject 93/68/EEC amendments to create an > > obligation to create annually dated DofC's for each year that > > series production is undertaken? > > > > It is interesting that the Low Voltage Directive has this > > requirement, and Directive 93/68/EEC also likewise amended these > > Directives . . . > > > > Directive 87/404/EEC (relating to simple pressure vessels) > > Directive 89/686/EEC (relating to Personal Protective Equipment) > > Directive 90/384/EEC (relating to non-automatic weighing > instruments) > > Directive 90/396/EEC (relating to appliances burning gaseous fuels) > > Directive 92/42/EEC (relating to Boilers) > > > > . . . but the recent Pressure Equipment Directive, > > 97/23/EC, does not have a requirement to include "the last two > > digits of the year in which the CE mark was affixed" on the DofC. > > > > Does anybody here know the original intended purpose for > > including the "year of affixing" requirement? > > > > Thanks in advance for your insights - on this decidedly > > non-technical matter. > > > > Regards, > > Chuck Seyboldt > > > > > > --------- > > This message is coming from the emc-pstc discussion list. > > To cancel your subscription, send mail to majord...@ieee.org > > with the single line: "unsubscribe emc-pstc" (without the > > quotes). For help, send mail to ed.pr...@cubic.com, > > jim_bac...@monarch.com, ri...@sdd.hp.com, or > > roger.volgst...@compaq.com (the list administrators). > > > > --------- > This message is coming from the emc-pstc discussion list. > To cancel your subscription, send mail to majord...@ieee.org > with the single line: "unsubscribe emc-pstc" (without the > quotes). For help, send mail to ed.pr...@cubic.com, > jim_bac...@monarch.com, ri...@sdd.hp.com, or > roger.volgst...@compaq.com (the list administrators). > > > > > > > --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).
