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
>
>
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