I have a copy of the "Guidelines on the Application of the Council Directive 73/23/EEC" (the LVD). These guidelines were published by the European Commission Directorate-General in July 1997. It states the following as one of the items that must be included in the DoC: "the last two digits of the year in which the CE marking was affixed (for the first time)." This document is available at http://www.ce-mark.com/low_voltage_guide.html <http://www.ce-mark.com/low_voltage_guide.html> .
Kurt Andrews Compliance Engineer Tracewell Systems, Inc. 567 Enterprise Dr. Westerville, OH 43081 Ph. 614-846-6175 Fax 614-846-7791 Email: [email protected] -----Original Message----- From: [email protected] [SMTP:[email protected]] Sent: Wednesday, August 04, 1999 5:02 AM To: Nick Williams Cc: Chuck Seyboldt; EMC-PSTC Discussion Group Subject: Re: The meaning of "Affixed" I agree with Nick's interpretation that it means the year when the CE Marking was first affixed to that product type for which the Declaration was produced. We consider that dating the Declaration when produced meets this requirement. If the Declaration has to be amended because new standards have had to be applied or because the product design changed, we consider that a new issuing of the Declaration and the Mark and so the Declaration carries the date of that new issue. Many Directives do not require the year to be marked alongside the CE Mark, but (for example EMC Directive) do not require it to be marked anywhere else on the product. Roger Viles WWG Nick Williams <[email protected]> on 03/08/99 22:13:34 Please respond to Nick Williams <[email protected]> To: Chuck Seyboldt <[email protected]>, EMC-PSTC Discussion Group <[email protected]> cc: (bcc: Roger Viles/PLY/Global) Subject: Re: The meaning of "Affixed" I take 'affixed' to mean the year in which the 'risk assessment' was done and the product was first placed on the EU market. Without doing a trawl through every directive to check the the point, I would guess that those directives which do not require the year to be given along with the CE logo require that the date of manufacture be marked on the product. This is certainly true for the PED. rgds. Nick. At 13:53 -0400 3/8/99, Chuck Seyboldt wrote: > 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 [email protected] >with the single line: "unsubscribe emc-pstc" (without the >quotes). 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