Dear Nick and Roger:
Thank you for your responses. The protocol that both of you
are advocating is the one in common use, and is also what we have
been advising our clients.
The plain language of the Directive seems to point the other
way, however. The language does not say that the DofC is to be
identified with "the FIRST time the CE mark is affixed" and the CE
mark is not affixed to the DofC, but rather to the goods. So, if
the CE mark is affixed to the goods in 1999 (and the DofC has no CE
mark on it), the plain language of the Directive says that the DofC
shall contain a "99" as a year identifier.
I doubt there would ever be a substantive issue, where a
company has design and production records that enable a correct
association between any given sample of a product, the date
(approximate) it was produced, and the declaration that is intended
to apply to it. Just another one of those legal curiosities.
Regards,
Chuck Seyboldt
On Wed, 4 Aug 1999 [email protected] wrote:
> 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.
> Nick Williams <[email protected]> on 03/08/99 22:13:34
> I take 'affixed' to mean the year in which the 'risk assessment'
> was done and the product was first placed on the EU market.
> At 13:53 -0400 3/8/99, Chuck Seyboldt wrote:
> >Directive 93/68/EEC.
> > Directive 73/23/EEC is hereby amended as follows:
> > - the last two digits of the year in which the CE marking was affixed.
> > 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.
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