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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