The Low Voltage Directive 2006/95/EC states in annex III that a declaration of
conformity (DOC) "must contain the following elements: ... the last two digits
of the year in which the CE marking was affixed."  I note that a like
statement is not listed for the EMC Directive.  

I interpret this requirement as listing the year in which the CE mark was
first affixed to this model number product.  If true, then the signature date
on the DOC would not be adequate because a company may make a later change to
a DOC and re-issue the DOC long after the first CE mark was affixed to this
product line.

I looked through the DOCs of others in our industry, and I do not see this
being followed anywhere.  What are your interpretations of this requirement?

My interpretation is that the "last two digits of the year" statement is
merely a minimum of two digits, but it allows for using a four digit year. 
Most people avoid using two digit years after the year 2000 crunch, so I'd
prefer to use a four digit year.  

You can view the low voltage directive by going to
"http://ec.europa.eu/enterprise/electr_equipment/lv/direct/text.htm";
<http://ec.europa.eu/enterprise/electr_equipment/lv/direct/text.htm>  and
clicking on the language version of choice ("en" for English, etc.).  Again,
the requirement is found in annex III.

Thanks. 
-- 


Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
[email protected]
303.272.9612 Office

  


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