I would agree with your interpretation, with a caveat in regard to your use of four digits for the year.
We have, in the past, been told by the MHRA (the enforcing body for the Medical Devices Directive in the UK) that we were not allowed to put the year number on DofC's because it might be confused with the notified body (NB) number for a product where the NB number is a requirement (i.e. where the manufacturer's quality system has to be assessed). This was for a two digit year number so I imagine they'd take a very dim view of the use of four digits (since this is the standard format for a notified body number). Our (unofficial) response to this was to conclude that the MHRA don't know the rules which apply to products which are not medical devices very well, and to ignore them in these cases. However, we do take care to ensure the digits are not present on DofCs for medical devices - the MDD and the directives which require the digits of the year are mutually exclusive so this is the correct approach. Nick. At 19:09 -0600 2/6/08, Monrad Monsen wrote: >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 > >Monrad L. Monsen >Compliance Program Manager >Storage Group >Sun Microsystems ><mailto:[email protected]>[email protected] >303.272.9612 Office > > > - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
