I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision
768/2008 and I interpret it to mean you need a unique model number which can be
cross referenced with the TCF reports for that model. I am not seeing where it
requires each unit to have a unique ID# listed on the DoC which essentially
means a unique DoC to be shipped with each product?
As long as the DoC has unique model numbers listed for the equipment you are
declaring as compliant, and has the date of issue, the authorities can cross
reference this for compliance by checking the products model number and DOM
against the DoC which is required to be on the equipment being put onto the
market in the EU. And of course your TCF reports must cross reference to the
model number on the label.
Can you be more specific on which wording you are talking about?
What I found much more interesting was COM(2011) 773 final Annex IV seems to
infer that you must ("shall") include a color photo of the equipment on the DoC
4. Object of the declaration (identification of electrical equipment allowing
traceability.
It shall include a colour image of sufficient clarity to enable the
identification of the
electric equipment).
COM(2011) 773 final Annex IV references Annex III of NLF Council Decision
768/2008 which list the photo as optional
4. Object of the declaration (identification of product allowing traceability.
It may include a photograph, where
appropriate):
While this is not as onerous as having to have a unique DoC for each product it
will still mean a lot of work for companies to modify their current DoC's to
add the photos as I have never seen a DoC which included product photos.
From: [email protected] [mailto:[email protected]] On Behalf Of Crane, Lauren
Sent: Wednesday, January 09, 2013 5:14 PM
To: [email protected]
Subject: One DoC per manufactured Unit?!
As many know, the LVD is in the process of being recast for alignment with the
New Legislative Framework (NLF).
The Commission proposed text, (COM(2011) 773 final), calls for what looks like
a unique equipment identification number do be provided in the Declaration of
Conformity (DoC). The same sort of language is used in the NLF Council Decision
768/2008, and RoHS2 criteria for the DoC.
This seems to imply there must be a DoC provided with a unit that contains that
unit's unique identification number (e.g., serial number), and that a DoC that
references an entire model line would not be acceptable.
Hints that this is the case can be seen in the Parliament's proposed amendments
to the Commission's text of the LVD, where they cleverly change the unique unit
number into a unique DoC number (much easier to deal with).
====
Amendment 48 - Zuzana Roithová
Annex IV - point 1
Text proposed by the Commission --> 1. No xxxxxx (unique identification of the
electric equipment):
Amendment Proposed --> 1. No xxxxxx (unique identification of the declaration):
====
Also, the previous Draft version of the RoHS2 FAQ had a question 9.9 which
said, in effect "no, no, we meant a unique DoC number" has been entirely
withdrawn in the current version of the FAQ.
Does anyone reading have any additional perspective on this battle? Will a
"model line" DoC be possible in the future?
Regards,
Lauren Crane
KLA-Tencor
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