The new DoC concept for the LVD says in COM2011-0773 (referring to 768/2008)
==================== ANNEX IV [Annex III of Decision No 768/2008/EC] EU DECLARATION OF CONFORMITY 1. No xxxxxx (unique identification of the electric equipment): 2. Name and address of the manufacturer or his authorised representative: 3. This EU declaration of conformity is issued under the sole responsibility of the manufacturer: 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). 5. The object of the declaration described above is in conformity with the relevant Union harmonisation legislation.........: 6. References to the relevant harmonised standards used, or references to the specifications in relation to which conformity is declared: 7. Additional information: Signed for and on behalf of:............................... (place and date of issue) (name, function)(signature) 768/2008 says: ANNEX III EC DECLARATION OF CONFORMITY 1. No...(unique identification of the product): 2. Name and address of the manufacturer or his authorised representative: 3. This declaration of conformity is issued under the sole responsibility of the manufacturer (or installer): 4. Object of the declaration (identification of product allowing traceability. It may include a photograph, where appropriate): 5. The object of the declaration described above is in conformity with the relevant Community harmonisation legislation: . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6. References to the relevant harmonised standards used or references to the specifications in relation to which conformity is declared: 7. Where applicable, the notified body ... (name, number)...performed...(description of intervention) ...and issued the certificate: ... 8. Additional information: Signed for and on behalf of:....................................... (place and date of issue): (name, function) (signature): Under point1 I read the type reference, where under point 4 an additional requirement is formulated allowing to make it traceable. I presume here that manufacture codes (manufacturing facility, possible other relevant details) are meant. In case of OEM product this may include the manufacturer, or the batch numbers that were referred to under chapter R2 point 5 It additionally requires a color image of the product where the original 768 document only say "may ". As the original stems from 2008 and this concept is from 2011 I am afraid the intention is to include the image... 15 april will learn more Regards, Ing. Gert Gremmen, BSc [email protected] <mailto:[email protected]> www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Van: [email protected] [mailto:[email protected]] Namens Tyra, John Verzonden: Sunday, January 13, 2013 10:21 PM Aan: Crane, Lauren; [email protected] Onderwerp: RE: One DoC per manufactured Unit?! 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 à 1. No xxxxxx (unique identification of the electric equipment): Amendment Proposed à 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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