I agree with John. We went through this when the new Machinery Directive came out a few years back. The directive itself only said, "description and identification of the machinery, including generic denomination, function, model, type, serial number and commercial name;", but the guide said, "As a general rule, the serial number of the machinery covered by the EC Declaration of Conformity shall be indicated". People all freaked out like they are doing now. We even had customers call us and tell us our DOCs were invalid because it didn't have the serial number on it.
We contacted our NB about this and they said you only have to include the serial number if it is required to identify units that are CE compliant vs non-compliant units within the same model. If all of your products within the same model number are compliant then only the model number is needed and not the serial number. I assume (and hope) the same logic will apply to the new LVD. As far as the color picture, well, that's just stupid. Why not ask for a hologram of the product? Our DOC is included in our manual and we are not going to add color for a single picture. I'm not sure where we would put a picture anyway. Our DOC is a full page now. It would most likely have to be very small or on a separate page. Oh, and do they want the DOC printed in one of 26 different languages? I love it when new directives come out. Gets the old blood boiling.... The Other Brian From: [email protected] [mailto:[email protected]] On Behalf Of Tyra, John Sent: Sunday, January 13, 2013 4:21 PM To: Crane, Lauren; [email protected] Subject: 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]> [mailto:[email protected]] On Behalf Of Crane, Lauren Sent: Wednesday, January 09, 2013 5:14 PM To: [email protected]<mailto:[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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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]>
