Re: [PSES] Declaration of Conformity

[Scott Xe]

Dear Charlie,

Thanks for your reply.  As some of ecodesign regulations do not require
energy labelling, appreciate your useful link which gives clear indications
which ecodesign regulations do not require energy labelling.

Best regards,

Scott


On Sun, 2 Jun 2024 at 03:10, Charlie Blackham 
wrote:

> Scott
>
>
>
> The Ecodesign Directive applies to products within scope of a Commission
> Regulation implementing Directive 2009/125/EC
>
>
>
> These products must then be labelled in accordance with the relevant
> Commission Delegated Regulation on how to energy label that product.
>
>
>
> You don’t declare compliance with a labelling method, you just label in
> accordance with it.
>
>
>
> Lists of relevant Regulations at
>
>
> https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/  *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Scott Xe 
> *Sent:* Saturday, June 1, 2024 2:33 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] Declaration of Conformity
>
>
>
> Hello Experts,
>
>
>
> According to the Ecodesign Directive (EU) 2009/125, manufacturers must
> draw up a declaration of conformity for covered products. However, the
> Energy Labelling Regulation (EU) 2017/1369 does not explicitly mention this
> requirement.
>
>
>
> Is a declaration of conformity also mandatory for products covered under
> the Energy Labelling Regulation (EU) 2017/1369 as part of the compliance
> process?
>
>
>
> Cheers,
>
>
>
> Scott
> --
>
> 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
> EMC-PSTC@LISTSERV.IEEE.ORG
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> 
>
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Re: [PSES] Declaration of Conformity

[Charlie Blackham]

Scott

The Ecodesign Directive applies to products within scope of a Commission 
Regulation implementing Directive 2009/125/EC

These products must then be labelled in accordance with the relevant Commission 
Delegated Regulation on how to energy label that product.

You don’t declare compliance with a labelling method, you just label in 
accordance with it.

Lists of relevant Regulations at
https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: Saturday, June 1, 2024 2:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Declaration of Conformity

Hello Experts,

According to the Ecodesign Directive (EU) 2009/125, manufacturers must draw up 
a declaration of conformity for covered products. However, the Energy Labelling 
Regulation (EU) 2017/1369 does not explicitly mention this requirement.

Is a declaration of conformity also mandatory for products covered under the 
Energy Labelling Regulation (EU) 2017/1369 as part of the compliance process?

Cheers,

Scott


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Re: [PSES] Declaration of Conformity

[Kunde, Brian]

I agree with you and I am in favor of providing the DoC to the customer 
(preferably before purchase); however, it is an unnecessary burden on the 
manufacturer to have to put the DoC in the Instruction Manual as the MD 
states.  Let me provide the DoC to my customer in a way that is best for me and 
my customer. Instruction Manuals are printed and packed months in advance and 
built in quantity. If the DoC information changes, I'm shipping old DoCs with 
my product or I have to rework my Manual Packs with the new DoC which is 
costly. So I would prefer not having to include this information in the Manual.

So how we do it is simply publish the content of the DoC in our manuals (as 
the MD allows), making the information as generic as possible and leaving out 
any dates or numbers or signatures that are likely to change, and provide our 
customers with the official DoC through our Sales/Marketing channels if 
requested. I think this is the approach a lot of companies are taking.

As we hear about proposed future requirement of other Directives wanting to 
make the DoC more unique for each product built and sold, it would make 
providing the DoC in a bound manual completely impossible and impractical.

Thanks for the information and references.

The Other Brian


From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Tuesday, December 03, 2013 10:47 AM
To: Kunde, Brian
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

The reason for this is that the workplace safety requirements introduced under 
Article 137 of the TFEU require an employer to ensure that equipment which they 
supply for the use of their employees complies with the applicable essential 
requirements. The Declaration is a useful piece of paper to assist an employer 
in this task.

Nick.



On 3 Dec 2013, at 00:11, Kunde, Brian 
brian_ku...@lecotc.commailto:brian_ku...@lecotc.com wrote:



The MD requires the DoC (not DoI) or a document calling out the content of the 
DoC to be provided in the Instruction Manual. The purpose of this requirement 
is not clear to me but it says it so you have to do it.



LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
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Re: [PSES] Declaration of Conformity

[Nick Williams]

The reason for this is that the workplace safety requirements introduced under 
Article 137 of the TFEU require an employer to ensure that equipment which they 
supply for the use of their employees complies with the applicable essential 
requirements. The Declaration is a useful piece of paper to assist an employer 
in this task. 

Nick. 



On 3 Dec 2013, at 00:11, Kunde, Brian brian_ku...@lecotc.com wrote:

 
 The MD requires the DoC (not DoI) or a document calling out the content of 
 the DoC to be provided in the Instruction Manual. The purpose of this 
 requirement is not clear to me but it says it so you have to do it. 
 



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Re: [PSES] Declaration of Conformity

[Crane, Lauren]

Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only 
available to the MD, and because it is related to a machine that is partly 
complete, it must include a list of the MD Annex I essential heath and safety 
requirements that have been applied and fulfilled. The assumption being that 
some have not been fulfilled because the machine is only partly completed.

In my experience, people often misunderstand the fine point details associated 
with partly completed machinery declarations because they are not necessarily 
aligned with common sense. Download the MD guide and give it a read. 
http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf

Regards,
Lauren Crane
KLA-Tencor



From: Mark Schmidt 
mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Monday, November 25, 2013 2:14:23 PM
Subject: [PSES] Declaration of Conformity
Hello List,

I need some help. I am very new to the Machinery Directive and my customer 
received a non-conformance from their customer about their DoC. It appears that 
my customer’s distributor generated a DoI, and it appears that it needs to be a 
DoC and most importantly their complaint is that it should include a list of 
which EHSRs are met or not met. Where or how do I determine if these are met or 
not. Is there a good place to reference? Any help is appreciated like I said I 
am a newbie when it comes to the Machinery Directive.

Thanks,
Mark Schmidt
-


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Re: [PSES] Declaration of Conformity

[John Cotman]

It is a requirement of the Machinery Directive that a copy of the
declaration be supplied with each machine.  Whether it should be a DoI or
DoC will depend on the circumstances, but either way it should be something
that the manufacturer does, so I can't see why the customer's distributor
has to generate the document at all?

 

Lauren is correct - a DoC means that all applicable EHSRs have been met.  As
they all have, it doesn't need to list them.  A DoI means some have not, so
you need to tell the user what is met and what therefore is not.  Crucially,
the recipient of a DoI has to carry out further work to bring the equipment
into full compliance, so they need to know what that work involves.

 

JohnC

 

  _  

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: 02 December 2013 15:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

 

Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept
only available to the MD, and because it is related to a machine that is
partly complete, it must include a list of the MD Annex I essential heath
and safety requirements that have been applied and fulfilled. The assumption
being that some have not been fulfilled because the machine is only partly
completed. 

 

In my experience, people often misunderstand the fine point details
associated with partly completed machinery declarations because they are not
necessarily aligned with common sense. Download the MD guide and give it a
read.
http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl
-2006-42-ec-2nd-201006_en.pdf

 

Regards,

Lauren Crane

KLA-Tencor

 

  _  

From: Mark Schmidt mark.schm...@dornerworks.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Monday, November 25, 2013 2:14:23 PM
Subject: [PSES] Declaration of Conformity

Hello List,

 

I need some help. I am very new to the Machinery Directive and my customer
received a non-conformance from their customer about their DoC. It appears
that my customer's distributor generated a DoI, and it appears that it needs
to be a DoC and most importantly their complaint is that it should include a
list of which EHSRs are met or not met. Where or how do I determine if these
are met or not. Is there a good place to reference? Any help is appreciated
like I said I am a newbie when it comes to the Machinery Directive.

 

Thanks,

Mark Schmidt

-


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Re: [PSES] Declaration of Conformity

[Mark Schmidt]

Thanks to all that have responded - overwhelming responses with very insightful 
information. I will continue my investigation into my customers problems with 
this directive which (in my opinion) is somewhat undefined or is lacking 
exactness. This in turn propagates misinterpretation.

Thanks to all,
Mark

From: John Cotman [mailto:john.cot...@conformance.co.uk]
Sent: Monday, December 02, 2013 12:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

It is a requirement of the Machinery Directive that a copy of the declaration 
be supplied with each machine.  Whether it should be a DoI or DoC will depend 
on the circumstances, but either way it should be something that the 
manufacturer does, so I can't see why the customer's distributor has to 
generate the document at all?

Lauren is correct - a DoC means that all applicable EHSRs have been met.  As 
they all have, it doesn't need to list them.  A DoI means some have not, so you 
need to tell the user what is met and what therefore is not.  Crucially, the 
recipient of a DoI has to carry out further work to bring the equipment into 
full compliance, so they need to know what that work involves.

JohnC


From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: 02 December 2013 15:58
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only 
available to the MD, and because it is related to a machine that is partly 
complete, it must include a list of the MD Annex I essential heath and safety 
requirements that have been applied and fulfilled. The assumption being that 
some have not been fulfilled because the machine is only partly completed.

In my experience, people often misunderstand the fine point details associated 
with partly completed machinery declarations because they are not necessarily 
aligned with common sense. Download the MD guide and give it a read. 
http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf

Regards,
Lauren Crane
KLA-Tencor



From: Mark Schmidt 
mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Monday, November 25, 2013 2:14:23 PM
Subject: [PSES] Declaration of Conformity
Hello List,

I need some help. I am very new to the Machinery Directive and my customer 
received a non-conformance from their customer about their DoC. It appears that 
my customer's distributor generated a DoI, and it appears that it needs to be a 
DoC and most importantly their complaint is that it should include a list of 
which EHSRs are met or not met. Where or how do I determine if these are met or 
not. Is there a good place to reference? Any help is appreciated like I said I 
am a newbie when it comes to the Machinery Directive.

Thanks,
Mark Schmidt
-


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Attachments are not permitted but the IEEE PSES Online Communities site at 
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David Heald LT;dhe...@gmail.commailto:dhe...@gmail.comGT;
-


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Re: [PSES] Declaration of Conformity

[Kunde, Brian]

The MD requires the DoC (not DoI) or a document calling out the content of the 
DoC to be provided in the Instruction Manual. The purpose of this requirement 
is not clear to me but it says it so you have to do it.

I would request additional information from the customer if you can. What 
exactly did they not like about the information they received. I've had 
customers reject a DoC only to find out after jumping through many hoops that 
they were wrong.

The Other Brian

Sent from my Windows Phone

From: John Cotman
Sent: 12/2/2013 1:10 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

It is a requirement of the Machinery Directive that a copy of the declaration 
be supplied with each machine.  Whether it should be a DoI or DoC will depend 
on the circumstances, but either way it should be something that the 
manufacturer does, so I can’t see why “the customer’s distributor” has to 
generate the document at all?

Lauren is correct – a DoC means that all applicable EHSRs have been met.  As 
they all have, it doesn’t need to list them.  A DoI means some have not, so you 
need to tell the user what is met and what therefore is not.  Crucially, the 
recipient of a DoI has to carry out further work to bring the equipment into 
full compliance, so they need to know what that work involves.

JohnC


From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
Sent: 02 December 2013 15:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Declaration of Conformity

Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only 
available to the MD, and because it is related to a machine that is partly 
complete, it must include a list of the MD Annex I essential heath and safety 
requirements that have been applied and fulfilled. The assumption being that 
some have not been fulfilled because the machine is only partly completed.

In my experience, people often misunderstand the fine point details associated 
with partly completed machinery declarations because they are not necessarily 
aligned with common sense. Download the MD guide and give it a read. 
http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf

Regards,
Lauren Crane
KLA-Tencor



From: Mark Schmidt 
mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com
To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG
Sent: Monday, November 25, 2013 2:14:23 PM
Subject: [PSES] Declaration of Conformity
Hello List,

I need some help. I am very new to the Machinery Directive and my customer 
received a non-conformance from their customer about their DoC. It appears that 
my customer’s distributor generated a DoI, and it appears that it needs to be a 
DoC and most importantly their complaint is that it should include a list of 
which EHSRs are met or not met. Where or how do I determine if these are met or 
not. Is there a good place to reference? Any help is appreciated like I said I 
am a newbie when it comes to the Machinery Directive.

Thanks,
Mark Schmidt
-


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Re: [PSES] Declaration of Conformity

[Mike Sherman ----- Original Message -----]

Mark -- 



This is indeed puzzling. 



The EHSRs are all in Annex I of the Machinery Safety Directive (MSD). When you 
do a DoC, you are typically  implicitly and explicitly declaring compliance 
with all relevant EHSRs. Annex II of the MSD has the requirements for DoC and 
DoI. 



However, if you cite a harmonized standard in your declaration  as evidence of 
compliance with EHSRs, and you do not meet all the requirements of that 
harmonized standard, I've seen the expectation somewhere (others may know this 
better than I, but the June 2010 Guideline to the MSD is a pretty good 
reference) that you list the requirements of the harmonnized standard that you 
do not comply with. 



Your email does not make it clear where in the chain of commerce your company 
falls. This affects whether you have the responsibility to create the DoC. 

Mike Sherman 

Product Safety and Compliance Engineer 

Graco Inc. 

- Original Message -


From: Mark Schmidt mark.schm...@dornerworks.com 
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Monday, November 25, 2013 2:14:23 PM 
Subject: [PSES] Declaration of Conformity 




Hello List, 

  

I need some help. I am very new to the Machinery Directive and my customer 
received a non-conformance from their customer about their DoC. It appears that 
my customer’s distributor generated a DoI, and it appears that it needs to be a 
DoC and most importantly their complaint is that it should include a list of 
which EHSRs are met or not met. Where or how do I determine if these are met or 
not. Is there a good place to reference? Any help is appreciated like I said I 
am a newbie when it comes to the Machinery Directive. 

  

Thanks, 

Mark Schmidt - 
 


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