Thanks John and all for your comments. There is a persistent problem knitted into this issue regarding the meaning of 'product'.
Most inquiries to the Commission tend to end up clarifying that 'product' means a particular unit and not a model line or type. This is particularly true when struggling with the grandfathering issue. The date for which a 'product' is placed on the market is the date on which that particular unit entered the EU. It is *not* the date when the model-line or type was first introduced to the EU. The "blue-guide" states on page 18, "Moreover, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series." Therefore, "Object of the declaration" (and the other equivalent statements) required by various CE directives can well mean a model-line or type description (except, perhaps, the very unique language of the MD which references serial number). But the new add in NLF is the point 1 "1. No...(unique identification of the product)" and it hints to me of a per-unit identification number. Why else would this new element be added by the NLF (New Legislative Framework) when "object of the declaration" has long been explained as 'model-line'? And why would parliamentarians be getting so tricky in their amendment proposals if it were not the Commissions intent to have this be a per-unit identifier? Regards, Lauren Crane KLA-Tencor From: Tyra, John [mailto:john_t...@bose.com] Sent: Sunday, January 13, 2013 3:21 PM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG 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: emc-p...@ieee.org<mailto:emc-p...@ieee.org> [mailto:emc-p...@ieee.org]<mailto:[mailto:emc-p...@ieee.org]> On Behalf Of Crane, Lauren Sent: Wednesday, January 09, 2013 5:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 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. 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