AMA Blog

Product marking: The important point is that there must be specific numbering must allow making a clear link to the relevant documentation that demonstrates the conformity of the specific type of product, in particular the declaration of conformity. This section is the same virtually the same as the section below, however it refers mainly to products that are sold under a brand or label other than the manufactures label in which case there has to be clear specific information given regarding the specifications as per the line above.

Manufacture and product information: Importance is given to the numbering system and making a clear link to the relevant documentation that demonstrates the conformity of the specific type of product, in particular the declaration of conformity.

Manufacture or importer marking: The manufacturer or importer must indicate their name, registered trademark and Name and address on the product. Article 6.6 (3) a single contact postal address on the product or, when not possible If lack of space, would be possible to indicate the name because of the size or physical characteristics of the product, on its and address within the product? packaging and/or on the accompanying documentation.

Safety instructions: Instructions and safety information need to be provided, whether the Instructions and safety information product is intended for consumers or other end-users. The Low Voltage Directive does not make a distinction on who is the user of the product. The documentation should include all the necessary information for the safe use of the product, to enable the user to assemble, install, operate, As Low Voltage Directive covers safety matters only, store, maintain, repair, and dispose of the product.

Importer Article 8.2: Before placing electrical equipment on the market the importer has an obligation to ensure that the appropriate conformity assessment procedure has been carried out by the manufacturer. The importer does not have to have a copy of the technical manufacturer documentation, but but has to ensure that the technical documentation can be made available to competent national authority upon request. Equipment bears the CE marking and is accompanied by appropriate marking. Even if there is no explicit obligation, the importer is advised to seek formal assurance in writing from the manufacturer that the documents will complied with the requirements set out in Article 6(5) and be made available when requested by the surveillance authority. But the (6)” technical documentation can be given directly by the manufacturer to the surveillance authorities. What is important is that the authorities receive the How do we interpret “the market importers shall documentation and that at importer's request the manufacturer provides the ensure”? Does it mean that the importers must have a information to Member States. copy of the declaration of conformity and the Technical Documentation

Instructions article 8.4: “Importers shall ensure that the electrical equipment is accompanied by instructions and safety information in language which can be easily understood by consumers and other end-users, as determined by the Member State." This does not mean that instructions need to be translated into the language of the local market. However manufactures would be well advised to seek the advice of their distributors as to the best practice for that market place. Sometimes the costs of not having good instructions exceed the costs of writing and translating instructions and other documents. Sometimes good intuitive screens can prevent the need to translate both the instructions and screen content for products with a user interface. However if in doubt do both!

Technical Data: “Directive 2014/35/EU Annex III.2 requires from the documentation start a risk analysis of the specific risks of the product to address them in manufacturer to include an appropriate risk analyses and order to comply with the essential requirements of the Directive because Annex III.2 evaluation in the technical documentation without providing any further details.”

All this means is that if you buy equipment it should have a risk assessment and that with this risk assessment you do not need to do your own risk assessment.

What does this mean to machine builders? Basically most things concerning machinery are covered in the machinery safety directive. But in some respects the directives overlap and so the best this is to make sure that where possible electrical items in reach of the operator are low voltage and pose no risk of shock etc.

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