Let us talk about the correct way of placing the Notified Body behind the CE logo, why size matters?
Let us get to the answers first, followed by the explanation.
During my work for a Certification body, many questions from manufacturers have passed, initially appointed for the R&TTE Directive 99/5/EC following the New Approach. As from 2016 under the RED 2014/53/EU following the New Legislative Framework. Numerous times we have seen CE marks followed by the numbers in a wrong way. Why? Because most are doing it wrong, Copy, Copy! An additional issue is the lack of knowing where to find it.
1 not correct example:
Why do we see these markings with the number so many times in the market? The question will stay unanswered, although the regulations and documents are clear and detailed, whereby an unambiguous interpretation is unavoidable.
The available European documents (from the commission and workgroups) furthermore do give clear information under the New Legislative Framework (NLF). The New Legislative Framework reinforces the application and enforcement of internal market legislation. It:
More information about the combination of the CE marking and the Notified Body number can be retrieved from the following sources:
1.Official Journal C272; Commission Notice — The ‘Blue Guide’ on the implementation of EU products rules 2016.
The document mentions the following about the CE and Notified Body number.
4.5.1.5. Affixing CE marking together with the identification number of the notified body
“Where a notified body is involved in the production control phase according to the applicable Union harmonisation legislation, its identification number must follow the CE marking.” and
“The CE marking and the identification number can also be affixed separately, as long as they remain combined.”
Also for the Notified Bodies, this was the reason for a lot of discussions. The working groups (e.g. www.redca.eu), attended by European Notified Bodies, advise the Commission. The advice results in the so-called Blue Guide and Technical Guidance Notices (TGN). Is the advise accepted then they are also legally binding. Most important, it provides clarification.
“ according to Article 20.3 of the RED, the CE marking has to be followed by the identification number of the notified body in the same height as the CE marking. *28 “
*28 So when the height of the CE Marking is less than 5 mm, as provided for in Article 19 (2) of the RED, the height of the identification number of the notified body will be also less than 5 mm.
Article 20 Rules and conditions for affixing the CE marking and the identification number of the notified body
“The identification number of the notified body shall have the same height as the CE marking.”
“Where applicable, the CE marking shall be followed by the identification number of the notified body responsible for the conformity assessment procedures set out in Article 52.“
“The various components of the CE Marking must have substantially the same vertical dimension, which may not be less then 5mm.“
Point 5 insists that the marking and the number may not be less than 5mm; however, this directive is from 1993, and as the applications change, also the European Commission publishes updated rules in their official journals.
1.Official Journal C272; Commission Notice — The ‘Blue Guide’ on the implementation of EU products rules 2016.
4.5.1.4. Principles of affixing the CE marking
“A minimum height of 5 mm is required to ensure that it is legible. However, according to the several pieces of legislation (*220) the minimum dimension of the CE marking may be waived for small devices or components.”
*220 Such as machinery, personal protective equipment, active implantable medical devices, medical devices, potentially explosives atmospheres, lifts — as regards safety components, in vitro diagnostic medical devices, radio and telecommunications terminal equipment or marine equipment.
Based on the above moreover, discussions about sizing about the CE marking and the combination should not exist. The European Commission and the workgroups also do give an unambiguous clarification in all their available documents.
As IoT Consulting Partners, we recommend to follow the law and guides and not copy what others do. Most essential is to prevent issues when going GLOBAL with your product. The Notified body number outside the European Union is highly respected, moreover, one which will give you real wings!
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