Declaration of Conformity - New directive, new declaration

[nukebat]

Hi folks,

Just wondering if anyone else has encountered this issue or has any smart answers...

As of the end of December this year the new Machinery Directive (2006/42/EC) comes into force. We have ammended our declaration of conformity to state that our machines comply with this new standard (which they do - have technical file and all compliance documents etc). This new style declaration must accompany the product if it is released for sale after 29th Dec this year.

- However, we have stock that has been pre-completed, awaiting sale. It is not likely to be sold before the end of the year. Inside the user manual of these is the declaration of conformity to the old standard, which will be o-o-d when these make it to retailers.
Can we simply attatch our new, ammended declaration on the outside of the packaging? (boxes are all sealed)

Any advice would be much appreciated!

Thanks!

 

[rclanzillotto]

Best approach is to replace the manual, but I'd consider the following:

In addition to the new declaration of conformity, provide an errata sheet for the manual that informs the customer that the DOC in the manual is not correct and has been updated to reflect the new machinery directive as follows etc. Instruct the customer to keep this errata sheet with the manual. I'd track the inclusion of the errata sheet as part of final inspection.

Good Luck. Rich

 

[nukebat]

Thanks for that.
We've decided to...

make up an errata sheet as suggested, but printed on stickers. These will be stuck to the outer, plastic wrapped, case of each product (which is not removed until it reaches the end user)
This is in compliance with the law in that it 'accompanies the machinery' at point of purchace by the end user.
This got by the huge problem of unwrapping, unsealing and opening every individual product to put a sheet inside, before sealing them all up again.

Still can't get my head around why there's no transition period for this change in system.

Cheers!