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.
- 1: The height of the number must be of the same height as the CE Mark;
- 2: The Font height of the number and the CE mark can indeed less than 5mm as long they are readable and legible;
- And last but not least: Yes, the CE Mark should be followed by the Notified body number and not on top or below.
Notified body labelling how it should not be.
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 New Legislative Framework.
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:
- improves market surveillance rules to better protect both consumers and professionals from unsafe products, including those imported from outside the EU. In particular, this applies to procedures for products which can pose danger to health or the environment;
- sets clear and transparent rules for the accreditation of conformity assessment bodies;
- boosts the quality of and confidence in the conformity assessment of products through stronger and clearer rules on the requirements for the notification of conformity assessment bodies;
- clarifies the meaning of CE marking and enhances its credibility;
- establishes a common legal framework for industrial products in the form of a toolbox of measures for use in future legislation. This includes definitions of terms commonly used in product legislation and procedures to allow future sectorial legislation to become more consistent and easier to implement.
- Harmonisation between all the directive and regulations in the way of setup and layout.
Explanation concerning correct placement of the Notified Body number
Follow and next to each other:
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.”
Same Height:
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.
- Blue Guide to the radio equipment directive 2014/53/EU
“ 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.
- Directive 2014/53/EU article 20.3 (European document issued by the Commission)”
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.”
- Directive 2017/745 Article 20:
“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.“
- Directive 93/42 ANNEX XII:
“The various components of the CE Marking must have substantially the same vertical dimension, which may not be less then 5mm.“
Height of the CE mark and the Notified body number can be less than 5 mm:
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.
Final Thoughts
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!
