logo
European Weighing Industry
Newsletter Issue #2 - December 2014
Versión Española
Version Française
Versione Italiana

 

Dear readers,

You are reading now the second edition of CECIP’s newsletter. The aim of this letter is, to inform you about the activities we develop to serve the interests of the weighing sector. Our communication group collects the content, selects the issues and controls the editorial part. Of course we appreciate it when you enjoy reading it. But that is not a goal in itself, this is not a novel. So help us with feedback, tell us what you need and/or what you think to be superfluous.

As we are just starting, there is plenty of possible content. Your support will help to select the issues, important for you.

by Vincent van der Wel, Penko Engineering, Netherlands

 

Type Approval Certificates – Differences between notified bodies

by Ian Turner (UK Weighing Federation, UK)

Nearly all of the instruments that we supply to our customers must have a type approval document before they can be supplied. This is perhaps one of the most important documents that we use and we must ensure that all of the instruments we place on the market are fully compliant with them. This means that these documents must be clear and concise and interpreted similarly in all Member States.

When these documents are ambiguous, vague or different notified bodies have different interpretations of requirements this can cause many problems to the suppliers of weighing instruments. The market surveillance authorities in different Member States come to different interpretations and this confusion and misunderstanding cost businesses many thousands of euro in meeting what are effectively local requirements in different countries.

One example relates to whether a type approval document can reference other manufacturers indicators, one notified body stated that this was clearly not permitted this and another was happy to do this. This confusion created unnecessary cost and delay in making the instruments available on the market and reflects just one of a number of examples that we have recorded over the past few months. There is great concern with the different views that notified bodies are showing with regard to software.

Whilst recognising that differences in view will naturally occur between notified bodies and the market surveillance authorities of different member, it is crucial that we work with the notified bodies and the co-ordination body NoBoMet to improve the method of resolving these problems.

We are working with both the WELMEC groups and the NoBoMet to develop a better and quicker method of clarifying these ambiguities and resolving them to ensure that all type approvals can be produced to be clearer and more consistent; when we have problems we need a clear answer and all notified bodies to follow these decisions.

To help with this we would like any examples that you have of either unclear or incorrect type approvals and examples where different notified bodies have reached different conclusions and this has caused problems for your business.

 

Can printing of a receipt be avoided in retail scales in Europe?

by Veronika Martens, Sartorius Lab Instruments GmbH & Co. KG

More and more customers in shops ask to avoid waste of paper because of environmental reasons and therefore avoid unnecessary printing. Shopkeepers want to change from “required printing” to “printing on demand” which means that customers are asked whether they want the receipt or not. That was the reason that several retail scales manufacturer wanted to have this function of “printing on demand” instead of “required printing” certified in their type-approval certificates. Some Notified Bodies already issued such type-approval certificates but some refused with reference to the European directive of non-automatic weighing instruments. Such leads to unfair competition because the shop keepers require this function. In at least one European country, market surveillance officially accepted such function.

As this was an unacceptable situation CECIP asked WELMEC working group 2 for clarification. WG2 agreed unanimously that the directive is very clear in this point. Printing is mandatory for price-computing instruments (for direct sales) that may perform functions other than per article weighing and price computation. But In case of totalising multiple articles printing this does not have to take place after each weighing sequence. It could take place when the transaction is complete.

The result in detail:

  • According to clause 14, 4th paragraph, of directive 2009/23/EC of non-automatic weighing instruments, printing is mandatory for price-computing instruments (for direct sales) that may perform functions other than per article weighing and price computation.
  • The initialisation of the (mandatory) printing step can either:
    • be triggered automatically by the weighing sequence, or
    • the weighing sequence can stop before printing and wait for a manual command to print, or
    • the print-out of all weighed items and non-weighed items can be performed at the end of the transaction. A new transaction can only commence after the print-out has been completed.
    Note: the printing step can't be circumvented and must be completed, either after each weighing sequence or at the end of the transaction.
  • ‘Printing’ on a secondary screen or in the same screen does not fulfil the requirements because this is not "printing" (it is "displaying") and so does not achieve the objective of letting the customer review if the items and price listed are those that have been purchased.
  • When a POS is connected to a NAWI the requirement for mandatory printing must also be fulfilled by the POS.
  • Transatlantic Trade and Investment Partnership (TTIP)

    by Ian Turner (UK Weighing Federation, UK)

    The Transatlantic Trade and Investment Partnership (TTIP) is a proposed free trade agreement between the European Union (EU) and the United States of America (USA). It is hoped that the agreement would result in multilateral economic growth between two of the world’s largest trade blocs. The discussions are taking place in a number of market sectors including technical barriers to trade, electronics and machinery and engineering with the hope of improving bilateral trade in these areas.

    CECIP have contacted the European commission to try and ensure that the weighing industry is included in these negotiations. The US and the EU both have developed and sophisticated but very different legal metrology systems. This means that instruments need to be reapproved for each respective market before they can be supplied. This produces unnecessary cost for industries in both North America and the EU.

    The international legal metrology framework already has existing procedures for the sharing of test data and results via the OIML frameworks. It is felt that if there could be greater recognition of these standards and agreements some of the technical barriers to trade could be reduced to the benefit of businesses in both market places. CECIP have made both national governments and the EU Commission aware of this view and have had both organisations be receptive to these views.

    The TTIP negotiations are progressing, but it can be difficult to find out the exact status of the discussions. We have been lead to believe that the discussions on machinery and engineering and barriers to trade have developed well and results will be made public very soon.

    If you would like to approach your own national authorities with this CECIP would be able to help with drafting letters and a lot of information on the progress of the negotiations can be found at http://ec.europa.eu/trade/policy/in-focus/ttip/

     

    New Directives under the New Legislative Framework (NLF) and the consequences for the Industry

    by Veronika Martens, Sartorius Lab Instruments GmbH & Co. KG

    As a result of the NLF several EU Directives were revised and came into force some months ago. This includes the EMC, Low Voltage, Machinery and ATEX Directives but as well NAWID (2014/31/EU) and MID (2014/32/EU).

    The NLF creates a number of new requirements. Member States have the task to implement these requirements by the 19th April 2016. One day later on 20th April 2016 the new regulations have to be applied by everybody. A transition period is not foreseen. Some things can be prepared before the 19th April but there are several matters, which manufacturers cannot complete in advance of this date. These may cause problems for manufacturers because they cannot change organisation process from one day to the next even when they carefully prepare things. In addition many questions are still open and cannot even yet be answered by the Commission (EC). The only things which we know remain are type-approval certificates resp. type evaluation certificates. The Directive states itself that those will stay valid even after the implementation date.

    The Directives give new requirements to Notified Bodies (NBs) which require changes in their quality management systems (QMS) and this may lead to certification and re-notification. Actions should be taken to ensure that all notified bodies are fully operational by 20th April 2016 and do not have to stop their activities. We are concerned what may happens when a NB is not yet re-notified by the 20th April 2016 Does a manufacturer who has been certified for Module D have to stop production in this case? What about his certification of Module D? Is it required that this has to be re-certified before that date as well? Does the registration numbers of the NB change? What about the registration number of the manufacturer? Those are only some questions concerned. If there are changes manufacturers have to renew documentation and labelling of instruments from one day to the other without any consideration of instruments which are in process already from before or are in stock not yet finally put into the market because of using Module F at the place of use or the like.

    Amongst others matters NAWID requires a change in design of the “green” M metrology sticker together with the order with the additional markings like CE, year and NB registration number etc. from one day to the other. From all Directives a change in the declaration of conformity is necessary. A joint declaration for all applicable Directive is required, a new layout and references to new registration numbers of Directives and maybe NB numbers etc.

    In this regard CECIP identified an organisational problem and therefore sent an official letter to the EC to point out the problems for industry and asked for solutions concerning a transition period, which is not foreseen by the Directives. These items will be discussed next meeting of the EC working group of measuring instruments which will probably in March next year and where CECIP participates. But we must be aware that this group handles NAWID and MID only. The other Directives as mentioned above are concerned as well.

    The letter with more detailed information you can order under LM14 030 (18th July 2014) from CECIP Secretariat.

     

    EN45501

    by Ian Turner (UK Weighing Federation, UK)

    It appears the long story of EN45501 may be coming to some sort of a conclusion. CEN have published some proposed dates on the publication and withdrawal of the existing standard. It is important to note that the proposed date of withdrawal of the existing standard is the 7th May 2015. After this date no new type approvals can be gained using this standard, but existing type approvals can continue to be used until they expire.

    EN 45501:2014

    The main outstanding issue appears to be the requirements in the standard relating to the conformity markings and the inscriptions, which must be placed on the instrument, but are not part of the essential of requirements in the Directive. It is felt that the standard will be published containing the marking requirements and a re- draft will begin immediately to correct this matter. This has become increasingly important as the new Directive 2014/31/EU contains different marking requirements to the existing Directive 2009/23/EU.

    The contents of the standard remain the same as the previous drafts that we have seen with the most significant changes relating to the EMC immunity levels and the requirements relating to software. As soon as the final draft is published we will begin work on a cross -reference table outlining the differences between the new and the old standard.

     

    New versus Repair

    by Daniel Meier, Mettler Toledo Switzerland

    European directives have harmonised non-automatic weighing instruments for more than 25 years and automatic weighing instruments for more than 10 years throughout the entire European market. Nevertheless there still exist massive differences among the individual European member states in interpretation of these harmonised rules. Of outstanding importance are the different interpretations of interventions to an instrument in use by national authorities.

    This leads again and again to situations, where authorities of one member state are asking for a specific intervention, which lead to a new conformity assessment of the instrument, whereas in another member state, the same intervention would be requested to be dealt as a repair.

    The European Commission has recently recognised, that barriers to trade are created where the conditions for putting into service, for installation and/or for use/operation are not harmonised, as they are still occurring in the measuring instrument sector specifically for weighing instruments (1). As a consequence the European Commission has called for further harmonisation of currently non-harmonised aspects in the area of legal metrology based on Regulation about reducing obstacles to the free movement of goods (2).

    CECIP is supporting this initiative and pledges for unrestricted adoption of a horizontal implementation. In many other industrial sectors this is a well-established approach as it is defined by the New Legislative Framework Regulation (3) and further explained in the Blue Guide (4). For clarity and in support of harmonised application by all stakeholders, the general decision workflow is illustrated in Fig.1.

    As a consequence of this horizontal approach, the economic operator responsible for the intervention decides based on these defined objective criteria, about the impact of the intervention and, depending on the result, follows applicable rules.

    CECIP is working with the European Commission and with WELMEC and supports members to make progress in reducing such cases and in implementing uniformly the pre-defined decision workflow in all member states.

    Manufacturers and other economic operators are encouraged to apply the decision workflow described and – in addition – to carefully study and follow relevant national regulation. CECIP has prepared a corresponding checklist (Document LM14 003). Copies are available from the secretariat.

     

    (1) Summary of the results of the 2013 public consultation on “Reforming the internal market for industrial products"
    (2) Regulation 764/2008/EC
    (3) Decision 768/2008/EC
    (4) The Guide is available from ENTR-IM-AND-ITS-INTL-DIMENSION@ec.europa.eu

    LMG President awarded with OIML Medal 2014

    The contribution of CECIP within the OIML has been recognised as very fruitful. As a result, Veronika Martens, President of the LMG, was awarded with the OIML medal within the awards 2014, which recognize her outstanding contribution to the development of legal metrology, being also the first woman getting such distinction. With this award, OIML proves authorities and industry are not natural enemies but can succesfully cooperate. Furthermore it is good to keep in mind, Veronika Martens did so voluntary; being made available for this demanding job by Sartorius. CECIP congratulates Veronika Martens for her achievement.




    Veronika Martens

    Who is who: OIML and the role which CECIP plays in their work

    by Veronika Martens, Sartorius Lab Instruments GmbH & Co. KG

    The International Organization of Legal Metrology is an intergovernmental treaty organization with 60 member countries and 68 corresponding member countries all over the world which:

    • develops model regulations, standards and related documents for use by legal metrology authorities and industry,
    • provides mutual recognition systems which reduce trade barriers and costs in a global market,
    • represents the interests of the legal metrology community within international organizations and forums concerned with metrology, standardization, testing, certification and accreditation,
    • promotes and facilitates the exchange of knowledge and competencies within the legal metrology community worldwide,
    • cooperates with other metrology bodies to raise awareness of the contribution that a sound legal metrology infrastructure can make to a modern economy.

    The mission of the OIML is to enable economies to put in place effective legal metrology infrastructures that are mutually compatible and internationally recognized, for all areas for which governments take responsibility, such as those which facilitate trade, establish mutual confidence and harmonize the level of consumer protection worldwide.

    The OIML issues several categories of publications:

    • International Recommendations, which are intended as model regulations for a number of categories of measuring instruments, and which OIML Member States are morally obliged to implement as far as possible;
    • International Documents, which are informative and are intended for guidance purposes; and
    • Other publications such as Vocabularies, Guides, Basic Publications and Expert Reports.

    In addition, the OIML has developed the following international systems:

    • the OIML Basic Certificate System for Type Evaluation of Measuring Instruments, in which participants use harmonized methods to assess and certify the conformity of types of measuring instruments with the requirements of OIML Recommendations, on a voluntary basis;
    • the Framework for a Mutual Acceptance Arrangement on OIML Type Evaluations (MAA), in which participants declare that they intend to accept and utilize type evaluation reports from those participants that are entitled to issue OIML MAA Certificates.

    The OIML is an “international standard-setting body” in the sense of the World Trade Organization's Technical Barriers to Trade Agreement. OIML publications should therefore be applied, when appropriate, by all signatories of the TBT Agreement when developing technical regulations, in application of Article 2.4 of that Agreement: "Where technical regulations are required and relevant international standards exist or their completion is imminent, Members shall use them, or the relevant parts of them, as a basis for their technical regulations except when such international standards or relevant parts would be an ineffective or inappropriate means for the fulfilment of the legitimate objectives pursued, for instance because of fundamental climatic or geographical factors or fundamental technological problems."

    Article 2.4 and the vision of a harmonized worldwide legal metrology system make the work of OIML so very important for CECIP. One of the countries resp. regions which follow Article 2.4 very close is Europe. For example the harmonized standard EN45501 for non-automatic weighing instruments is nearly an exact copy of OIML R76. The measuring instruments directive MID even directly refers to OIML Recommendations as standardisation documents e.g. OIML R51 or R61. There are several countries in the world which more or less follow Article 2.4 as well. Nevertheless the way to a harmonized worldwide legal metrology system still is far away.

    Participation of CECIP:

    CECIP is officially listed as a “Technical Liaison” of OIML and actively takes part:

    • With oral presentation in CIML meetings. Several times those had been referenced by participants during the meetings and even taken in own presentations of some members at home. In almost all cases CECIP is the only representative of industry there.
    • In more than 15 PGs, TCs, SCs and ad-hoc Working Groups which concern weighing industry e.g. development of Recommendations like R76, R51, R60 etc. but as well Documents like D11, or Basic Publications like B10 and projects like implementation of the MAA. The listing in which groups CECIP participates you can find under http://www.oiml.org/en/technical-work/tc-sc/organization_sc_view

    How OIML is organized:

    • The International Conference on Legal Metrology is the highest decision-making body in the Organization. It is composed of representatives of the Member States and meets every four years. Member States are morally obliged to implement the decisions of the Conference (see Article VIII of the OIML Convention).
    • The International Committee of Legal Metrology (CIML) meets annual and is the functional decision-making body of the Organization. CIML Members (one per Member State) are designated by their government. They are in principle officials in the department concerned with measuring instruments, or have active official functions in the field of legal metrology.

      The CIML Members are the main permanent contact of the OIML in the Member States. They have a double role: they represent their country on the Committee, and they represent the OIML in their country.

      Corresponding Members may attend Committee Meetings as observers, and Organizations in liaison may be invited to attend as observers as well. Liaisons may take part in the discussions and are invited to give oral presentations in order to introduce their organization and their needs and expectations. CECIP is officially listed as a “Technical Liaison” and takes part with oral presentation in almost all CIML meetings. In almost all cases CECIP is the only representative of industry in these meetings.

      Amongst others, the CIML:
      • adopts various internal regulations, procedures, etc.,
      • approves changes to the OIML's technical work program, and
      • adopts OIML Recommendations, Documents, other publications, etc.
      which then will be confirmed by the conference during their regular meetings every four years.

      The CIML is headed by a President and two Vice-presidents who are elected for a time period by the Committee.
    • The International Bureau of Legal Metrology (BIML) is the Secretariat and headquarters of the OIML, ensuring both the day to day running of activities and the planning of longer term actions. The BIML is situated in Paris, France. The BIML consists of a Director with two assistant Directors and 6 persons for additional staff.
    • Project Groups (PG) within the OIML's Technical Committees (TC) and Subcommittees (SC) develop the Organization's technical publications. TCs, SCs and PGs are composed of:
      • Participating Members (P-Members): Member States willing to participate actively in the work of TCs, SCs or PGs. P-members have voting rights;
      • Observer Members (O-Members): Member States which wish to follow the work of TCs, SCs or PGs without voting rights. Corresponding Members may also be O-Members; and
      • Liaison Organizations like CECIP, which are organizations interested in the work of TCs, SCs or PGs. They take part in meetings and discussions, give advice but have no voting rights.

    Website of OIML:

    The website with useful information of OIML can be seen under http://www.oiml.org/en/.

    Beside information about OIML itself there are for example:

    • all OIML Documents, Recommendations etc. for download;
    • listing of all issued OIML Certificates;
    • information about the two certificate systems Basic System and the MAA the Mutual Acceptance Arrangement together with a listing of the issuing Participants and their scope. Very new is a listing of actual Manufacturer’s Testing Laboratories (MTLs) which are certified and supervised for testing of their instruments under the MAA;
    • agenda, reports, presentations and minutes of the CIML meetings;
    • password protected area e.g. for the technical work of the different working groups.

    Reference note: several information about the organisation of OIML is directly copied from the OIML website.

     

    Agenda

    • 03/12/2014 CECIP Taskforce & Communication Group meeting, Brussels (BE)
    • 09-10/12/2014 WELMEC WG8 meeting, Paris (FR)
    • 27/01/2015 CECIP Board, BTG, Taskforce & Communication Group meetings, Brussels (BE)
    • 03/02/2015 CECIP Software Subgroup meeting, Berlin (DE)
    • 04/02/2015 CECIP LMG meeting, Berlin (DE)
    • 11/03/2015 wgMI meeting, Brussels (BE)
    • 18/03/2015 WELMEC WG7 subgroup of software meeting, Brussels (BE)

     

    © 2009 - CECIP