Orgalime NLF interpretative fiche - Transitional DoC arrangements

Orgalime requests the European Commission to allow for pragmatic solutions to the question of which Directives should manufacturers indicate on Declarations of Conformity (DoC) issued during the transposition period.

This is the period starting from the date of entry into force of the revised Directive (new Directive) and ending with the date of repeal of the existing Directive (old Directive), that is until 19 April 2016.

Such pragmatic solutions are necessary after the alignment of Directives with the New Legislative Framework. This alignment led to a change of the Directives’ numbering, but without any changes to their essential requirements. Nevertheless, the Directives’ provisions for the transitional period do not contain any statements regarding the version(s) of the Directive(s) to be referenced in the Declarations of Conformity (DoC).