The term “model number” does not appear in the legislation. What is stated, for example in the Low Voltage Directive, is that a type, batch, or serial number, or another means of identification, must be applied to the product. The format is flexible; the traceability is not. <\/p>\n\n
In addition to that number, the manufacturer shall indicate their name, registered trade name or trademark, and a postal address at which they can be contacted. That address shall indicate a single contact point. The contact details must be in a language easily understood by end-users and market surveillance authorities. <\/p>\n\n
Similar provisions are found in other harmonization legislation and in the General Product Safety Regulation. The wording varies, but the intent does not: a regulator must be able to trace the product back to the technical file. <\/p>\n\n
On the product itself. If this is not possible due to the size or nature of the product, the information may be placed on the packaging or in an accompanying document. This exception applies to small or unsuitable products, not to products where it simply does not look attractive. <\/p>\n\n
Pay attention to the durability of the marking. A sticker that peels off after a few cleanings makes the product untraceable. For products that get wet or are used in a work environment, engraving or a durable label is more prudent. <\/p>\n\n
You sell under your own brand with your own article number. Your supplier tested the same product under their number. During an inspection, there is a product with number A and a report with number B. There is nothing linking the two together. <\/p>\n\n
This is not a mere formality. An inspector cannot determine whether the report belongs to this product. Visual similarity is not proof, as products are counterfeited. The result is that your file will be judged as insufficient, even if the product is technically sound. <\/p>\n\n
The same applies to a supplier who uses one report for an entire range of numbers. In that case, the question is not whether the report exists, but why those numbers should be considered equivalent. <\/p>\n
The most cost-effective solution is preventive. With the first order, ask which type number is on the reports and whether the manufacturer is willing to include your number in the documentation. Arranging a link afterward takes more effort than agreeing on it properly beforehand. <\/p>\n<\/div>\n\n
A declaration of equivalence is a written statement from the party that owns the documentation, stating that the product under your number is identical to the product under their number. It is not a legally prescribed document, but a way to establish that link. <\/p>\n\n
Its value lies in the substantiation, not in its existence. A statement that only claims two numbers refer to the same product is weak. A statement that specifies which parts, materials, and specifications are identical and refers to the relevant report is useful. <\/p>\n\n
Do not assume that such a statement is always sufficient. It fills a gap in traceability, but it does not replace the report and does not cover differences that actually exist. <\/p>\n
Briefly let us know which product is involved and what is stated on the report. We will contact you regarding what is required. <\/p>\n\t\n\t\n
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