Supplier test-report review

A test report records the results of examinations carried out on a defined specimen. In Decision No 768/2008/EC, Annex II, Module A, point 2, test reports are one element of the technical documentation, together with the results of design calculations and other examinations.

Directive 2006/42/EC, Annex VII, refers to technical reports giving the results of tests carried out by the manufacturer or by a body chosen by the manufacturer or the authorised representative. The Low Voltage Directive 2014/35/EU and the Radio Equipment Directive 2014/53/EU use the same NLF documentation model: where tests are used to demonstrate conformity, the reports belong in the technical documentation.

The manufacturer remains responsible for the conformity of the product. A laboratory report does not transfer that responsibility. A notified body takes part only when the conformity-assessment procedure requires it. Choosing a body to perform a test is not the same thing as a notified-body certificate.

A supplier document titled CE certificate is not, on its own, proof of complete conformity.

• Identification of the specimen: type, model and the configuration that was tested.
• The standard or specification, its edition, and the clauses covered.
• The method and the results, with the date of the test.
• The identity of the body that performed the test.
• A clear boundary between results and any certificate that only summarises them.

These are general patterns, not a finding about a particular report.

• The specimen is not the model or the configuration placed on the market.
• The edition of the standard is not stated, or a withdrawn edition is presented as current.
• Only some clauses were tested, but the file presents the report as covering the whole act.
• The document is a certificate without the results that would let a reader see what was tested.
• A notified-body mark is implied although the procedure did not require a notified body.

• Which exact model and configuration should be compared with the report?
• Which act, and which standard and edition, is the report said to support?
• Who performed the test: the manufacturer, a chosen laboratory, or a notified body?
• Which clauses are inside the report, and which are not?
• What is the date of the test relative to the version now placed on the market?

A document review does not replace a physical test or validation where these are needed. A harmonised standard supports a presumption only for the requirements it covers, and only to the extent it was applied.

The report is not the declaration of conformity. Under the NLF model the manufacturer still draws up that declaration under the manufacturer's sole responsibility.

The obligations depend on the product and on the applicable act. The rules of the Machinery Directive, the Low Voltage Directive 2014/35/EU and the Radio Equipment Directive 2014/53/EU, including CE marking where the applicable text provides for it, are separate from Regulation (EU) 2023/988 on general consumer-product safety. There is no CE marking under that Regulation.