COCIR appreciates the Commission’s Services Interpretative Document on the Implementation of Directive 2007/47/EC amending Directives 90/385/EEC, 93/42/EEC and 98/8/EC issued on 5 June 2009. Unfortunately the flexibility in the wording with regards DoC led to different interpretations sometimes conflicting requirements to manufacturers from National Member States and Notified Bodies.
COCIR decided to issue this recommendation paper with the objective to bring uniformity among manufacturers in their communication with customers, notified bodies and competent authorities. Further, it should foster an unambiguous situation where all DoCs dated on/after 21 March 2010 only mention Directive 93/42/EEC.