---
title: "MetrD — Metrology Framework Directive"
description: "The Metrology Framework Directive sets the EC pattern approval and EC initial verification procedures and marks of the old-approach metrology system, applied by its separate directives and accepted in every Member State. It entered into force on 18 May 2009 as a recast of Directive 71/316/EEC and was adapted to delegated acts by Regulation (EU) 2019/1243 from 26 July 2019."
type: "guide"
url: "https://www.conphora.com/regulations/metrd/"
markdown: "https://www.conphora.com/regulations/metrd.md"
locale: "en"
language: "en"
published: "2009-05-18"
updated: "2026-09-12"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Directive 2009/34/EC"
celex: "32009L0034"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0034"
tags: ["MetrD", "Measuring Instruments"]
license: "Free to quote with attribution and a link to the page"
---

# MetrD — Metrology Framework Directive

The Metrology Framework Directive sets the EC pattern approval and EC initial verification procedures and marks of the old-approach metrology system, applied by its separate directives and accepted in every Member State. It entered into force on 18 May 2009 as a recast of Directive 71/316/EEC and was adapted to delegated acts by Regulation (EU) 2019/1243 from 26 July 2019.

## Key facts

- **Official title:** Directive 2009/34/EC of the European Parliament and of the Council of 23 April 2009 relating to common provisions for both measuring instruments and methods of metrological control (Recast)
- **Reference:** Directive 2009/34/EC
- **CELEX:** 32009L0034
- **Act type:** Directive
- **In force:** 2009-05-18
- **Applies from:** 2009-05-18
- **Enforced by:** The metrological services of the Member States apply the directive: they grant, extend and withdraw EC pattern approval, carry out EC initial verification, affix the verification marks, prevent the use of confusable marks and may forbid the placing on the market and putting into service of instruments whose approved pattern shows a general defect, with every refusal, withdrawal or prohibition reasoned and open to the national remedies; since 16 July 2021 the directive is point 28 of Annex I to Regulation (EU) 2019/1020, so the national market surveillance authorities also hold that regulation's investigation and enforcement powers for it. In Denmark the directive is implemented by bekendtgørelse nr. 1139 af 15. december 2003 om EØF-typegodkendelse og -verifikation, under which Sikkerhedsstyrelsen receives applications for and grants EØF-typegodkendelse and authorises the accredited laboratories that carry out EØF-førstegangsverifikation, and since 1 July 2021 legal metrology falls under the product act (lov om produkter og markedsovervågning), which lists the directive in section 2, names Erhvervsstyrelsen as the control authority and provides orders, prohibitions and fines that can rise to imprisonment of up to 2 years under aggravating circumstances; since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen.
- **Category:** Measuring Instruments

## Who it applies to

**Covered by the act:** Instruments, meaning measuring instruments, components of measuring instruments, additional devices and measurement equipment, for which a separate directive adopted under the framework prescribes EC pattern approval or EC initial verification; Units of measurement, the harmonisation of methods of measurement and metrological control and the means needed to apply them, as regulated by the separate directives; The prescription, methods of measurement, metrological control and marking of quantities of prepackaged products, as regulated by the separate directives on prepackages and measuring container bottles; Manufacturers and their representatives established in the Community who apply for EC pattern approval, submit instruments for EC initial verification or affix the exemption signs on their own responsibility; Instruments and products bearing the EC signs and marks, which Member States may not prevent, prohibit or restrict from being placed on the market or put into service

**Derived and downstream products:** The directive is a framework: it fixes the procedures and the signs, while the separate directives fix the measurement procedures, characteristics and technical requirements of each instrument category and may set the date on which national provisions are replaced (Art. 1(5) and Art. 1(6)); The separate instrument directives no longer exist: Directive 2004/22/EC repealed eleven of them from 30 October 2006 and Directive 2011/17/EU repealed the remaining eight, the last on 1 December 2015; EC pattern approvals and certificates issued until 30 November 2015 under Directives 71/347/EEC, 75/33/EEC, 76/765/EEC and 86/217/EEC remain valid (Article 6(2)); weights conforming to Directives 71/317/EEC and 74/148/EEC could instead be subject to EC initial verification until 30 November 2025 (Article 6(3)), and Directive 76/766/EEC on alcohol tables has no transitional provision (Directive 2004/22/EC, Art. 22; Directive 2011/17/EU, Art. 1 to Art. 3 and Art. 6); What still refers to the framework are the reversed-epsilon sign of Article 6 on measuring container bottles, the small e of Annex II section 3, to which Article 12 on confusable marks applies mutatis mutandis, and the further-checks point of the prepackage directive, which applies Article 15 mutatis mutandis, and, historically, Article 16, under which the Commission amended the units of measurement directive in 2019; since 26 July 2019 the empowerment in Article 16 reaches only Annexes I and II of this directive, not the annexes of the separate directives (Directive 75/107/EEC, Annex I point 5; Directive 76/211/EEC, Annex I points 3.3 and 6; Directive (EU) 2019/1258, citations and recital 2); Measuring instruments in the MID categories and all non-automatic weighing instruments are made available with CE marking under Directives 2014/32/EU and 2014/31/EU, which apply from 20 April 2016, so EC pattern approval and EC initial verification do not apply to them (Directive 2014/32/EU, Art. 2(1), Art. 7 and Art. 51; Directive 2014/31/EU, Art. 1(1) and Art. 46); Since 16 July 2021 the directive is Union harmonisation legislation under Regulation (EU) 2019/1020, Annex I point 28, so its market surveillance authorities may demand documents and supply-chain information, order corrective action and prohibit, withdraw or recall non-compliant products (Regulation (EU) 2019/1020, Art. 14 and Art. 16)

**Roles under the act:**

- **Manufacturer** — The manufacturer of an instrument, who alone or through his representative established within the Community may apply for EC pattern approval, in one Member State only, who affixes the EC approval sign to instruments conforming to the approved pattern, and who, where a separate directive does not require EC pattern approval or EC initial verification, affixes the special sign or symbol on his own responsibility.
- **Authorised representative established in the Community** — The representative of the manufacturer established within the Community, who may make the application for EC pattern approval in the manufacturer's place and whose name and address appear in the application.
- **Importer** — Any natural or legal person established within the Union who places a product from a third country on the Union market; an economic operator for Regulation (EU) 2019/1020, whose Annex I lists this directive, and an erhvervsdrivende under the Danish product act.
- **Distributor (wholesaler or retailer)** — Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market; an economic operator for Regulation (EU) 2019/1020 and an erhvervsdrivende under the Danish product act.
- **Instrument owner or user in legally controlled measurement** — The person who uses an instrument bearing EC signs or marks in service, subject to the in-service control requirements that the separate directives specify; in Denmark the instrumentejer, the natural or legal person who uses or makes available an instrument for a measurement on which a payment is based.

## Key dates

- 1971-07-26: Council Directive 71/316/EEC adopted, the original common provisions for measuring instruments and methods of metrological control that Directive 2009/34/EC recasts; transposition deadline 30 January 1973
- 2004-01-01: Danish executive order 1139 of 15 December 2003 on EØF-typegodkendelse og -verifikation enters into force, replacing executive order 154 of 10 March 1995; approvals issued under the old order remain valid until they expire or are withdrawn
- 2006-10-30: Measuring Instruments Directive 2004/22/EC applies and repeals eleven old-approach instrument directives adopted under Directive 71/316/EEC: gas meters, meters for liquids other than water and their ancillary equipment, material measures of length, cold-water meters as regards MI-001, continuous totalising weighing machines, electrical energy meters, taximeters, measuring systems for liquids other than water, automatic checkweighing and weight-grading machines and hot-water meters
- 2009-04-23: Directive 2009/34/EC adopted by the European Parliament and the Council as a recast of Directive 71/316/EEC; published in OJ L 106 of 28 April 2009
- 2009-05-18: Entry into force, the twentieth day after publication; Directive 71/316/EEC as amended by the acts in Annex III, Part A is repealed and references to it are read as references to the recast per the Annex IV correlation table
- 2010-04-01: Danish executive order 349 of 30 March 2010 in force: EØF-typegodkendelse is applied for and granted by Sikkerhedsstyrelsen, which replaces Den Danske Akkrediterings- og Metrologifond throughout the order and authorises the verification laboratories
- 2011-04-07: Directive 2011/17/EU in force, the twentieth day after publication in OJ L 71 of 18 March 2011: it repeals the eight remaining instrument directives adopted under Directive 71/316/EEC in two steps
- 2011-07-01: Directive 71/349/EEC on the calibration of the tanks of vessels repealed; EC initial verifications carried out and calibration certificates issued until 30 June 2011 remain valid
- 2015-12-01: Directives 71/317/EEC and 74/148/EEC on weights, 71/347/EEC on the standard mass of grain, 75/33/EEC on cold-water meters, 76/765/EEC on alcoholometers, 76/766/EEC on alcohol tables and 86/217/EEC on tyre pressure gauges repealed; EC pattern approvals and certificates issued until 30 November 2015 under Directives 71/347/EEC, 75/33/EEC, 76/765/EEC and 86/217/EEC remain valid (Article 6(2)); weights conforming to Directives 71/317/EEC and 74/148/EEC could instead be subject to EC initial verification until 30 November 2025 (Article 6(3)), and Directive 76/766/EEC on alcohol tables has no transitional provision
- 2016-04-20: Directive 2014/32/EU (MID) and Directive 2014/31/EU (NAWI) apply: the ten MID instrument categories and all non-automatic weighing instruments follow the new-approach conformity assessment with CE marking, not the EC pattern approval and EC initial verification of this directive
- 2019-07-26: Regulation (EU) 2019/1243 in force: Article 5(3) on limited approvals deleted, Article 16 replaced by an empowerment to amend Annexes I and II by delegated act, Article 16a inserted with a five-year delegation from this date, Article 17 on the committee deleted
- 2020-06-13: Commission Directive (EU) 2019/1258 applies: adopted under Article 16 of this directive, it aligns the SI base unit definitions in the Annex to Directive 80/181/EEC with the 2018 decision of the General Conference on Weights and Measures
- 2021-07-01: Legal metrology in Denmark comes under the product act (lov om produkter og markedsovervågning), which lists the directive on common provisions for measuring instruments and methods of metrological control in section 2
- 2021-07-16: Regulation (EU) 2019/1020 applies: Directive 2009/34/EC is point 28 of its Annex I, so market surveillance authorities hold the regulation's powers for it; the directive is not in Annex II, so the penalty duty of Article 41 attaches through national law rather than to the directive itself
- 2024-07-26: End of the first five-year period of the Commission's delegated power under Article 16a(2); the delegation is tacitly extended for identical periods unless the European Parliament or the Council opposes no later than three months before the end of each period
- 2025-11-30: Last day on which weights conforming to Directives 71/317/EEC and 74/148/EEC may be subject to EC initial verification under Articles 8, 9 and 10 of this directive
- 2026-01-01: Sikkerhedsstyrelsen becomes the department Markedsovervågning of Erhvervsstyrelsen and continues the same tasks, including EØF-typegodkendelse and the authorisation of verification laboratories

## What you must do

### Manufacturer

- Apply for EC pattern approval yourself or through your representative established in the Community, in one Member State only for one and the same instrument, in the official language of that Member State, sending a copy of the application to every other Member State at the same time.
- State in the application your name and address or those of your representative, the category of instrument, the intended use, the measurement characteristics and the commercial designation or type, and enclose in duplicate a description of the construction and operation, the protecting arrangements, the regulation and adjustment devices and the intended locations of verification marks and seals, general arrangement and detail drawings, a schematic drawing and, where relevant, existing national approvals.
- Put the standards, material and assisting personnel that the metrological service requires at its disposal for the approval examination, which covers the entire performance of the instrument under normal conditions of use, and deposit a sample instrument, parts, scale models or drawings where the service requests it.
- Affix the EC approval sign shown in the certificate, the stylised epsilon with the Member State letters and the last two digits of the year above and the identification number below, to each instrument conforming to the approved pattern where Article 11 or a separate directive requires it, and otherwise at your option; the sign must be visible, legible and indelible.
- Keep the granting Member State informed of any modification of or addition to the approved pattern and obtain additional EC pattern approval where the change influences or might influence measurement results or the prescribed conditions of use; where the rules have changed so that the modified pattern could be approved only under the new provisions, a new approval is needed instead.
- Watch the validity of the approval: it lasts 10 years, may be extended for successive periods of 10 years, cannot be extended after an amendment or adaptation of the Community provisions under which it could no longer be granted, and continues to apply to instruments already in service; a limited approval for a new technique lasts at most two years, extendable by up to three.
- Submit new or reconditioned instruments for EC initial verification with the measurement characteristics and the technical construction and functioning requirements of the separate directive, and where verification takes place outside the office, provide the standards, means and assisting personnel and a copy of the EC approval certificate; where a separate directive exempts the category from approval or verification, affix instead the reversed-epsilon sign or the approval sign in a hexagon on your own responsibility.
- Submit new or reconditioned instruments for EC initial verification against the separate directive's measurement and construction requirements and, where verification takes place outside the office, provide the standards, means, assisting personnel and a copy of the EC approval certificate.
- Where a separate directive exempts the category from EC pattern approval or initial verification, affix the reversed-epsilon sign or the approval sign in a hexagon on your own responsibility.
- Bring instruments into conformity with the approved pattern or the separate directive when warned, since otherwise the Member State may forbid their placing on the market and putting into service, and never use marks or inscriptions liable to be confused with the EC signs or marks; in Denmark a breach of the marking and confusion rules is punishable by a fine.
- When warned, bring instruments into conformity with the approved pattern or the separate directive; otherwise the Member State may forbid their placing on the market and putting into service.
- Never use marks or inscriptions liable to be confused with the EC signs or marks; in Denmark a breach of the marking and confusion rules is punishable by a fine.

### Authorised representative established in the Community

- Make the application for EC pattern approval in the manufacturer's place only if you are established within the Community, in one Member State only, giving your name and address in the application.
- Send a copy of the application simultaneously to all Member States and draw it up, with the correspondence and where required the annexed documents, in the official language of the Member State applied to.
- Receive the EC pattern approval certificate as applicant and, where the approval is refused, not extended or withdrawn, or verification is refused, expect a reasoned decision with information on the national remedies and their time limits.
- In Denmark, apply to Sikkerhedsstyrelsen for EØF-typegodkendelse with documentation that the instrument meets the legal requirements, and know that decisions may be brought before the agency and that giving incorrect or misleading information in connection with a decision is punishable by a fine.

### Importer

- Place on the market only instruments and products whose EC signs or marks were affixed in accordance with the directive and the separate directive concerned; a Member State may not restrict such products, but may act against instruments that do not conform to the approved pattern.
- On request, provide the market surveillance authority with documents, technical specifications, data or information on the compliance of the product and with information on the supply chain, the distribution network, the quantities on the market and other models with the same technical characteristics.
- Take the corrective action the authority requires within the period it sets where the product does not conform, which may include bringing it into compliance, preventing it from being made available, or withdrawing or recalling it.
- In Denmark, ensure as erhvervsdrivende that a product you place on the market meets the rules of the product act and the rules made under it, and expect orders to remedy, stop sales, withdraw, recall or destroy a non-compliant product, with fines for failing to give information or access or for disregarding a decision.

### Distributor (wholesaler or retailer)

- Make available only instruments and products bearing EC signs or marks affixed in accordance with the directive and the separate directive concerned, and never affix or tolerate marks or inscriptions liable to be confused with them.
- On request, provide the market surveillance authority with the documents and supply-chain information it needs and give it access for on-site inspections and physical checks.
- Take the corrective action the authority requires within the period it sets, including stopping the making available or withdrawing or recalling the product.
- In Denmark, comply with orders and prohibitions of the control authority under the product act, which may be addressed to anyone who has been a link in the sale of a product, and note that disregarding them is punishable by a fine.

### Instrument owner or user in legally controlled measurement

- Use an instrument bearing EC signs or marks only within the in-service control requirements, in particular the maximum errors permitted in service, that the separate directive specifies; where none applies, the national rules for comparable instruments serve as the criteria.
- Note that the acceptance duty for an instrument bearing the EC initial verification mark lasts until the end of the year following the year in which the mark was affixed unless a separate directive provides longer; after that, the national in-service rules govern.
- In Denmark, as instrumentejer ensure that an instrument used for a measurement on which a payment is based meets the product act and the rules made under it, even if you are not an erhvervsdrivende.
- Expect the control authority to order you to bring a non-compliant instrument used for payment-based measurement into conformity, or to forbid its use for such measurement, and comply with the order.

## Requirements

Each duty above as an identified requirement (20); ids are permanent and shared with the compliance engine.

### evidence

- `metrd-mfr-bring-conformity-warned` (Manufacturer, product, on-event) — When warned, bring instruments into conformity with the approved pattern or the separate directive; otherwise the Member State may forbid their placing on the market and putting into service. [Art. 7(4)]
- `metrd-imp-take-corrective-action` (Importer, product, on-event) — Take the corrective action the authority requires within the period it sets where the product does not conform, which may include bringing it into compliance, preventing it from being made available, or withdrawing or recalling it. [Art. 16(1), (2) and (3)]
- `metrd-dist-take-corrective-action` (Distributor (wholesaler or retailer), product, on-event) — Take the corrective action the authority requires within the period it sets, including stopping the making available or withdrawing or recalling the product. [Art. 16(2) and Art. 16(3)]

### mark

- `metrd-mfr-affix-approval-sign` (Manufacturer, product, before-market) — Affix the EC approval sign shown in the certificate, the stylised epsilon with the Member State letters and the last two digits of the year above and the identification number below, to each instrument conforming to the approved pattern where Article 11 or a separate directive requires it, and otherwise at your option; the sign must be visible, legible and indelible. [Art. 4 and Annex I points 3.1 and 3.5]
- `metrd-mfr-affix-exemption-sign` (Manufacturer, product, before-market) — Where a separate directive exempts the category from EC pattern approval or initial verification, affix the reversed-epsilon sign or the approval sign in a hexagon on your own responsibility. [Art. 11 and Annex I points 3.3 and 3.4]

### procedure

- `metrd-mfr-put-standards-material` (Manufacturer, product, before-market) — Put the standards, material and assisting personnel that the metrological service requires at its disposal for the approval examination, which covers the entire performance of the instrument under normal conditions of use, and deposit a sample instrument, parts, scale models or drawings where the service requests it. [Annex I points 2.2, 2.4 and 4]
- `metrd-mfr-submit-initial-verification` (Manufacturer, lot, per-lot) — Submit new or reconditioned instruments for EC initial verification against the separate directive's measurement and construction requirements and, where verification takes place outside the office, provide the standards, means, assisting personnel and a copy of the EC approval certificate. [Art. 6, Art. 8 and Annex II point 2.3]

### submission

- `metrd-mfr-apply-pattern-approval` (Manufacturer, product, before-market) — Apply for EC pattern approval yourself or through your representative established in the Community, in one Member State only for one and the same instrument, in the official language of that Member State, sending a copy of the application to every other Member State at the same time. [Art. 2(4) and Annex I point 1.1]
- `metrd-mfr-state-application-name` (Manufacturer, product, before-market) — State in the application your name and address or those of your representative, the category of instrument, the intended use, the measurement characteristics and the commercial designation or type, and enclose in duplicate a description of the construction and operation, the protecting arrangements, the regulation and adjustment devices and the intended locations of verification marks and seals, general arrangement and detail drawings, a schematic drawing and, where relevant, existing national approvals. [Annex I points 1.2, 1.3 and 1.4]
- `metrd-mfr-keep-granting-member` (Manufacturer, product, on-event) — Keep the granting Member State informed of any modification of or addition to the approved pattern and obtain additional EC pattern approval where the change influences or might influence measurement results or the prescribed conditions of use; where the rules have changed so that the modified pattern could be approved only under the new provisions, a new approval is needed instead. [Art. 2(5)]
- `metrd-mfr-watch-validity-approval` (Manufacturer, product, periodic) — Watch the validity of the approval: it lasts 10 years, may be extended for successive periods of 10 years, cannot be extended after an amendment or adaptation of the Community provisions under which it could no longer be granted, and continues to apply to instruments already in service; a limited approval for a new technique lasts at most two years, extendable by up to three. [Art. 5(1) and Art. 5(2)]
- `metrd-oth-make-application-pattern` (Authorised representative established in the Community, product, before-market) — Make the application for EC pattern approval in the manufacturer's place only if you are established within the Community, in one Member State only, giving your name and address in the application. [Art. 2(4) and Annex I point 1.2(a)]
- `metrd-oth-send-copy-application` (Authorised representative established in the Community, product, before-market) — Send a copy of the application simultaneously to all Member States and draw it up, with the correspondence and where required the annexed documents, in the official language of the Member State applied to. [Annex I point 1.1]
- `metrd-oth-apply-sikkerhedsstyrelsen-f-typegodkendelse` (Authorised representative established in the Community, product, before-market) — In Denmark, apply to Sikkerhedsstyrelsen for EØF-typegodkendelse with documentation that the instrument meets the legal requirements, and know that decisions may be brought before the agency and that giving incorrect or misleading information in connection with a decision is punishable by a fine. [§ 1, nr. 2; https://www.retsinformation.dk/eli/lta/2003/1139 · § 22 and § 24]

### verification

- `metrd-imp-place-market-instruments` (Importer, product, before-market) — Place on the market only instruments and products whose EC signs or marks were affixed in accordance with the directive and the separate directive concerned; a Member State may not restrict such products, but may act against instruments that do not conform to the approved pattern. [Art. 1(3) and Art. 7]
- `metrd-imp-ensure-erhvervsdrivende-product` (Importer, product, before-market) — In Denmark, ensure as erhvervsdrivende that a product you place on the market meets the rules of the product act and the rules made under it, and expect orders to remedy, stop sales, withdraw, recall or destroy a non-compliant product, with fines for failing to give information or access or for disregarding a decision. [§ 4, nr. 1, § 5, stk. 1, § 14 and § 37]
- `metrd-dist-make-available-instruments` (Distributor (wholesaler or retailer), product, before-market) — Make available only instruments and products bearing EC signs or marks affixed in accordance with the directive and the separate directive concerned, and never affix or tolerate marks or inscriptions liable to be confused with them. [Art. 1(3) and Art. 12]

### standing

- `metrd-mfr-avoid-confusing-marks` (Manufacturer, company, ongoing) — Never use marks or inscriptions liable to be confused with the EC signs or marks; in Denmark a breach of the marking and confusion rules is punishable by a fine. [Art. 12; https://www.retsinformation.dk/eli/lta/2003/1139 · § 11, § 18 and § 24]
- `metrd-imp-provide-market-surveillance` (Importer, company, ongoing) — On request, provide the market surveillance authority with documents, technical specifications, data or information on the compliance of the product and with information on the supply chain, the distribution network, the quantities on the market and other models with the same technical characteristics. [Art. 14(4), points (a) and (b), and Annex I point 28]
- `metrd-dist-provide-market-surveillance` (Distributor (wholesaler or retailer), company, ongoing) — On request, provide the market surveillance authority with the documents and supply-chain information it needs and give it access for on-site inspections and physical checks. [Art. 14(4), points (a), (b), (d) and (e), and Annex I point 28]

## Penalties

The directive contains no penalty article. Its own toolkit is administrative: the Member State that granted an EC pattern approval may withdraw it where the instruments do not conform to the approved pattern or the separate directive, where the metrological requirements of the certificate are not met or where approval was granted improperly, must withdraw it where instruments of the pattern reveal a general defect in service, and may then forbid the placing on the market and putting into service of the instruments until further notice, informing the other Member States and the Commission; the same applies to instruments exempt from EC initial verification whose manufacturer, after due warning, does not bring them into conformity, and Member States must prevent the use of marks liable to be confused with the EC signs or marks. Every refusal, withdrawal or prohibition must state its reasons and be notified with the available remedies and time limits. Since 16 July 2021 the directive is point 28 of Annex I to Regulation (EU) 2019/1020, whose market surveillance authorities can demand documents and supply-chain information, require corrective action within a set period, prevent a product from being made available, or have it withdrawn, recalled or destroyed; the directive is not listed in Annex II of that regulation, so the penalties come from national law. In Denmark, executive order 1139 of 15 December 2003 on EØF-typegodkendelse og -verifikation punishes with a fine the giving of incorrect or misleading information in connection with a decision and breaches of the marking, withdrawal and confusable-mark rules, with liability for companies, and since 1 July 2021 legal metrology falls under the product act (lov om produkter og markedsovervågning, lovbekendtgørelse 22 of 8 January 2026), which supplements Regulation (EU) 2019/1020, lists the directive in section 2, names Erhvervsstyrelsen as the control authority, lets it issue orders and prohibitions, including orders to the owner of an instrument used for payment-based measurement, and punishes with fines those who fail to give information or access or disregard its decisions, the fine rising to imprisonment of up to 2 years under aggravating circumstances because measuring instruments and methods of metrological control are a product area within section 2(1) no 15 (section 37(2)); since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen.

## Checklist

1. Identify which EU act governs your instrument: a MID category (Directive 2014/32/EU), a non-automatic weighing instrument (Directive 2014/31/EU), a measuring container bottle or prepackage (Directives 75/107/EEC and 76/211/EEC), or national metrological control only; EC pattern approval and EC initial verification under this directive apply only where a surviving separate directive refers to them (Article 1).
2. For MID and NAWI instruments, follow the new-approach conformity assessment and CE marking instead; check that any certificate issued under Directive 2004/22/EC before 20 April 2016 is still valid and that no EC pattern approval sign or verification mark is used on them (Directive 2014/32/EU, Articles 7 and 50).
3. For instruments formerly covered by a directive repealed by Directive 2011/17/EU, do not expect new EC pattern approvals; EC pattern approvals and certificates issued until 30 November 2015 under Directives 71/347/EEC, 75/33/EEC, 76/765/EEC and 86/217/EEC remain valid (Article 6(2)), weights conforming to Directives 71/317/EEC and 74/148/EEC could instead be subject to EC initial verification until 30 November 2025 (Article 6(3)), and Directive 76/766/EEC on alcohol tables has no transitional provision (Directive 2011/17/EU, Article 6).
4. Where a separate directive requires EC pattern approval, apply in one Member State only, as manufacturer or through a representative established in the Community, with the Annex I point 1 file and copies to all other Member States (Article 2(4), Annex I point 1).
5. Keep a register of your EC pattern approvals with their 10-year validity, extensions, additions for modifications and any limitations, and stop affixing a sign whose approval has lapsed except on instruments already in service (Articles 2(5) and 5).
6. Affix the correct sign: the stylised epsilon approval sign, the letter P before it for a limited approval, the reversed epsilon where approval is not required and the sign in a hexagon where verification is not required — all of them at a visible point of each instrument, legible and indelible. The final EC initial verification mark, the small e with the hexagon year stamp, is not yours to affix: it goes on under the responsibility of the Member State when the instrument has been completely verified (Articles 4, 6, 10 and 11, Annex I points 3.1 to 3.5, Annex II point 3).
7. Never use marks or inscriptions liable to be confused with the EC signs or marks, and check that the marks on measuring container bottles and prepackages follow the forms of Annex I point 3.3 and Annex II section 3 (Article 12; Directive 75/107/EEC Annex I point 5; Directive 76/211/EEC Annex I point 3.3).
8. In Denmark, apply to Sikkerhedsstyrelsen (Erhvervsstyrelsen, Markedsovervågning) for EØF-typegodkendelse, use a laboratory it has authorised for EØF-førstegangsverifikation, and keep the in-service tolerances of the general Danish rules for instruments subject to control (executive order 1139 of 2003, §§ 2, 3, 15, 19 and 20).
9. Be ready for market surveillance under Regulation (EU) 2019/1020 and the Danish product act: documents, supply-chain information and corrective action on request, orders and prohibitions from the control authority, and fines for non-compliance (Regulation (EU) 2019/1020 Articles 14 and 16; lovbekendtgørelse 22 of 2026 §§ 14, 16, 16 a and 37).

## Questions

### When did Directive 2009/34/EC start to apply and what did it replace?

Directive 2009/34/EC was adopted on 23 April 2009, published in OJ L 106 of 28 April 2009 and entered into force on the twentieth day after publication, 18 May 2009. It is a recast: it repealed Council Directive 71/316/EEC of 26 July 1971, as amended by the acts listed in Annex III Part A, without changing the substance, and references to the repealed directive are read as references to the recast according to the Annex IV correlation table. The transposition deadlines of the old directive and its amendments, from 30 January 1973 for Directive 71/316/EEC to 9 March 2008 for Directive 2007/13/EC, stay in force under Annex III Part B.

### Does the directive still matter now that the MID and the NAWI Directive exist?

Only at the margins. The instrument directives adopted under the framework have all gone: Directive 2004/22/EC repealed eleven of them from 30 October 2006, when the Measuring Instruments Directive took over gas, liquid, water, electricity and heat meters, length measures, automatic weighing machines and taximeters, and Directive 2011/17/EU repealed the remaining eight, the last on 1 December 2015. Non-automatic weighing instruments follow Directive 2014/31/EU. What still refers to Directive 2009/34/EC is the reversed-epsilon sign on measuring container bottles under Directive 75/107/EEC, the small e and the confusable-marks and in-service control articles applied mutatis mutandis by the prepackage Directive 76/211/EEC, and the Article 16 delegated power under which the Commission amended the units of measurement Directive 80/181/EEC in 2019. The directive itself remains in force and is listed in Annex I of the market surveillance regulation.

### What is EC pattern approval and how long is it valid?

EC pattern approval is the approval of an instrument type by a Member State under the directive and the relevant separate directive. It constitutes the instrument's admission to EC initial verification and, where verification is not required, the authorisation to place it on the market and put it into service. Only the manufacturer or his representative established in the Community may apply, in one Member State only, and the examination covers the documents and the measurement characteristics of the pattern under normal conditions of use. The approval is valid for 10 years, may be extended for successive periods of 10 years, allows an unlimited number of instruments, cannot be extended after a change of the Community provisions under which it could no longer be granted, and continues to apply to instruments already in service. Modifications that influence measurement results need an additional approval. A limited approval for a new technique not provided for in a separate directive may be granted after consulting the other Member States, for at most two years, extendable by up to three.

### What do the epsilon signs and the e mark on an instrument mean?

The EC approval sign of Article 4 is a stylised letter epsilon with the distinguishing letters of the Member State that granted the approval and the last two digits of the year in its upper part and an identification number in its lower part; a letter P of the same size before it marks a limited approval. The sign of Article 6 is the same epsilon reversed symmetrically about a vertical axis with no other indication, affixed by the manufacturer on his own responsibility where a category meeting a separate directive is exempt from EC pattern approval; it is the sign on measuring container bottles. The sign of Article 11 is the approval sign inside a hexagon, for categories exempt from EC initial verification. The final EC initial verification mark is two stamps: a lower-case e carrying the Member State letters and the number of the verifying office, and the last two digits of the year of verification in a hexagon; the partial verification mark is the lower-case e alone and also serves as a seal. None of them is the CE marking.

### How does EC initial verification work?

EC initial verification is the examination of a new or reconditioned instrument and the confirmation of its conformity to the approved pattern and to the requirements of the directive and the separate directives, certified by the EC initial verification mark. The metrological service first determines whether the instrument belongs to a category exempt from pattern approval and meets the technical requirements, or has an approval and conforms to the approved pattern, then examines the metrological characteristics, the maximum permissible errors, the construction and the presence of prescribed inscriptions and stamp plates. Verification is carried out in one stage for instruments that form a whole on leaving the factory and in two or more stages for instruments whose correct functioning depends on installation, with the last stage at the place of installation. A Member State's obligation to accept an instrument bearing the mark lasts until the end of the year following the year in which the mark was affixed unless a separate directive provides a longer period.

### Can a Member State refuse an instrument that bears EC signs or marks?

Not on the basis of the directive and the separate directives. No Member State may prevent, prohibit or restrict the placing on the market or entry into service of an instrument or product bearing EC marks or signs affixed under the conditions of the directive and the separate directive concerned, and Member States attach the same value to EC pattern approval and initial verification as to their national measures. Member States may, however, require the prescribed inscriptions in their official language, the separate directives fix the control requirements for instruments in service, and the Member State that granted an approval may withdraw it and forbid the instruments until further notice where they reveal a general defect in service, informing the other Member States and the Commission.

### Who handles EC pattern approval and verification in Denmark, and what are the penalties?

Executive order 1139 of 15 December 2003 on EØF-typegodkendelse og -verifikation implements the directive; since executive order 349 of 30 March 2010, EØF-typegodkendelse is applied for at and granted by Sikkerhedsstyrelsen, which also authorises the laboratories that carry out EØF-førstegangsverifikation, on the basis that they hold the necessary accreditation from DANAK or from an equivalent accreditation body that is a signatory to the EA multilateral agreement on mutual recognition. Approvals are valid for 10 years, in-service instruments with EC marks are checked under the general Danish rules for instruments subject to control, and giving incorrect information or breaching the marking, withdrawal and confusable-mark rules is punishable by a fine, with liability for companies. Since 1 July 2021 legal metrology falls under the product act, which lists the directive in section 2, names Erhvervsstyrelsen as the control authority and provides orders and prohibitions, including orders to the owner of an instrument used for payment-based measurement, and fines that can rise to imprisonment of up to 2 years under aggravating circumstances. Since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen.

### What did Regulation (EU) 2019/1243 change?

It aligned the directive with the Lisbon Treaty from 26 July 2019. Article 5(3), which let Member States that had granted limited EC pattern approvals ask for adaptation of the annexes, was deleted because such approvals no longer exist; Article 16 now empowers the Commission to adopt delegated acts amending Annexes I and II to adapt them to technical progress; the new Article 16a confers that power for five years from 26 July 2019, tacitly extended for identical periods unless the European Parliament or the Council objects, with consultation of Member States' experts and a three-month objection period; and Article 17 on the committee procedure was deleted. It is the only act that has amended the directive since 2009.

## What changed

- 2026-09-12 (guidance): **Guide rewritten from the official text** — The body was rewritten from the consolidated text of Directive 2009/34/EC, Regulation (EU) 2019/1243, Directive 2011/17/EU, the MID and NAWI directives, Directives 75/107/EEC and 76/211/EEC, Regulation (EU) 2019/1020 and the Danish executive order 1139 of 2003 and product act: the article structure now follows the act (22 articles and four annexes), the signs and marks are described from Annexes I and II, the repeal of every separate instrument directive is dated, and the earlier statements that the MID and the NAWI Directive are built on this directive and that authorised representatives and importers rely on its provisions to place instruments on the market were removed as unsupported by the text.
- 2026-01-01 (guidance): **Sikkerhedsstyrelsen becomes part of Erhvervsstyrelsen** — From January 2026 Sikkerhedsstyrelsen is a department of Erhvervsstyrelsen named Markedsovervågning and carries out the same tasks as before, including EØF-typegodkendelse and the authorisation of laboratories for EØF-førstegangsverifikation under executive order 1139 of 2003; the product act as consolidated on 8 January 2026 names Erhvervsstyrelsen as the control authority.
- 2025-11-30 (applies): **EC initial verification of weights under the repealed directives ends** — The last transitional measure of Directive 2011/17/EU expires: weights conforming to Directives 71/317/EEC and 74/148/EEC could be subject to EC initial verification under Articles 8, 9 and 10 of this directive until this date.
- 2021-07-16 (applies): **Regulation (EU) 2019/1020 applies to the directive** — The market surveillance regulation lists Directive 2009/34/EC as point 28 of its Annex I, so the national authorities hold its investigation and enforcement powers for the directive; the directive is not in Annex II, so the penalty duty of Article 41 attaches through national law. In Denmark legal metrology came under the product act on 1 July 2021.
- 2020-06-13 (applies): **Commission Directive (EU) 2019/1258 applies under Article 16** — Adopted on the basis of Article 16 of this directive, the Commission directive aligned the definitions of the SI base units in the Annex to Directive 80/181/EEC with the 2018 decision of the General Conference on Weights and Measures; Member States had to transpose it by 13 May 2020 and apply it from 13 June 2020.
- 2019-07-26 (amendment): **Regulation (EU) 2019/1243 in force: delegated acts replace the committee procedure** — The regulation of 20 June 2019, published in OJ L 198 of 25 July 2019, deleted Article 5(3) on limited approvals, replaced Article 16 by an empowerment to amend Annexes I and II by delegated act, inserted Article 16a conferring that power for five years from 26 July 2019 with tacit extension, and deleted Article 17 on the committee.
- 2016-04-20 (applies): **MID 2014/32/EU and NAWI 2014/31/EU apply** — The recast Measuring Instruments Directive and Non-automatic Weighing Instruments Directive apply from this date with new-approach conformity assessment and CE marking; Directive 2004/22/EC is repealed with its certificates remaining valid, and Directive 2009/23/EC is repealed.
- 2015-12-01 (applies): **Seven remaining instrument directives repealed by Directive 2011/17/EU** — Directives 71/317/EEC and 74/148/EEC on weights, 71/347/EEC on the standard mass of grain, 75/33/EEC on cold-water meters, 76/765/EEC on alcoholometers, 76/766/EEC on alcohol tables and 86/217/EEC on tyre pressure gauges cease to apply; EC pattern approvals and certificates issued until 30 November 2015 under Directives 71/347/EEC, 75/33/EEC, 76/765/EEC and 86/217/EEC remain valid (Article 6(2)); weights conforming to Directives 71/317/EEC and 74/148/EEC could instead be subject to EC initial verification until 30 November 2025 (Article 6(3)), and Directive 76/766/EEC on alcohol tables has no transitional provision.
- 2011-07-01 (applies): **Directive 71/349/EEC on the calibration of the tanks of vessels repealed** — The first repeal under Directive 2011/17/EU, in force since 7 April 2011, takes effect; EC initial verifications and calibration certificates issued until 30 June 2011 remain valid.
- 2010-04-01 (guidance): **Danish executive order 349 of 2010: Sikkerhedsstyrelsen takes over EØF-typegodkendelse** — The amending order makes Sikkerhedsstyrelsen the authority that receives applications for and grants EØF-typegodkendelse and authorises the laboratories for EØF-førstegangsverifikation, replacing Den Danske Akkrediterings- og Metrologifond throughout executive order 1139 of 2003; executive order 161 of 5 March 2008 had earlier added the Member State letters of the 2004 and 2007 accessions to the signs.
- 2009-05-18 (in-force): **Directive 2009/34/EC in force; Directive 71/316/EEC repealed** — Adopted on 23 April 2009 and published in OJ L 106 on 28 April 2009, the recast entered into force on the twentieth day after publication, repealing Directive 71/316/EEC as amended by the acts listed in Annex III Part A and providing that references to it are read according to the Annex IV correlation table; no new transposition deadline applies.
- 2006-10-30 (applies): **Measuring Instruments Directive 2004/22/EC applies and repeals eleven instrument directives** — Directive 2004/22/EC repealed the old-approach directives on gas meters, meters for liquids other than water and their ancillary equipment, material measures of length, cold-water meters as regards MI-001, continuous totalising weighing machines, electrical energy meters, taximeters, measuring systems for liquids other than water, automatic checkweighing and weight-grading machines and hot-water meters, with a transition of up to ten years for instruments satisfying the previous rules.

## MetrD in plain terms

Directive 2009/34/EC is the framework of the old-approach metrology system. It does not set requirements for any instrument itself: it lays down the two common procedures, EC pattern approval of an instrument type and EC initial verification of each instrument, and the signs and marks that show an instrument has passed them, and it leaves the measurement procedures, characteristics and technical requirements for each category to separate directives adopted under it (Art. 1(5)). In return, no Member State may prevent, prohibit or restrict the placing on the market or entry into service of an instrument or product bearing EC marks or signs affixed under those conditions, and Member States attach the same value to EC pattern approval and initial verification as to their own national measures (Art. 1(3) and Art. 1(4)).

The directive is a recast of Council Directive 71/316/EEC of 26 July 1971 and its amendments, adopted on 23 April 2009, published in OJ L 106 of 28 April 2009 and in force on 18 May 2009 (Art. 20 and Art. 21). Its one amendment is Regulation (EU) 2019/1243, which from 26 July 2019 replaced the committee procedure with delegated acts. The system it describes has, however, largely been dismantled around it: the instrument directives built on Directive 71/316/EEC were replaced by the Measuring Instruments Directive from 30 October 2006 and the remaining ones repealed by Directive 2011/17/EU by 1 December 2015, so today the framework matters for the reversed-epsilon sign on measuring container bottles, the small e on prepackages, the adaptation of the units of measurement directive, and for instruments still in service under old EC approvals.

> **Official text**
> Read the consolidated text on EUR-Lex: [Directive 2009/34/EC, consolidated 26 July 2019 (CELEX 02009L0034-20190726)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0034-20190726). The [original act](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0034) and its [document information page](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0034) carry the publication and entry-into-force dates.

## Scope

The directive applies to instruments, meaning measuring instruments, components of measuring instruments, additional devices and measurement equipment; to units of measurement, the harmonisation of methods of measurement and metrological control and the means required to apply them; and to the prescription, methods of measurement, metrological control and marking of quantities of prepackaged products (Art. 1(1) and Art. 1(2)). For each of these, the separate directives specify the requirements and may fix the date on which national provisions are replaced by Community provisions (Art. 1(5) and Art. 1(6)).

Which separate directives still exist decides what the framework covers in practice. Directive 2004/22/EC repealed eleven instrument directives from 30 October 2006: gas meters, meters for liquids other than water and their ancillary equipment, material measures of length, cold-water meters as regards the MI-001 meters, continuous totalising weighing machines, electrical energy meters, taximeters, measuring systems for liquids other than water, automatic checkweighing and weight-grading machines and hot-water meters (Directive 2004/22/EC, Art. 22). Directive 2011/17/EU repealed the eight that remained: the calibration of the tanks of vessels from 1 July 2011, and weights of medium and above-medium accuracy, the standard mass of grain, cold-water meters, alcoholometers, alcohol tables and tyre pressure gauges from 1 December 2015; EC pattern approvals and certificates issued until 30 November 2015 under Directives 71/347/EEC, 75/33/EEC, 76/765/EEC and 86/217/EEC remain valid (Article 6(2)); weights conforming to Directives 71/317/EEC and 74/148/EEC could instead be subject to EC initial verification under Articles 8, 9 and 10 of this directive until 30 November 2025 (Article 6(3)), and Directive 76/766/EEC on alcohol tables has no transitional provision (Directive 2011/17/EU, Art. 1 to Art. 3 and Art. 6). The Measuring Instruments Directive 2014/32/EU now covers ten instrument categories, MI-001 to MI-010, with two more, EV charging and compressed gas dispenser measuring systems, added by Directive (EU) 2026/706 from 10 October 2028, and Directive 2014/31/EU covers all non-automatic weighing instruments; both use new-approach conformity assessment with CE marking and neither refers to EC pattern approval or EC initial verification (Directive 2014/32/EU, Art. 2(1) and Art. 7; Directive (EU) 2026/706, Art. 1 and Art. 3; Directive 2014/31/EU, Art. 1(1)).

What still refers to the framework are the products of Article 1(1)(b) and (c). Council Directive 75/107/EEC requires the manufacturer of a measuring container bottle to affix the sign of Article 6, the reversed epsilon, on his own responsibility (Directive 75/107/EEC, Annex I point 5). Council Directive 76/211/EEC takes the form of the small e on prepackages from the drawing in section 3 of Annex II and applies the prohibition of confusable marks and the in-service control article mutatis mutandis (Directive 76/211/EEC, Annex I points 3.3 and 6). Its own annexes no longer go through the framework: Regulation (EU) 2019/1243 replaced its Article 6 with a delegated-acts empowerment and inserted Article 6a, so from 26 July 2019 the Commission amends Annexes I and II of that directive directly. And Commission Directive (EU) 2019/1258, which aligned the SI base unit definitions in Directive 80/181/EEC with the 2018 decision of the General Conference on Weights and Measures, was adopted on the basis of Article 16 of this directive, whose recital describes it as the general framework for separate directives on units of measurement (Directive (EU) 2019/1258, citations and recital 2).

The duties fall on the manufacturer or his representative established within the Community, who alone may apply for EC pattern approval and who affixes the signs (Art. 2(4), Art. 4, Art. 6 and Art. 11); the metrological services of the Member States carry out the examinations and affix the verification marks (Art. 10 and Art. 13). Importers and distributors are addressed not by the directive but by Regulation (EU) 2019/1020, which lists it as point 28 of Annex I, and in Denmark by the product act as erhvervsdrivende (Regulation (EU) 2019/1020, Art. 3 and Annex I; lovbekendtgørelse 22 of 2026, § 4).

## What you must do

### EC pattern approval

Member States grant EC pattern approval in accordance with the directive and the relevant separate directive; the approval constitutes admission to EC initial verification and, where verification is not required, the authorisation to place the instruments on the market and put them into service, and a category exempted from approval by its separate directive goes directly to verification (Art. 2(1) and Art. 2(2)). An application may be made only by the manufacturer or his representative established within the Community, in one Member State only for one and the same instrument, in the official language of that Member State, with a copy sent simultaneously to all other Member States; it states the applicant's name and address, the category, the intended use, the measurement characteristics and the type, and is accompanied in duplicate by descriptions of construction and operation, protecting arrangements, adjustment devices and the locations for verification marks and seals, drawings, a schematic diagram and any national approvals already granted (Art. 2(4) and Annex I points 1.1 to 1.4). The examination comprises a study of the documents and an examination of the measurement characteristics in the laboratories of the metrological service, in approved laboratories or at the place of manufacture, delivery or installation, or only of the documents where the characteristics are known in detail, and covers the entire performance of the instrument under normal conditions of use; the service may require standards, material and assisting personnel from the applicant and, in the cases the separate directives mention, the deposit of a sample instrument (Annex I points 2 and 4).

The Member State that carried out the examination draws up the EC pattern approval certificate and forwards it to the applicant, sending copies to the Commission and the other Member States, which may also obtain the examination reports (Art. 4 and Annex I point 5). Approval is valid for 10 years, extendable for successive periods of 10 years, with no limit on the number of instruments; it cannot be extended after an amendment or adaptation of the Community provisions under which it could no longer be granted, but continues to apply to instruments already in service (Art. 5(1)). Modifications or additions that influence or might influence measurement results or the prescribed conditions of use need additional approval from the granting Member State, or a new approval where the rules have changed (Art. 2(5)). Where a new technique not provided for in a separate directive is used, an approval with limited effect may be granted after consulting the other Member States, with limits on numbers, notification of installation places, restrictions on use and on the technique, for at most two years extendable by up to three (Art. 5(2)). The former Article 5(3) on adapting the annexes after such approvals was deleted by Regulation (EU) 2019/1243 because limited approvals no longer exist.

### EC initial verification

EC initial verification is the examination of a new or reconditioned instrument and the confirmation of its conformity to the approved pattern and to the requirements of the directive and the separate directives, certified by the EC initial verification mark; it may be carried out by a method other than unit checking in the cases the separate directives specify (Art. 8(1) and Art. 8(2)). The metrological service determines whether the instrument belongs to a category exempt from pattern approval and satisfies the technical construction and functioning requirements, or has an approval and conforms to the approved pattern, and examines the metrological characteristics, the maximum permissible errors, the construction in so far as it guarantees that the characteristics will not deteriorate under normal conditions of use, and the presence of prescribed inscriptions and stamp plates (Art. 9). Verification is carried out in one stage for instruments that form a whole on leaving the factory and in two or more stages for instruments whose correct functioning depends on the conditions of installation or use, the last stage at the place of installation and the others at a place chosen by the service; outside the office the service may require standards, means, assisting personnel and a copy of the approval certificate (Annex II points 1 and 2). The Member State's obligation to accept an instrument bearing the mark lasts until the end of the year following the year in which the mark was affixed, unless a separate directive provides longer (Art. 8(4)).

### Signs and marks

The EC approval sign of Article 4 is a stylised letter epsilon containing, in its upper part, the distinguishing capital letters of the Member State that granted the approval and the last two digits of the year, and in its lower part an identification number assigned by the metrological service; the letter P of the same size before it marks a limited approval (Annex I points 3.1 and 3.2). Where a category meeting a separate directive does not require EC pattern approval, the manufacturer may affix on his own responsibility the special sign of Article 6, the same epsilon reversed symmetrically about a vertical axis and bearing no other indication unless a separate directive stipulates otherwise (Art. 6 and Annex I point 3.3). Where EC initial verification is not required, the manufacturer affixes the sign of Article 11, the approval sign inside a hexagon (Art. 11 and Annex I point 3.4). All signs affixed by the manufacturer must be at a visible point of each instrument and all ancillary equipment submitted for verification, legible and indelible (Annex I point 3.5). The final EC verification mark, affixed under the responsibility of the Member State when the instrument is completely verified, consists of two stamps: a lower-case letter e with the Member State letters and, where necessary, a territorial subdivision figure in the upper half and the identification number of the verifying agent or office in the lower half, and the last two digits of the year of verification in a hexagon; the partial verification mark is the first stamp alone and also serves as a seal, and the actual diameters of the circles described about the marks are 1.6 mm, 3.2 mm, 6.3 mm and 12.5 mm (Art. 10 and Annex II point 3). Member States must prevent the use of marks or inscriptions liable to be confused with the EC signs or marks, notify one another and the Commission of the services authorised to examine, certify and mark, and may require the prescribed inscriptions in their official language (Art. 12, Art. 13 and Art. 14). The country lists in Annex I point 3.1 and Annex II point 3.1.1.1 of the consolidated text run from B for Belgium to UK for the United Kingdom.

### Withdrawal, control in service and decisions

The Member State that granted an EC pattern approval may withdraw it where the instruments do not conform to the approved pattern or the separate directive, where the metrological requirements of the certificate or the limits of a limited approval are not met, or where approval was granted improperly, and must withdraw it where instruments of the pattern reveal in service a defect of a general nature that makes them unsuitable for their intended use; it may then forbid the placing on the market and putting into service of the instruments until further notice, informing the other Member States and the Commission, and the same procedure applies to instruments exempt from EC initial verification whose manufacturer, after due warning, does not bring them into conformity (Art. 7). The separate directives specify the control requirements for instruments in service bearing EC signs or marks, in particular the maximum errors permitted in service, and less stringent national requirements for unmarked instruments may serve as criteria (Art. 15). Every decision refusing or withdrawing approval, refusing verification or prohibiting placing on the market or entry into service must state its reasons and be notified with the remedies and time limits available under national law (Art. 18).

### Adaptation to technical progress

Since Regulation (EU) 2019/1243, the Commission is empowered to adopt delegated acts amending Annexes I and II to adapt them to technical progress (Art. 16). The power is conferred for five years from 26 July 2019 and tacitly extended for identical periods unless the European Parliament or the Council opposes no later than three months before the end of each period; it may be revoked at any time, the Commission consults Member States' experts before adopting an act, and an act enters into force only if neither institution objects within three months, extendable by two (Art. 16a). The former Article 17 on the committee was deleted. The empowerment is also narrower than the one it replaced: until 26 July 2019 Article 16 covered 'Annexes I and II to this Directive and the annexes to the separate Directives referred to in Article 1', which is how the Commission adopted Directive (EU) 2019/1258 on the SI base units in Directive 80/181/EEC on 23 July 2019, three days before the change, under the committee procedure of the old Article 17; the new Article 16 reaches only Annexes I and II of this directive, and Member States had to apply Directive (EU) 2019/1258 from 13 June 2020.

### Obligations by role

The manufacturer applies for approval, supplies the file, standards and samples, affixes the approval sign or the exemption signs, keeps the granting Member State informed of modifications, watches the 10-year validity, submits instruments for verification and brings non-conforming instruments into conformity when warned (Art. 2, Art. 4 to Art. 8 and Annex I). The authorised representative established in the Community may make the application in the manufacturer's place and receives the certificate and any reasoned refusal (Art. 2(4), Art. 4 and Art. 18). Importers and distributors place on the market and make available only products whose EC signs or marks were properly affixed, and owe the market surveillance authorities the documents, supply-chain information and corrective action of Regulation (EU) 2019/1020 (Art. 1(3); Regulation (EU) 2019/1020, Art. 14 and Art. 16). Owners and users of instruments in service keep within the in-service requirements the separate directives or national rules specify (Art. 15).

## Enforcement and penalties

The directive has no penalty article. Its enforcement is the administrative toolkit of Articles 7, 12 and 18: withdrawal of EC pattern approval, prohibition of the instruments until further notice, prevention of confusable marks, and reasoned decisions with national remedies. Since 16 July 2021 the directive is point 28 of Annex I to Regulation (EU) 2019/1020, so market surveillance authorities may require documents and supply-chain information, carry out inspections, order corrective action within a set period and prohibit, withdraw, recall or destroy non-compliant products (Regulation (EU) 2019/1020, Art. 14, Art. 16 and Art. 44). The directive is not among the acts listed in Annex II of that regulation, so the duty to lay down penalties under its Article 41 attaches through national law rather than to the directive itself.

In Denmark the directive is implemented by bekendtgørelse nr. 1139 af 15. december 2003 om EØF-typegodkendelse og -verifikation, issued by Sikkerhedsstyrelsen under lov om erhvervsfremme, in force since 1 January 2004 and amended by executive orders 161 of 5 March 2008 and 349 of 30 March 2010. Since the 2010 amendment, EØF-typegodkendelse is applied for at and granted by Sikkerhedsstyrelsen, which also authorises the laboratories that carry out EØF-førstegangsverifikation, on the basis that they hold the necessary accreditation from DANAK or from an equivalent accreditation body that is a signatory to the EA multilateral agreement on mutual recognition; the order mirrors the directive's application file, 10-year validity, additional and limited approvals, exemption signs, verification stages and marks, subjects EC-marked instruments in service to the general Danish rules for instruments subject to control, lets decisions be brought before Sikkerhedsstyrelsen, and punishes with a fine the giving of incorrect or misleading information in connection with a decision and breaches of the marking, withdrawal and confusable-mark rules, with liability for companies (§§ 2, 3, 7, 12, 13, 15, 17 to 22 and 24). Since 1 July 2021 legal metrology falls under the product act, lov om produkter og markedsovervågning (lovbekendtgørelse nr. 22 af 8. januar 2026), which supplements Regulation (EU) 2019/1020, lists the directive on common provisions for measuring instruments and methods of metrological control in § 2, stk. 1, nr. 15, names Erhvervsstyrelsen as the control authority, lets it issue orders and prohibitions, including orders to the owner of an instrument used for a measurement on which a payment is based, and punishes with fines those who fail to give information or access or who disregard its decisions; because this directive is a product area within § 2, stk. 1, nr. 15, the penalty can rise to imprisonment of up to 2 years under aggravating circumstances, which § 37, stk. 2, defines as danger to safety or health, an accident causing serious injury or death, repetition after an earlier conviction for a similar breach, or a systematic breach committed for economic gain, with liability for companies (§ 1, § 2, § 9, § 14, § 16, § 16 a and § 37). Since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen and carries out the same tasks as before.

## How Conphora helps

Conphora keeps the metrology framework, the surviving separate directives, the MID and the NAWI Directive and the Danish executive orders in one place and tells you which regime your instrument or product is in, so that an old EC pattern approval, a reversed-epsilon bottle, an e-marked prepackage or a CE-marked meter is checked against the right rules. The platform tracks the validity of approvals and certificates, maps the signs and marks you use against the forms the annexes prescribe, and alerts you if the directive, the separate directives or the Danish rules change.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Directive 2009/34/EC relating to common provisions for both measuring instruments and methods of metrological control, consolidated text of 26 July 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0034-20190726)
- [Directive 2009/34/EC as published in OJ L 106, 28 April 2009 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0034)
- [Document information, dates and relationships for CELEX 32009L0034 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0034)
- [Regulation (EU) 2019/1243 adapting acts providing for the regulatory procedure with scrutiny to Articles 290 and 291 TFEU (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1243)
- [Directive 2011/17/EU repealing eight metrology directives adopted under Directive 71/316/EEC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0017)
- [Directive 2004/22/EC on measuring instruments, consolidated text of 1 December 2009 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0022-20091201)
- [Directive 2014/32/EU on measuring instruments, consolidated text of 27 January 2015 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0032-20150127)
- [Directive (EU) 2026/706 amending Directive 2014/32/EU (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0706)
- [Directive 2014/31/EU on non-automatic weighing instruments (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031)
- [Commission Directive (EU) 2019/1258 amending the Annex to Directive 80/181/EEC as regards the definitions of SI base units (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L1258)
- [Council Directive 75/107/EEC on bottles used as measuring containers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31975L0107)
- [Council Directive 76/211/EEC on the making-up by weight or by volume of certain prepackaged products, consolidated text of 26 July 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01976L0211-20190726)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Legal metrology (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/legal-metrology_en)
- [Measuring and weighing instruments in the EU (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/legal-metrology/measuring-weighing-instruments-eu_en)
- [Bekendtgørelse nr. 1139 af 15. december 2003 om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2003/1139)
- [Bekendtgørelse nr. 161 af 5. marts 2008 om ændring af bekendtgørelse om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2008/161)
- [Bekendtgørelse nr. 349 af 30. marts 2010 om ændring af bekendtgørelse om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2010/349)
- [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22)
- [Regler og bekendtgørelser for måling og vægt (Sikkerhedsstyrelsen)](https://sik.dk/erhverv/produkter/love-og-regler/vaegte-og-maalere/regler-og-vejledning-maaling-vaegt-og-e-maerkning)
- [Legal måling og vejning (legal metrologi) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/legal-maaling-og-vejning-legal-metrologi)
- [Typegodkendelser, oversigt over nationale og EØF-typegodkendelser (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/typegodkendelser)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen)

*This guide is for general information and is not legal advice.*

## Sources

- [Directive 2009/34/EC relating to common provisions for both measuring instruments and methods of metrological control, consolidated text of 26 July 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02009L0034-20190726)
- [Directive 2009/34/EC as published in OJ L 106, 28 April 2009 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009L0034)
- [Document information, dates and relationships for CELEX 32009L0034 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0034)
- [Regulation (EU) 2019/1243 adapting acts providing for the regulatory procedure with scrutiny to Articles 290 and 291 TFEU (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1243)
- [Directive 2011/17/EU repealing eight metrology directives adopted under Directive 71/316/EEC (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0017)
- [Directive 2004/22/EC on measuring instruments, consolidated text of 1 December 2009 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004L0022-20091201)
- [Directive 2014/32/EU on measuring instruments, consolidated text of 27 January 2015 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0032-20150127)
- [Directive (EU) 2026/706 amending Directive 2014/32/EU as regards EV supply equipment, compressed gas dispensers and electricity, gas and thermal energy meters (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026L0706)
- [Directive 2014/31/EU on non-automatic weighing instruments (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031)
- [Commission Directive (EU) 2019/1258 amending the Annex to Directive 80/181/EEC as regards the definitions of SI base units (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019L1258)
- [Council Directive 75/107/EEC on bottles used as measuring containers (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:31975L0107)
- [Council Directive 76/211/EEC on the making-up by weight or by volume of certain prepackaged products, consolidated text of 26 July 2019 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:01976L0211-20190726)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Legal metrology (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/legal-metrology_en)
- [Measuring and weighing instruments in the EU (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/single-market/goods/building-blocks/legal-metrology/measuring-weighing-instruments-eu_en)
- [Bekendtgørelse nr. 1139 af 15. december 2003 om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2003/1139)
- [Bekendtgørelse nr. 161 af 5. marts 2008 om ændring af bekendtgørelse om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2008/161)
- [Bekendtgørelse nr. 349 af 30. marts 2010 om ændring af bekendtgørelse om EØF-typegodkendelse og -verifikation (Retsinformation)](https://www.retsinformation.dk/eli/lta/2010/349)
- [Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2026/22)
- [Regler og bekendtgørelser for måling og vægt (Sikkerhedsstyrelsen)](https://sik.dk/erhverv/produkter/love-og-regler/vaegte-og-maalere/regler-og-vejledning-maaling-vaegt-og-e-maerkning)
- [Legal måling og vejning (legal metrologi) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/legal-maaling-og-vejning-legal-metrologi)
- [Typegodkendelser, oversigt over nationale og EØF-typegodkendelser (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/typegodkendelser)
- [Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)](https://erhvervsstyrelsen.dk/sikkerhedsstyrelsen-en-del-af-erhvervsstyrelsen)

_Reviewed 2026-09-24 by Conphora compliance team_