---
title: "NAWI — Non-automatic Weighing Instruments Directive"
description: "The Non-automatic Weighing Instruments Directive requires operator-assisted weighing instruments used for legally controlled purposes to meet accuracy classes I to IIII, pass notified-body assessment and carry the CE and metrology markings, binding manufacturers, importers and distributors. It has applied since 20 April 2016, replacing Directive 2009/23/EC, and has never been amended."
type: "guide"
url: "https://www.conphora.com/regulations/nawi/"
markdown: "https://www.conphora.com/regulations/nawi.md"
locale: "en"
language: "en"
published: "2014-04-18"
updated: "2026-09-12"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Directive 2014/31/EU"
celex: "32014L0031"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031"
tags: ["NAWI", "Measuring Instruments"]
license: "Free to quote with attribution and a link to the page"
---

# NAWI — Non-automatic Weighing Instruments Directive

The Non-automatic Weighing Instruments Directive requires operator-assisted weighing instruments used for legally controlled purposes to meet accuracy classes I to IIII, pass notified-body assessment and carry the CE and metrology markings, binding manufacturers, importers and distributors. It has applied since 20 April 2016, replacing Directive 2009/23/EC, and has never been amended.

## Key facts

- **Official title:** Directive 2014/31/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of non-automatic weighing instruments (recast)
- **Reference:** Directive 2014/31/EU
- **CELEX:** 32014L0031
- **Act type:** Directive
- **In force:** 2014-04-18
- **Applies from:** 2016-04-20
- **Enforced by:** National market surveillance authorities enforce the national laws transposing the directive; Article 36 still cites Article 15(3) and Articles 16 to 29 of Regulation (EC) No 765/2008, read as Regulation (EU) 2019/1020 since 16 July 2021, whose Annex I lists the directive as point 50 and whose Article 4 requires an economic operator established in the Union for every instrument placed on the market. In Denmark the directive is implemented by executive order nr. 773 of 1 June 2022 on making non-automatic weighing instruments available on the market, issued under the product act (lov om produkter og markedsovervågning), which lists the directive in section 2 as point 13 and names Erhvervsstyrelsen as the control authority; the tasks are carried out by Sikkerhedsstyrelsen, since January 2026 the department Markedsovervågning of Erhvervsstyrelsen, which also designates the Danish notified bodies, and executive order nr. 591 of 29 May 2018 binds the undertaking that has a weighing instrument at its disposal and uses it for one of those purposes — the vægtejer — to accuracy classes, self-checks and reverification, while section 16 a of the product act reaches any instrument owner, natural or legal person. The toolkit is corrective action within a set period, prohibition or restriction of the making available, withdrawal or recall, orders to end formal non-compliance such as a missing CE or metrology marking, inscription, declaration or technical documentation, orders to the owner of an instrument used for payment-based weighing, and national penalties that must be effective, proportionate and dissuasive and may include criminal penalties for serious infringements.
- **Category:** Measuring Instruments

## Who it applies to

**Covered by the act:** All non-automatic weighing instruments, that is weighing instruments requiring the intervention of an operator during weighing, such as shop and counter scales, platform and pallet scales, weighbridges, laboratory balances, patient scales and price-labelling scales; Instruments used or intended for the six legally controlled purposes of Article 1(2)(a) to (f): mass for commercial transactions; mass for calculating a toll, tariff, tax, bonus, penalty, remuneration, indemnity or similar payment; mass for the application of laws or regulations or for an expert opinion in court proceedings; mass in medical practice for weighing patients for monitoring, diagnosis and treatment; mass for making up medicines on prescription in a pharmacy and in analyses in medical and pharmaceutical laboratories; and price on the basis of mass for direct sales to the public and the making-up of prepackages; Instruments for all other applications, Article 1(2)(g): they need only the manufacturer's name and the maximum capacity, must not carry the conformity marking, and their makers, importers and distributors keep the identification and address duties; The economic operators in the chain: manufacturers, authorised representatives, importers and distributors

**Derived and downstream products:** Only instruments used or intended for the purposes in Article 1(2)(a) to (f) must satisfy the Annex I essential requirements; devices included in or connected to such an instrument that are not used for those purposes are not subject to them, and carry the restrictive use symbol, a black capital M on a red square of at least 25 mm by 25 mm with two crossed diagonals (Art. 4, Art. 6(5), Art. 18 and Annex III, point 3); Instruments may not be put into service for the purposes in Article 1(2)(a) to (f) unless they meet the directive, and must continue to conform once in service; in Denmark executive order nr. 591/2018 makes the using undertaking responsible for accuracy class, self-check and reverification (Art. 3(2) and (3); executive order nr. 591/2018, § 3 to § 8); Automatic weighing instruments, which weigh without operator intervention, are outside the directive; they are MI-006 under the Measuring Instruments Directive 2014/32/EU (Art. 2, point (2); Directive 2014/32/EU, Art. 2(1)); Instruments conforming to harmonised standards whose references are published in the Official Journal are presumed to meet the essential requirements those standards cover; the Commission publishes the list of harmonised standards under the directive and works with WELMEC on guidance (Art. 12; European Commission, measuring and weighing instruments page); An importer or distributor that sells under its own name or trade mark, or modifies an instrument already placed on the market in a way that may affect compliance, is treated as the manufacturer (Art. 10); Instruments similar to those used for direct sales to the public that do not satisfy the additional requirements for such instruments must carry the indelible marking 'Not to be used for direct sale to the public' near the display (Annex I, point 14)

**Roles under the act:**

- **Manufacturer (including brand owners)** — Any natural or legal person who manufactures an instrument or has an instrument designed or manufactured, and markets that instrument under his name or trade mark; an importer or distributor that places an instrument on the market under its own name or trade mark or modifies an instrument in a way that may affect compliance is treated as the manufacturer.
- **Authorised representative** — Any natural or legal person established within the Union who has received a written mandate from a manufacturer to act on his behalf in relation to specified tasks; the duty to design and manufacture to the essential requirements and the duty to draw up the technical documentation cannot form part of the mandate.
- **Importer** — Any natural or legal person established within the Union who places an instrument from a third country on the Union market.
- **Distributor (wholesaler, retailer or dealer supplying scales)** — Any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes an instrument available on the market.

## Key dates

- 1993-01-01: Council Directive 90/384/EEC on non-automatic weighing instruments applies, with a ten-year transition for instruments conforming to the rules in force before that date; Directive 93/68/EEC's marking arrangements followed from 1 January 1995
- 2009-06-05: Directive 2009/23/EC, the codification of Directive 90/384/EEC, enters into force; it is the act Directive 2014/31/EU recasts and repeals
- 2014-02-26: Directive 2014/31/EU adopted by the European Parliament and the Council as a recast of Directive 2009/23/EC aligned with the New Legislative Framework
- 2014-04-18: Entry into force, the twentieth day after publication in OJ L 96 of 29 March 2014
- 2016-04-19: Deadline for Member States to adopt and publish the laws transposing points (3) to (19) of Article 2, Articles 6 to 17, Articles 19 to 43 and Annexes II, III and IV
- 2016-04-20: National measures apply; Article 1, points (1) and (2) of Article 2, Articles 3, 4, 5 and 18 and Annexes I, V and VI apply directly; Directive 2009/23/EC repealed; instruments conforming to it and placed on the market before this date may still be made available and put into service, and its certificates remain valid
- 2018-07-01: Danish executive order nr. 591 of 29 May 2018 on the use of non-automatic weighing instruments in force: undertakings that use an instrument for one of the six legal purposes must use the prescribed accuracy class, run a traceable self-check against an in-service tolerance of twice the tolerance at placing on the market and have the instrument reverified by an accredited firm when its seal is broken
- 2021-07-01: Legal metrology, including non-automatic weighing instruments, falls under the Danish product act (lov om produkter og markedsovervågning)
- 2021-07-16: Regulation (EU) 2019/1020 applies: it replaces the market surveillance articles of Regulation (EC) No 765/2008 that Article 36 cites, lists the directive as point 50 of its Annex I and, under Article 4, requires an economic operator established in the Union for every non-automatic weighing instrument placed on the market
- 2022-07-01: Danish executive order nr. 773 of 1 June 2022 on making non-automatic weighing instruments available on the market in force, replacing order nr. 1381 of 25 November 2016; it repeats the seven categories of use, the operator duties, the modules, the markings and the notified-body designation by Sikkerhedsstyrelsen
- 2026-01-01: Sikkerhedsstyrelsen becomes the department Markedsovervågning of Erhvervsstyrelsen and continues the same tasks, including the control of weighing instruments and the designation of notified bodies

## What you must do

### Manufacturer (including brand owners)

- Design and manufacture instruments intended for the six legal purposes to the essential requirements of Annex I: legal units of mass, an accuracy class I, II, III or IIII with the verification scale interval, minimum capacity and number of verification scale intervals of Table 1, errors within the maximum permissible errors of Table 3, repeatable and reproducible results, insensitivity to tilt, the specified temperature range, correct behaviour on power fluctuation and disturbances, no features that facilitate fraud, correct indication and printing, levelling, zeroing and tare devices, and the extra rules for instruments for direct sales to the public and price labelling.
- Draw up the Annex II technical documentation, which must allow the conformity to be assessed and include an adequate analysis and assessment of the risks, a general description, design and manufacturing drawings, the explanations needed to understand them, the list of harmonised standards applied in full or in part or the solutions adopted instead, design calculations, examinations and test reports, and carry out or have carried out the Article 13 conformity assessment procedure.
- Carry out an adequate analysis and assessment of the risks of the instrument and include it in the technical documentation.
- Draw up the Annex II technical documentation: a general description, design and manufacturing drawings with explanations, the harmonised standards applied or the solutions adopted instead, design calculations, examinations and test reports.
- Carry out, or have carried out, the Article 13 conformity assessment procedure for instruments intended for a legal purpose.
- Choose EU-type examination (module B) followed by conformity to type based on quality assurance of the production process (module D) or on product verification (module F), or conformity based on unit verification (module G); module B is not compulsory for instruments that use no electronic device and whose load-measuring device does not use a spring to balance the load, which then follow module D1 or F1. In Denmark the notified body must be designated by Sikkerhedsstyrelsen or by another Member State.
- Draw up the EU declaration of conformity per the Annex IV model, containing the elements of the modules used, continuously updated, translated into the languages the Member State requires and, where several Union acts apply, as a single declaration covering them all, and affix the CE marking and the supplementary metrology marking before placing the instrument on the market; in Denmark the declaration must be in Danish or English.
- Draw up the EU declaration of conformity per the Annex IV model with the elements of the modules used, kept continuously updated, translated into the languages the Member State requires (in Denmark Danish or English) and, where several Union acts apply, as a single declaration.
- Affix the CE marking and the supplementary metrology marking, the capital letter M and the last two digits of the year of affixing in a rectangle of the CE marking's height, visibly, legibly and indelibly to the instrument or its data plate, the metrology marking immediately after the CE marking and both followed by the identification number of the notified body involved in production control, affixed by the body or under its instructions.
- Apply the Annex III inscriptions: for legally used instruments the EU-type examination certificate number where appropriate, your name or trade mark, the accuracy class in an oval, Max, Min, e, the type, batch or serial number and where applicable d, T, dT, Lim, temperature limits and the load-receptor ratio, with Max, Min, e and d also near the display; for other instruments only your name or trade mark and Max, without the conformity marking; and the restrictive use symbol on connected devices not used for the legal purpose.
- Keep the technical documentation and the EU declaration of conformity for 10 years after the instrument was placed on the market, keep series production in conformity, taking account of changes in design and in the standards referenced, and where the risks warrant it sample-test marketed instruments, investigate and keep a register of complaints, non-conforming instruments and recalls, and keep distributors informed.
- Keep the technical documentation and the EU declaration of conformity for 10 years after the instrument was placed on the market.
- Keep series production in conformity, taking account of changes in design or characteristics and in the harmonised standards referenced.
- Where the risks warrant it, sample-test marketed instruments, investigate complaints, keep a register of complaints, non-conforming instruments and recalls, and keep distributors informed of that monitoring.
- Mark your name, registered trade name or trade mark and a single postal contact address on the instrument, supply legally used instruments with instructions and information in a language the Member State determines, and if an instrument you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, inform the competent authorities where it presents a risk, provide conformity documentation on reasoned request, cooperate on risk-elimination measures and identify your suppliers and customers for 10 years.
- Mark your name, registered trade name or trade mark and a single postal contact address on the instrument.
- Supply legally used instruments with instructions and information in a language the Member State determines.
- If an instrument you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk inform the competent national authorities of the Member States concerned.
- On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments.
- Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied.

### Authorised representative

- Act under a written mandate that at least lets you keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the instrument was placed on the market, provide conformity information and documentation on reasoned request, and cooperate with the authorities on risk-elimination measures for the instruments in your mandate.
- Act only under a written mandate from the manufacturer that sets out the tasks you perform on its behalf.
- Keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the instrument was placed on the market.
- On a reasoned request, provide the authority with the information and documentation demonstrating conformity, and cooperate with it on measures to eliminate the risks of the instruments covered by your mandate.
- Do not take over the manufacturer's duty to design and manufacture to the essential requirements or to draw up the technical documentation; those cannot form part of the mandate.
- Where the notified body instructs it, affix its identification number after the CE and metrology markings on the manufacturer's behalf, and be able to identify the economic operators that supplied you and that you supplied for 10 years.
- Where the notified body instructs it, affix its identification number after the CE and metrology markings on the manufacturer's behalf.
- Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied.
- Where the manufacturer is outside the Union and no importer exists, you may be the economic operator established in the Union that Regulation (EU) 2019/1020 requires for every non-automatic weighing instrument placed on the market, verifying the declaration and documentation, informing the authorities of risks and cooperating on corrective action.

### Importer

- Place only compliant instruments on the market, and before placing a legally used instrument on the market check that the manufacturer carried out the Article 13 conformity assessment, drew up the technical documentation, affixed the CE marking and the supplementary metrology marking, supplied the required documents and applied the identification and address markings; hold back instruments you believe do not meet Annex I and inform the manufacturer and the market surveillance authorities where they present a risk. For instruments not intended for a legal purpose, check the identification and address markings.
- Indicate your name, registered trade name or trade mark and a postal contact address on the instrument or, where that requires opening the packaging, on the packaging and in an accompanying document, in a language end users and the authorities understand.
- Ensure legally used instruments are accompanied by instructions and information in a language the Member State determines, in Denmark Danish or English, and keep storage and transport conditions from jeopardising compliance with Annex I while the instrument is under your responsibility.
- Ensure legally used instruments are accompanied by instructions and information in a language the Member State determines, in Denmark Danish or English.
- While an instrument is under your responsibility, keep storage and transport conditions from jeopardising its compliance with Annex I.
- Where the risks warrant it, sample-test marketed instruments, investigate and keep a register of complaints, non-conforming instruments and recalls, and keep distributors informed.
- If an instrument you placed on the market does not conform, immediately take corrective measures, withdraw or recall it, and where it presents a risk inform the competent national authorities of the Member States concerned with details of the non-compliance and the corrective measures.
- Keep a copy of the EU declaration of conformity of legally used instruments at the disposal of the market surveillance authorities for 10 years and ensure the technical documentation can be made available on request; provide conformity information on reasoned request in a language the authority understands, cooperate on risk-elimination measures and identify suppliers and customers for 10 years.
- Keep a copy of the EU declaration of conformity of legally used instruments at the disposal of the market surveillance authorities for 10 years, and ensure the technical documentation can be made available on request.
- On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments.
- Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied.
- If you place an instrument on the market under your own name or trade mark, or modify an instrument already placed on the market in a way that may affect compliance, you carry the manufacturer's obligations under Article 6.

### Distributor (wholesaler, retailer or dealer supplying scales)

- Act with due care and, before making a legally used instrument available, verify that it bears the CE marking and the supplementary metrology marking, is accompanied by the required documents and by instructions and information in a language end users in the Member State understand, and that the manufacturer and importer applied their identification and address markings; hold back instruments you believe do not meet Annex I and inform the manufacturer or importer and the market surveillance authorities where they present a risk. For instruments not intended for a legal purpose, verify the identification and address markings.
- Keep storage and transport conditions from jeopardising compliance with Annex I while a legally used instrument is under your responsibility.
- If an instrument you made available does not conform, make sure corrective measures are taken to bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned.
- On reasoned request, provide the information and documentation demonstrating conformity, cooperate on risk-elimination measures, and identify the economic operators that supplied you and that you supplied for 10 years.
- On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments.
- Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied.
- If you sell under your own name or trade mark or modify an instrument in a way that may affect compliance, you take on the manufacturer's obligations; in Denmark an instrument used for weighing on which payment is based must also meet the rules in the hands of the undertaking that uses it, which must use the prescribed accuracy class, self-check it and have it reverified, and can be ordered to bring it into conformity or forbidden to use it.
- If you make an instrument available under your own name or trade mark, or modify one in a way that may affect compliance, you take on the manufacturer's obligations under Article 6.

## Requirements

Each duty above as an identified requirement (39); ids are permanent and shared with the compliance engine.

### evidence

- `nawi-mfr-design-manufacture-instruments` (Manufacturer (including brand owners), product, before-market) — Design and manufacture instruments intended for the six legal purposes to the essential requirements of Annex I: legal units of mass, an accuracy class I, II, III or IIII with the verification scale interval, minimum capacity and number of verification scale intervals of Table 1, errors within the maximum permissible errors of Table 3, repeatable and reproducible results, insensitivity to tilt, the specified temperature range, correct behaviour on power fluctuation and disturbances, no features that facilitate fraud, correct indication and printing, levelling, zeroing and tare devices, and the extra rules for instruments for direct sales to the public and price labelling. [Art. 4, Art. 6(1) and Annex I, points 1 to 15]
- `nawi-mfr-carry-out-risk-analysis` (Manufacturer (including brand owners), product, before-market) — Carry out an adequate analysis and assessment of the risks of the instrument and include it in the technical documentation. [Art. 6(2) and Annex II, point 1.3]
- `nawi-mfr-draw-technical-documentation` (Manufacturer (including brand owners), product, before-market) — Draw up the Annex II technical documentation: a general description, design and manufacturing drawings with explanations, the harmonised standards applied or the solutions adopted instead, design calculations, examinations and test reports. [Art. 6(2) and Annex II, point 1.3]
- `nawi-mfr-draw-eu-declaration` (Manufacturer (including brand owners), product-market, before-market) — Draw up the EU declaration of conformity per the Annex IV model with the elements of the modules used, kept continuously updated, translated into the languages the Member State requires (in Denmark Danish or English) and, where several Union acts apply, as a single declaration. [Art. 6(2) and Art. 14; https://www.retsinformation.dk/eli/lta/2022/773 · § 37]
- `nawi-mfr-supply-instructions` (Manufacturer (including brand owners), product-market, before-market) — Supply legally used instruments with instructions and information in a language the Member State determines. [Art. 6(7)]
- `nawi-oth-hold-written-mandate` (Authorised representative, company, before-market) — Act only under a written mandate from the manufacturer that sets out the tasks you perform on its behalf. [Art. 7(1) and Art. 7(2)]

### data

- `nawi-mfr-apply-annex-iii` (Manufacturer (including brand owners), product, before-market) — Apply the Annex III inscriptions: for legally used instruments the EU-type examination certificate number where appropriate, your name or trade mark, the accuracy class in an oval, Max, Min, e, the type, batch or serial number and where applicable d, T, dT, Lim, temperature limits and the load-receptor ratio, with Max, Min, e and d also near the display; for other instruments only your name or trade mark and Max, without the conformity marking; and the restrictive use symbol on connected devices not used for the legal purpose. [Art. 6(5), Art. 18 and Annex III]

### mark

- `nawi-mfr-affix-marking-supplementary` (Manufacturer (including brand owners), product, before-market) — Affix the CE marking and the supplementary metrology marking, the capital letter M and the last two digits of the year of affixing in a rectangle of the CE marking's height, visibly, legibly and indelibly to the instrument or its data plate, the metrology marking immediately after the CE marking and both followed by the identification number of the notified body involved in production control, affixed by the body or under its instructions. [Art. 16 and Art. 17]
- `nawi-mfr-mark-name-address` (Manufacturer (including brand owners), product, before-market) — Mark your name, registered trade name or trade mark and a single postal contact address on the instrument. [Art. 6(6)]
- `nawi-oth-affix-notified-body-number` (Authorised representative, product, before-market) — Where the notified body instructs it, affix its identification number after the CE and metrology markings on the manufacturer's behalf. [Art. 17(4)]
- `nawi-imp-indicate-name-registered` (Importer, product, before-market) — Indicate your name, registered trade name or trade mark and a postal contact address on the instrument or, where that requires opening the packaging, on the packaging and in an accompanying document, in a language end users and the authorities understand. [Art. 8(3)]

### decision

- `nawi-mfr-choose-eu-type-examination` (Manufacturer (including brand owners), company, before-market) — Choose EU-type examination (module B) followed by conformity to type based on quality assurance of the production process (module D) or on product verification (module F), or conformity based on unit verification (module G); module B is not compulsory for instruments that use no electronic device and whose load-measuring device does not use a spring to balance the load, which then follow module D1 or F1. In Denmark the notified body must be designated by Sikkerhedsstyrelsen or by another Member State. [Art. 13 and Annex II; https://www.retsinformation.dk/eli/lta/2022/773 · § 34 and § 35]

### procedure

- `nawi-mfr-carry-out-conformity-assessment` (Manufacturer (including brand owners), product, before-market) — Carry out, or have carried out, the Article 13 conformity assessment procedure for instruments intended for a legal purpose. [Art. 6(2) and Art. 13]

### submission

- `nawi-mfr-take-corrective-measures` (Manufacturer (including brand owners), product, on-event) — If an instrument you placed on the market does not conform, immediately bring it into conformity, withdraw or recall it, and where it presents a risk inform the competent national authorities of the Member States concerned. [Art. 6(8)]
- `nawi-imp-immediately-take-corrective` (Importer, product, on-event) — If an instrument you placed on the market does not conform, immediately take corrective measures, withdraw or recall it, and where it presents a risk inform the competent national authorities of the Member States concerned with details of the non-compliance and the corrective measures. [Art. 8(7)]
- `nawi-dist-make-sure-corrective` (Distributor (wholesaler, retailer or dealer supplying scales), product, on-event) — If an instrument you made available does not conform, make sure corrective measures are taken to bring it into conformity, withdraw or recall it, and where it presents a risk immediately inform the competent national authorities of the Member States concerned. [Art. 9(4)]

### verification

- `nawi-oth-economic-operator-established` (Authorised representative, product, ongoing) — Where the manufacturer is outside the Union and no importer exists, you may be the economic operator established in the Union that Regulation (EU) 2019/1020 requires for every non-automatic weighing instrument placed on the market, verifying the declaration and documentation, informing the authorities of risks and cooperating on corrective action. [Art. 4(1) to Art. 4(5)]
- `nawi-imp-place-compliant-instruments` (Importer, product, before-market) — Place only compliant instruments on the market, and before placing a legally used instrument on the market check that the manufacturer carried out the Article 13 conformity assessment, drew up the technical documentation, affixed the CE marking and the supplementary metrology marking, supplied the required documents and applied the identification and address markings; hold back instruments you believe do not meet Annex I and inform the manufacturer and the market surveillance authorities where they present a risk. For instruments not intended for a legal purpose, check the identification and address markings. [Art. 8(1) and Art. 8(2)]
- `nawi-imp-ensure-instructions-accompany` (Importer, product-market, before-market) — Ensure legally used instruments are accompanied by instructions and information in a language the Member State determines, in Denmark Danish or English. [Art. 8(4); https://www.retsinformation.dk/eli/lta/2022/773 · § 20, stk. 2, nr. 3]
- `nawi-dist-act-due-care` (Distributor (wholesaler, retailer or dealer supplying scales), product-market, before-market) — Act with due care and, before making a legally used instrument available, verify that it bears the CE marking and the supplementary metrology marking, is accompanied by the required documents and by instructions and information in a language end users in the Member State understand, and that the manufacturer and importer applied their identification and address markings; hold back instruments you believe do not meet Annex I and inform the manufacturer or importer and the market surveillance authorities where they present a risk. For instruments not intended for a legal purpose, verify the identification and address markings. [Art. 9(1) and Art. 9(2)]

### standing

- `nawi-mfr-keep-documentation-years` (Manufacturer (including brand owners), product, ongoing) — Keep the technical documentation and the EU declaration of conformity for 10 years after the instrument was placed on the market. [Art. 6(3)]
- `nawi-mfr-maintain-series-conformity` (Manufacturer (including brand owners), company, ongoing) — Keep series production in conformity, taking account of changes in design or characteristics and in the harmonised standards referenced. [Art. 6(4)]
- `nawi-mfr-sample-test-register` (Manufacturer (including brand owners), company, ongoing) — Where the risks warrant it, sample-test marketed instruments, investigate complaints, keep a register of complaints, non-conforming instruments and recalls, and keep distributors informed of that monitoring. [Art. 6(4)]
- `nawi-mfr-provide-information-request` (Manufacturer (including brand owners), company, ongoing) — On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments. [Art. 6(9)]
- `nawi-mfr-identify-suppliers-customers` (Manufacturer (including brand owners), company, ongoing) — Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied. [Art. 11]
- `nawi-oth-keep-documentation-years` (Authorised representative, product, ongoing) — Keep the EU declaration of conformity and the technical documentation at the disposal of the national market surveillance authorities for 10 years after the instrument was placed on the market. [Art. 7(2)(a)]
- `nawi-oth-provide-information-request` (Authorised representative, company, ongoing) — On a reasoned request, provide the authority with the information and documentation demonstrating conformity, and cooperate with it on measures to eliminate the risks of the instruments covered by your mandate. [Art. 7(2)(b) and Art. 7(2)(c)]
- `nawi-oth-identify-suppliers-customers` (Authorised representative, company, ongoing) — Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied. [Art. 11]
- `nawi-imp-ensure-storage-transport` (Importer, company, ongoing) — While an instrument is under your responsibility, keep storage and transport conditions from jeopardising its compliance with Annex I. [Art. 8(5)]
- `nawi-imp-sample-test-marketed-instruments` (Importer, company, ongoing) — Where the risks warrant it, sample-test marketed instruments, investigate and keep a register of complaints, non-conforming instruments and recalls, and keep distributors informed. [Art. 8(6)]
- `nawi-imp-keep-declaration-copy` (Importer, product, ongoing) — Keep a copy of the EU declaration of conformity of legally used instruments at the disposal of the market surveillance authorities for 10 years, and ensure the technical documentation can be made available on request. [Art. 8(8)]
- `nawi-imp-provide-information-request` (Importer, company, ongoing) — On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments. [Art. 8(9)]
- `nawi-imp-identify-suppliers-customers` (Importer, company, ongoing) — Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied. [Art. 11]
- `nawi-dist-keep-storage-transport` (Distributor (wholesaler, retailer or dealer supplying scales), company, ongoing) — Keep storage and transport conditions from jeopardising compliance with Annex I while a legally used instrument is under your responsibility. [Art. 9(3)]
- `nawi-dist-provide-information-request` (Distributor (wholesaler, retailer or dealer supplying scales), company, ongoing) — On a reasoned request, provide the authority with the information and documentation demonstrating conformity in a language it understands, and cooperate on measures to eliminate the risks posed by the instruments. [Art. 9(5)]
- `nawi-dist-identify-suppliers-customers` (Distributor (wholesaler, retailer or dealer supplying scales), company, ongoing) — Be able to identify, for 10 years after each supply, the economic operators that supplied you and the economic operators you supplied. [Art. 11]

## Penalties

Member States lay down the rules on penalties for infringements by economic operators of their national transposing laws and enforce them; the penalties must be effective, proportionate and dissuasive and may include criminal penalties for serious infringements. Market surveillance authorities evaluate instruments that present a risk to the public interests the directive protects, require corrective action, withdrawal or recall within a period commensurate with the risk, inform the notified body, and if the operator fails to act prohibit or restrict the making available, withdraw or recall the instrument and notify the Commission and the other Member States; compliant instruments that still present a risk can be treated the same way. Formal non-compliance, such as a missing or wrongly affixed CE marking or supplementary metrology marking, missing Annex III inscriptions, a missing notified body number, a missing or incorrect EU declaration of conformity, missing or incomplete technical documentation or missing manufacturer or importer identification, must be ended and otherwise leads to restriction, prohibition, withdrawal or recall. Since 16 July 2021 the surveillance powers come from Regulation (EU) 2019/1020, whose authorities can demand documents and supply-chain information, inspect and check products, require corrective action, prohibit the making available and have instruments withdrawn, recalled or destroyed. In Denmark, executive order nr. 773 of 1 June 2022 lets Sikkerhedsstyrelsen order formal non-compliance corrected within a deadline and then order withdrawal, recall or a sales ban under the product act, and punishes with a fine the placing on the market of non-conforming instruments, missing documentation, markings, instructions, notifications, mandates and use of a body not designated by Sikkerhedsstyrelsen or another Member State, with imprisonment of up to 2 years in aggravating circumstances; executive order nr. 591 of 29 May 2018 fines the owner who uses an unmarked instrument, the wrong accuracy class or no self-check or reverification for a legal purpose; and the product act adds orders to warn users, stop marketing, remedy, stop sales, withdraw, recall or destroy, prohibitions, orders to the owner of an instrument used for payment-based weighing, and fines, rising to imprisonment of up to 2 years in aggravating circumstances, for breaches of the act, of Regulation (EU) 2019/1020 Article 4 and of the authority's decisions. Since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen.

## Checklist

1. Confirm the instrument is non-automatic, that is it needs an operator during weighing; an instrument that weighs without one falls under the Measuring Instruments Directive as MI-006 instead (Article 2, point (2)).
2. Decide which of the seven categories of use in Article 1(2) the instrument is intended for; only the six purposes in points (a) to (f) trigger the essential requirements, the conformity assessment and the CE and metrology markings (Articles 1(2) and 4).
3. Decide your role for each product, remembering that selling under your own brand or modifying an instrument makes you the manufacturer (Article 2, point (5), and Article 10).
4. Select the accuracy class I, II, III or IIII and the verification scale interval, minimum capacity and number of verification scale intervals from Annex I Table 1, and design to the maximum permissible errors of Table 3 and the direct-sales rules of point 14 where relevant (Annex I, points 2, 4 and 14).
5. Apply the harmonised standards listed in the Official Journal under the directive, or document the solutions used instead (Article 12 and Annex II, point 1.3(c)(iv)).
6. Choose the module route, B + D, B + F, D1 or F1 for mechanical non-spring instruments, or G, and engage a notified body listed by the Commission; in Denmark one designated by Sikkerhedsstyrelsen or another Member State (Article 13, Annex II and executive order nr. 773/2022 § 34).
7. Compile the technical documentation with the risk analysis, drawings, standards list, calculations and test reports, and keep it with the declaration for 10 years (Article 6(3) and Annex II, point 1.3).
8. Draw up the Annex IV EU declaration of conformity, as a single declaration where other Union acts also apply, translated as the Member States require (Article 14).
9. Affix the CE marking, the supplementary metrology marking M with the two-digit year in a rectangle, the notified body number and the Annex III inscriptions before placing on the market, and the restrictive use symbol on connected non-legal devices (Articles 16, 17 and 18 and Annex III).
10. Set up the corrective-action and notification procedure, 10-year supplier and customer traceability and, where the risks warrant it, sample testing and a complaints register (Articles 6(4), 6(8), 8(6), 8(7), 9(4) and 11).

## Questions

### When did the Non-automatic Weighing Instruments Directive 2014/31/EU start to apply?

The recast directive was adopted on 26 February 2014, published in the Official Journal on 29 March 2014 and entered into force on 18 April 2014. Member States had to transpose it by 19 April 2016 and apply their measures from 20 April 2016, when Article 1, the first two definitions, Articles 3, 4, 5 and 18 and Annexes I, V and VI also took effect and Directive 2009/23/EC was repealed. Instruments conforming to the old directive and placed on the market before 20 April 2016 may still be made available and put into service, and certificates issued under it remain valid. The directive has not been amended since.

### Which scales need the CE marking and the M metrology marking?

Non-automatic weighing instruments used or intended for the six purposes in Article 1(2)(a) to (f): mass for commercial transactions; mass for calculating a toll, tariff, tax, bonus, penalty, remuneration, indemnity or similar payment; mass for the application of laws or regulations or for court expertise; weighing patients in medical practice for monitoring, diagnosis and treatment; making up medicines on prescription in a pharmacy and analyses in medical and pharmaceutical laboratories; and price on the basis of mass for direct sales to the public and the making-up of prepackages. Instruments for any other use, point (g), must not bear the conformity marking and need only the manufacturer's name or trade mark and the maximum capacity.

### What are the accuracy classes I, II, III and IIII?

Annex I defines four accuracy classes: I special, II high, III medium and IIII ordinary. Each is set by the verification scale interval e, the minimum capacity and the number of verification scale intervals in Table 1: class I has e of at least 0,001 g, a minimum capacity of 100 e and at least 50 000 intervals; class II covers e from 0,001 g to 0,05 g with 20 e and 100 to 100 000 intervals, or e of at least 0,1 g with 50 e and 5 000 to 100 000 intervals; class III covers e from 0,1 g to 2 g with 20 e and 100 to 10 000 intervals, or e of at least 5 g with 20 e and 500 to 10 000 intervals; class IIII has e of at least 5 g, 10 e and 100 to 1 000 intervals. The maximum permissible error is 0,5 e, 1,0 e or 1,5 e depending on the load, and twice that in service. In Denmark the using undertaking must use class I, II or III for legal weighing, class I or II for precious metals, and may use class IIII for bulk goods, transport fees and vehicle weighing for fines.

### Do I need a notified body under the NAWI Directive?

Yes for every instrument intended for a legal purpose. The manufacturer chooses EU-type examination (module B) followed by conformity to type based on quality assurance of the production process (module D) or on product verification (module F), or conformity based on unit verification (module G). Module B is not compulsory for instruments that use no electronic device and whose load-measuring device does not use a spring to balance the load; those use quality assurance of the production process (module D1) or product verification (module F1) instead, still with a notified body. The Commission notes that the directive requires notified bodies for most products in its scope, and in Denmark the body must be designated by Sikkerhedsstyrelsen or by another Member State.

### What is the supplementary metrology marking?

The capital letter M and the last two digits of the year of its affixing, surrounded by a rectangle whose height equals the height of the CE marking. It follows the same general principles as the CE marking, is affixed visibly, legibly and indelibly to the instrument or its data plate before placing on the market, immediately after the CE marking, and both are followed by the identification number of the notified body involved in production control, affixed by the body or under its instructions; other marks indicating a special risk or use may follow. Devices connected to a legal instrument but not used for the legal purpose carry the restrictive use symbol instead, a black M on a red square crossed by two diagonals.

### Can a scale certified under the old Directive 2009/23/EC still be sold?

Instruments covered by Directive 2009/23/EC, in conformity with it and placed on the market before 20 April 2016 may still be made available and put into service, and certificates issued under it are valid under the current directive. Sikkerhedsstyrelsen adds that such instruments may keep the old green M marking and need no manufacturer's address, that a declaration referring only to Directive 2009/23/EC must be reissued under Directive 2014/31/EU while keeping the old type-examination certificate, and that a modified instrument needs a new conformity assessment and declaration under the current directive, with the person modifying it treated as the manufacturer.

### Who enforces the NAWI Directive in Denmark and what applies to a scale in use?

The product act lists the directive in section 2 as point 13 and names Erhvervsstyrelsen as the control authority; the tasks are carried out by Sikkerhedsstyrelsen, since January 2026 the department Markedsovervågning of Erhvervsstyrelsen, which also designates the Danish notified bodies under executive order nr. 773/2022. Once a scale is in legal use, executive order nr. 591/2018 requires the using undertaking to use an instrument marked under order nr. 773/2022 in the prescribed accuracy class, to run a metrologically traceable self-check against an in-service tolerance of twice the tolerance at placing on the market, to stop using the scale and have it reverified by a DANAK-accredited or equivalent firm when its seal is broken, and to use it only in the range in which it was reverified; the authority can order the owner to bring an instrument used for payment into conformity or forbid its use, and breaches are fined.

### How long must I keep the technical documentation and traceability records?

Manufacturers keep the technical documentation and the EU declaration of conformity of legally used instruments for 10 years after the instrument was placed on the market, authorised representatives keep both at the disposal of the authorities for the same period, and importers keep a copy of the declaration for 10 years and ensure the documentation can be produced. All economic operators must be able to identify who supplied them and whom they supplied for 10 years after the supply.

## What changed

- 2026-09-12 (guidance): **Guide rebuilt on the SPEC-62 model from the directive text** — The guide was rewritten from the text of Directive 2014/31/EU, Regulation (EU) 2019/1020, the Danish executive orders nr. 773/2022 and nr. 591/2018, the product act and Sikkerhedsstyrelsen's NAWI questions and answers: the seven categories of use, the Annex I class tables, the exact module routes and the Annex III inscriptions replace the earlier summary, the earlier claim of a type-examination-free route for class III and IIII instruments is corrected to the module D1 and F1 rule for instruments without electronic devices or a spring, the Danish owner duties and enforcement basis are now sourced, Sikkerhedsstyrelsen is placed within Erhvervsstyrelsen since January 2026, and the market surveillance reference is read as Regulation (EU) 2019/1020.
- 2022-07-01 (applies): **Danish executive order nr. 773/2022 on making non-automatic weighing instruments available in force** — The order issued under the product act replaces order nr. 1381 of 25 November 2016, repeats the seven categories of use, the operator duties, the module routes, the CE and metrology markings and the designation of notified bodies by Sikkerhedsstyrelsen, and keeps the 20 April 2016 transition for instruments meeting the 2003 control order and for certificates under Directive 2009/23/EC.
- 2021-07-16 (applies): **Regulation (EU) 2019/1020 replaces the market surveillance articles of Regulation (EC) No 765/2008** — Articles 15 to 29 of Regulation (EC) No 765/2008, which Article 36 of the directive cites, are replaced and the directive is listed as point 50 of Annex I to Regulation (EU) 2019/1020; its Article 4 requires an economic operator established in the Union for every non-automatic weighing instrument placed on the market.
- 2016-04-20 (applies): **Directive 2014/31/EU applies; Directive 2009/23/EC repealed** — Member States apply their transposing measures from 20 April 2016, Article 1, the first two definitions, Articles 3, 4, 5 and 18 and Annexes I, V and VI apply from the same date and Directive 2009/23/EC is repealed; instruments conforming to the old directive and placed on the market before 20 April 2016 may still be made available and put into service, and its certificates remain valid.
- 2014-04-18 (in-force): **Directive 2014/31/EU enters into force** — Adopted on 26 February 2014 as a recast of Directive 2009/23/EC aligned with the New Legislative Framework and published in OJ L 96 on 29 March 2014, the directive entered into force on the twentieth day after publication; Member States had until 19 April 2016 to transpose it.

## NAWI in plain terms

The Non-automatic Weighing Instruments Directive (NAWI, sometimes NAWID), formally Directive 2014/31/EU, is the EU's law for scales that need a person during weighing. A weighing instrument is a measuring instrument that determines the mass of a body by using the action of gravity on it, and it is non-automatic when it requires the intervention of an operator during weighing (Art. 2, points (1) and (2)). The directive applies to all such instruments (Art. 1(1)), but it distinguishes seven categories of use, and only the first six carry the metrological regime: mass for commercial transactions; mass for calculating a toll, tariff, tax, bonus, penalty, remuneration, indemnity or similar payment; mass for the application of laws or regulations or for an expert opinion in court proceedings; mass in medical practice for weighing patients for monitoring, diagnosis and treatment; mass for making up medicines on prescription in a pharmacy and in analyses in medical and pharmaceutical laboratories; and price on the basis of mass for direct sales to the public and the making-up of prepackages. The seventh category, point (g), is every other application (Art. 1(2)). An instrument that meets the directive circulates freely: Member States may not impede its making available or, for the six legal uses, its putting into service (Art. 5).

The 2014 text is a recast of Directive 2009/23/EC, itself the codification of Council Directive 90/384/EEC, aligned with the New Legislative Framework, adding the economic operator duties, the traceability rules and the market surveillance procedures shared with the other CE-marking directives (recital 1 and footnote 3). It entered into force on 18 April 2014, Member States had to transpose it by 19 April 2016 and apply it from 20 April 2016, when Directive 2009/23/EC was repealed (Art. 44 to Art. 46). The directive has not been amended; the three corrigenda recorded on EUR-Lex (2015, 2016 and 2021) concern other language versions, not the English text.

> **Official text**
> Read the directive on EUR-Lex: [Directive 2014/31/EU (CELEX 32014L0031)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031). No consolidated version exists because the directive has never been amended; the [document information page](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32014L0031) lists the corrigenda and the repeal of Directive 2009/23/EC.

## Scope

The directive's requirements follow the intended use, not the type of scale. Instruments used or intended for the six purposes in Article 1(2)(a) to (f) must satisfy the essential requirements of Annex I; where such an instrument includes or is connected to devices that are not used for those purposes, those devices are not subject to the essential requirements (Art. 4) and carry the restrictive use symbol instead, a black capital M on a red square of at least 25 mm by 25 mm with two crossed diagonals (Art. 18 and Annex III, point 3). Member States must ensure that only conforming instruments are made available, that instruments are not put into service for the six legal uses unless they conform, and that instruments in such service continue to conform (Art. 3). Instruments intended for any other use, point (g), need only the manufacturer's name or trade mark and the maximum capacity and must not bear the conformity marking (Annex III, point 2), but their makers, importers and distributors keep the identification and address duties (Art. 6(5) and (6), Art. 8(2) and Art. 9(2)).

Automatic weighing instruments, which weigh without an operator, are outside the directive; they are MI-006 under the Measuring Instruments Directive 2014/32/EU (Directive 2014/32/EU, Art. 2(1)). Instruments conforming to Directive 2009/23/EC and placed on the market before 20 April 2016 may still be made available and put into service, and certificates issued under the old directive remain valid (Art. 43).

The duties fall on the economic operators: manufacturer, authorised representative, importer and distributor (Art. 2, point (9)). A manufacturer is whoever manufactures an instrument or has it designed or manufactured and markets it under his own name or trade mark (Art. 2, point (5)), and an importer or distributor that sells under its own brand or modifies an instrument in a way that may affect compliance takes on the manufacturer's obligations (Art. 10). In Denmark, executive order nr. 773 of 1 June 2022 repeats the seven categories of use and the operator duties (executive order nr. 773/2022, § 2), and executive order nr. 591 of 29 May 2018 adds duties for the owner of an instrument in legal use (executive order nr. 591/2018, § 1 and § 3).

## What you must do

### Essential requirements and accuracy classes

An instrument for a legal use must meet the essential requirements of Annex I, written in the terminology of the International Organisation of Legal Metrology. The metrological requirements cover the legal units of mass, with the troy ounce allowed for precious metals and the metric carat for precious stones (point 1); the four accuracy classes I special, II high, III medium and IIII ordinary, each defined in Table 1 by the verification scale interval e, the minimum capacity and the minimum and maximum number of verification scale intervals, class I with e of at least 0,001 g, 100 e and at least 50 000 intervals, class II with e from 0,001 g to 0,05 g or at least 0,1 g, class III with e from 0,1 g to 2 g or at least 5 g and 100 or 500 to 10 000 intervals, and class IIII with e of at least 5 g, 10 e and 100 to 1 000 intervals (point 2); the classification of single-range, multiple-range and multi-interval instruments (point 3); the maximum permissible errors of Table 3, 0,5 e, 1,0 e or 1,5 e depending on the load, doubled in service (point 4); repeatability and reproducibility (point 5); reaction to small load changes (point 6); and the influence of tilt, temperature, with a range of at least 5 °C for class I, 15 °C for class II and 30 °C for classes III and IIII, power supply, humidity and prolonged loading (point 7). The design and construction requirements cover the preservation of metrological qualities, fault detection and alarms on electronic instruments, durability, interfaces, protection against fraudulent use and ready execution of statutory controls (point 8), the indication and printing of results (points 9 and 10), levelling, zeroing and tare devices (points 11 to 13), the additional rules for instruments for direct sales to the public with a maximum capacity of not more than 100 kg, which must show the customer all essential information and the price calculation, and the marking 'Not to be used for direct sale to the public' on similar instruments that do not meet them (point 14), and price labelling instruments (point 15).

### Harmonised standards

Instruments conforming to harmonised standards, or parts of them, whose references are published in the Official Journal are presumed to conform to the essential requirements those standards cover (Art. 12). The Commission publishes the current list of harmonised standards under the directive and has asked CEN and CENELEC to update them, and works with WELMEC on guidance such as Guide 2 on the common application of the MID and the NAWID, Guide 2.4 on non-critical constructions, Guide 5.2 on market surveillance and Guide 7.5 on software in non-automatic weighing instruments (European Commission, measuring and weighing instruments page). Sikkerhedsstyrelsen's questions and answers explain that type-examination certificates issued under EN 45501:1992 remain valid and that a declaration may refer to Directive 2014/31/EU and that standard, but that a certificate cannot be extended after 10 years if the standard has changed (Sikkerhedsstyrelsen, NAWI questions and answers).

### Conformity assessment with a notified body

Conformity with Annex I is established, at the manufacturer's choice, by EU-type examination (module B, Annex II point 1) followed either by conformity to type based on quality assurance of the production process (module D, point 2) or by conformity to type based on product verification (module F, point 4), or by conformity based on unit verification (module G, point 6). Module B is not compulsory for instruments that do not use electronic devices and whose load-measuring device does not use a spring to balance the load; for those instruments quality assurance of the production process (module D1, point 3) or product verification (module F1, point 5) applies instead (Art. 13(1)). Every route involves a notified body, and the documents and correspondence are drawn up in an official language of the Member State where the procedure is carried out or in a language the body accepts (Art. 13(2)). The technical documentation lodged with the application for EU-type examination must allow the conformity to be assessed and include an adequate analysis and assessment of the risks, a general description, design and manufacturing drawings and the explanations needed to understand them, the harmonised standards applied in full or in part or the solutions adopted instead, design calculations and examinations, and test reports (Annex II, point 1.3). Member States notify the bodies authorised for these tasks and designate a notifying authority responsible for assessing, notifying and monitoring them; they may decide that the assessment and monitoring are carried out by a national accreditation body within the meaning of Regulation (EC) No 765/2008, and where the notifying authority entrusts those tasks to a non-governmental body, that body must be a legal entity, meet the requirements for notifying authorities mutatis mutandis and carry liability cover, with the notifying authority remaining fully responsible (Art. 19 and Art. 20); the Commission assigns each body an identification number and publishes the list (Art. 28). In Denmark the manufacturer must use a body designated by Sikkerhedsstyrelsen or by another Member State (executive order nr. 773/2022, § 34 and § 41).

### Declaration, markings and inscriptions

The EU declaration of conformity states that the essential requirements have been demonstrated, follows the Annex IV model, contains the elements of the modules used, is continuously updated, is translated into the languages the Member State requires and, where several Union acts apply, is a single declaration covering them all; by drawing it up the manufacturer assumes responsibility (Art. 14). In Denmark it must be in Danish or English (executive order nr. 773/2022, § 37). Conformity of a legally used instrument is shown by the CE marking and the supplementary metrology marking (Art. 15): the capital letter M and the last two digits of the year of its affixing, surrounded by a rectangle of the CE marking's height, subject to the same general principles as the CE marking (Art. 16). Both are affixed visibly, legibly and indelibly to the instrument or its data plate before placing on the market, the metrology marking immediately after the CE marking and both followed by the identification number of the notified body involved in production control, affixed by the body or under its instructions; other marks indicating a special risk or use may follow (Art. 17).

Legally used instruments also bear the Annex III inscriptions: the EU-type examination certificate number where appropriate, the manufacturer's name or trade mark, the accuracy class enclosed in an oval, Max, Min and e, the type, batch or serial number and, where applicable, an identification mark on each separate unit, d, the tare effects T and dT, the maximum safe load Lim, the special temperature limits and the ratio between load receptor and load; Max, Min, e and d are repeated near the display, the data plate must be sealable, and the instrument must have facilities so that the marking and inscriptions cannot be removed without damage (Annex III, point 1). Instruments not intended for a legal use bear only the manufacturer's name or trade mark and Max (Annex III, point 2).

### Obligations by role

Manufacturers design and manufacture legally used instruments to Annex I, draw up the technical documentation and carry out the conformity assessment, draw up the declaration and affix both markings, keep the documentation and declaration for 10 years, keep series production in conformity, sample-test and keep a complaints register where the risks warrant it, apply the identification and inscriptions, mark their name and address, supply instructions in the required language, take corrective action, inform the authorities of risks and cooperate on request (Art. 6). Authorised representatives act under a mandate that must at least cover keeping the documents and cooperating with the authorities, and cannot take over the design or documentation duties (Art. 7). Importers place only compliant instruments on the market, verify the manufacturer's assessment, documentation, markings, documents and identification, add their own name and address, ensure the instructions, protect the instrument in storage and transport, sample-test where warranted, take corrective action and keep the declaration for 10 years (Art. 8). Distributors verify the markings, documents, instructions and identification before making an instrument available, protect it in storage and transport and see that corrective action is taken (Art. 9). Importers and distributors that sell under their own brand or modify an instrument become manufacturers (Art. 10), and every operator identifies its suppliers and customers for 10 years (Art. 11). Since 16 July 2021, Regulation (EU) 2019/1020 also requires an economic operator established in the Union, a manufacturer, importer, authorised representative or fulfilment service provider, for every instrument placed on the market (Regulation (EU) 2019/1020, Art. 4).

### Instruments in use in Denmark

Once a scale is in legal use, Danish executive order nr. 591 of 29 May 2018 binds the undertaking that has the instrument at its disposal and uses it for one of the six purposes, which the order calls the vægtejer: the instrument must meet and be marked under the making-available order, be installed per the manufacturer's instructions and belong to accuracy class I, II or III, class I or II for trade in precious metals, with class IIII also allowed for commercial transactions and payments involving bulk goods, transport fees other than postage and vehicle weighing for fines (§ 3 and § 4). The owner must run a self-check based on metrologically traceable measurements so that the in-service tolerance, twice the tolerance that applied when the instrument was placed on the market, is not exceeded, must not have the instrument set to exploit the maximum permissible errors or favour one party, and must stop using it and have it reverified when its seal is broken or it has been tampered with, by a firm accredited by DANAK or an equivalent body or lawfully established in another EU/EEA country, using it only in the range in which it was reverified (§ 5 to § 8). Sikkerhedsstyrelsen controls compliance and fines breaches (§ 10 and § 12). Sikkerhedsstyrelsen's guidance notes that the 2018 order changed, among other things, the earlier requirement of four-yearly reverification, and that the product act's section 16 a addresses the instrument owner directly (Sikkerhedsstyrelsen, NAWI in use guidance).

## Enforcement and penalties

Article 36 applies Article 15(3) and Articles 16 to 29 of Regulation (EC) No 765/2008 to all instruments covered by Article 1; those articles were replaced by Regulation (EU) 2019/1020 from 16 July 2021, which lists the directive as point 50 of its Annex I, so the reference is read as that regulation. Where an authority has sufficient reason to believe that an instrument presents a risk to the public interests the directive protects, it evaluates the instrument, requires corrective action, withdrawal or recall within a period commensurate with the risk, informs the notified body and, if the operator does not act, prohibits or restricts the making available, withdraws or recalls the instrument and informs the Commission and the other Member States (Art. 37). The Commission decides disputed national measures through the Union safeguard procedure (Art. 38), compliant instruments that still present a risk can be treated the same way (Art. 39), and formal non-compliance, a missing or wrongly affixed CE or metrology marking, missing Article 6(5) inscriptions, a missing notified body number, a missing or incorrect declaration, missing documentation or missing identification, must be ended and otherwise leads to restriction, prohibition, withdrawal or recall (Art. 40).

Penalties are set nationally: Member States lay down effective, proportionate and dissuasive penalties for infringements of their transposing laws, which may include criminal penalties for serious infringements (Art. 42). In Denmark, legal metrology has fallen under the product act (lov om produkter og markedsovervågning) since 1 July 2021 (Sikkerhedsstyrelsen, rules and executive orders page); the act lists the directive in section 2 as point 13, names Erhvervsstyrelsen as the control authority and provides orders to warn users, stop marketing, remedy, stop sales, withdraw, recall or destroy, prohibitions, orders to the owner of an instrument used for payment-based measurement and fines that rise to imprisonment of up to 2 years in aggravating circumstances (LBK nr. 22/2026, § 2, § 9, § 14, § 16, § 16 a and § 37). Executive order nr. 773 of 1 June 2022 implements the directive itself: it lets Sikkerhedsstyrelsen order formal non-compliance corrected within a deadline and then order withdrawal, recall or a sales ban, and punishes breaches, including the use of a notified body not designated by Sikkerhedsstyrelsen or another Member State, with fines and, in aggravating circumstances, imprisonment of up to 2 years (§ 54 and § 55). Since January 2026 Sikkerhedsstyrelsen is the department Markedsovervågning of Erhvervsstyrelsen (the Danish Business Authority) and carries out the same tasks.

## How Conphora helps

Conphora monitors the NAWI Directive, its harmonised standards and the WELMEC guides, and maps your scales against the intended-use categories, the module routes and the marking and inscription requirements, flagging gaps in the technical documentation, the EU declaration of conformity, the metrology marking and the Annex III inscriptions before they become enforcement problems. The platform helps you build and keep the documentation and the 10-year records, combines the NAWI declaration with the EMC, Low Voltage and other declarations the same scale needs, and alerts you when a standard, a Danish executive order or the enforcement setup changes.

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

## Sources

- [Directive 2014/31/EU on non-automatic weighing instruments as published in OJ L 96, 29 March 2014 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031)
- [Document information, dates, corrigenda and relationships for CELEX 32014L0031 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32014L0031)
- [Directive 2009/23/EC on non-automatic weighing instruments, repealed from 20 April 2016 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0023)
- [Directive 2014/32/EU on measuring instruments, which covers automatic weighing instruments (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0032)
- [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, with the WELMEC guides and harmonised standards under the NAWID (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. 773 af 1. juni 2022 om tilgængeliggørelse på markedet af ikke-automatiske vægte (Retsinformation)](https://www.retsinformation.dk/eli/lta/2022/773)
- [Bekendtgørelse nr. 591 af 29. maj 2018 om anvendelse af ikke-automatiske vægte (Retsinformation)](https://www.retsinformation.dk/eli/lta/2018/591)
- [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://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/love-og-regler-0/regler-og-bekendtgoerelser-maaling-og-vaegt)
- [Spørgsmål og svar om direktiv om ikke-automatiske vægte (NAWI) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-vaegt-og-e-maerkning-metrologi/spoergsmaal-og-svar/spoergsmaal-og-svar-om-direktiv-om-ikke-automatiske-vaegte-nawi)
- [Vejledning for ikke-automatiske vægte (NAWI) i brug (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/vejledning-ikke-automatiske-vaegte-nawi-brug)
- [Legal måling og vejning (legal metrologi) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/legal-maaling-og-vejning-legal-metrologi)
- [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 2014/31/EU on non-automatic weighing instruments as published in OJ L 96, 29 March 2014 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0031)
- [Document information, dates, corrigenda and relationships for CELEX 32014L0031 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32014L0031)
- [Directive 2009/23/EC on non-automatic weighing instruments, repealed from 20 April 2016 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009L0023)
- [Directive 2014/32/EU on measuring instruments, which covers automatic weighing instruments (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0032)
- [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, with the WELMEC guides and harmonised standards under the NAWID (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. 773 af 1. juni 2022 om tilgængeliggørelse på markedet af ikke-automatiske vægte (Retsinformation)](https://www.retsinformation.dk/eli/lta/2022/773)
- [Bekendtgørelse nr. 591 af 29. maj 2018 om anvendelse af ikke-automatiske vægte (Retsinformation)](https://www.retsinformation.dk/eli/lta/2018/591)
- [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://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/love-og-regler-0/regler-og-bekendtgoerelser-maaling-og-vaegt)
- [Spørgsmål og svar om direktiv om ikke-automatiske vægte (NAWI) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-vaegt-og-e-maerkning-metrologi/spoergsmaal-og-svar/spoergsmaal-og-svar-om-direktiv-om-ikke-automatiske-vaegte-nawi)
- [Vejledning for ikke-automatiske vægte (NAWI) i brug (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/vejledning-ikke-automatiske-vaegte-nawi-brug)
- [Legal måling og vejning (legal metrologi) (Sikkerhedsstyrelsen)](https://www.sik.dk/erhverv/produkter/maaling-og-vaegt-metrologi/vejledninger/legal-maaling-og-vejning-legal-metrologi)
- [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_