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2014, Member States had to transpose it by 19 April 2016 and apply it from 20 April 2016, when Directive 2009/23/EC was repealed (Art. 44 to Art. 46).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). No consolidated version exists because the directive has never been amended; the document information page 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 · See plans and pricing
Sources
- Directive 2014/31/EU on non-automatic weighing instruments as published in OJ L 96, 29 March 2014 (EUR-Lex)
- Document information, dates, corrigenda and relationships for CELEX 32014L0031 (EUR-Lex)
- Directive 2009/23/EC on non-automatic weighing instruments, repealed from 20 April 2016 (EUR-Lex)
- Directive 2014/32/EU on measuring instruments, which covers automatic weighing instruments (EUR-Lex)
- Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)
- Legal metrology (European Commission, DG GROW)
- Measuring and weighing instruments in the EU, with the WELMEC guides and harmonised standards under the NAWID (European Commission, DG GROW)
- Bekendtgørelse nr. 773 af 1. juni 2022 om tilgængeliggørelse på markedet af ikke-automatiske vægte (Retsinformation)
- Bekendtgørelse nr. 591 af 29. maj 2018 om anvendelse af ikke-automatiske vægte (Retsinformation)
- Bekendtgørelse af lov om produkter og markedsovervågning, LBK nr. 22 af 8. januar 2026 (Retsinformation)
- Regler og bekendtgørelser for måling og vægt (Sikkerhedsstyrelsen)
- Spørgsmål og svar om direktiv om ikke-automatiske vægte (NAWI) (Sikkerhedsstyrelsen)
- Vejledning for ikke-automatiske vægte (NAWI) i brug (Sikkerhedsstyrelsen)
- Legal måling og vejning (legal metrologi) (Sikkerhedsstyrelsen)
- Sikkerhedsstyrelsen, en del af Erhvervsstyrelsen from January 2026 (Erhvervsstyrelsen)
This guide is for general information and is not legal advice.