Technical Insight

GAR INSIGHT
Non-Automatic Weighing Instruments Directive 2014/31/EU — NAWI Requirements, Conformity Assessment & CE Marking
GAR INSIGHT · WEIGHING INSTRUMENTS & CE MARKING

When the result of a weighing operation determines a selling price, supports a medical decision, establishes a commercial transaction or provides a legally controlled measurement, the reliability of the weighing instrument becomes a matter of legal metrology rather than simply product performance.

Directive 2014/31/EU establishes the European regulatory framework for non-automatic weighing instruments, commonly referred to as NAWIs. A non-automatic weighing instrument is a weighing instrument that requires the intervention of an operator during weighing.

The Directive distinguishes between instruments used for specifically regulated applications and instruments used for other purposes. This distinction is fundamental because instruments used for the regulated applications identified by the Directive must satisfy essential metrological requirements and undergo the applicable conformity assessment before being placed on the market and put into use.

For regulated applications, compliant instruments carry both the CE marking and the supplementary metrology marking. Depending on the conformity assessment route, an appropriately notified conformity assessment body is involved in assessing the instrument or the manufacturer’s quality system.

This GAR Insight explains NAWI scope, regulated applications, accuracy classes, essential requirements, weighing performance, conformity assessment, technical documentation, Notified Body involvement, marking and the route to European market access.

ARTICLE GUIDE

Navigate This Article

Explore NAWI scope, regulated applications, accuracy classes, essential requirements, metrological performance, conformity assessment, technical documentation and CE marking.

01
REGULATORY FOUNDATION

Understanding Directive 2014/31/EU

Directive 2014/31/EU harmonises requirements concerning the making available on the market of non-automatic weighing instruments and establishes specific requirements for instruments used for legally controlled weighing applications.

The Directive replaced Directive 2009/23/EC and has applied since 20 April 2016.

Legislation Directive 2014/31/EU
Common Name NAWI / NAWID
Regulatory Field Legal Metrology
Applicable Since 20 April 2016
The regulatory question is not simply whether the product is a weighing scale. The manufacturer must establish whether the instrument is non-automatic and whether it is intended for one of the regulated applications for which the Directive requires conformity with its essential requirements.
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02
PRODUCT QUALIFICATION

What Is a Non-Automatic Weighing Instrument?

A weighing instrument determines the mass of a body by using the action of gravity on that body. It may also determine other mass-related quantities, parameters, magnitudes or characteristics.

Under Directive 2014/31/EU, a weighing instrument is considered non-automatic when it requires the intervention of an operator during weighing.

Non-Automatic Weighing

The weighing operation requires human intervention—for example, placing or removing the load, initiating or controlling the weighing process, or determining acceptance of the weighing result.

Automatic Weighing

The weighing process operates according to a predetermined programme without requiring operator intervention during the weighing operation. Such instruments generally fall outside NAWID and may instead be addressed by the MID where applicable.

The distinction between NAWI and automatic weighing is fundamental. Two instruments may use similar load cells, electronics and software but fall under different EU legal-metrology legislation because of how the weighing operation is performed.
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03
REGULATED USE

Which Weighing Applications Require NAWI Conformity?

Directive 2014/31/EU identifies specific applications for which instruments must satisfy the essential requirements of the Directive. These are situations where inaccurate weighing could affect trade, taxation, health, legal decisions or consumer protection.

Commercial Transactions

Determination of mass for commercial transactions is a regulated application under the Directive.

Tolls, Tariffs & Taxes

Instruments used to calculate tolls, tariffs, taxes, bonuses, penalties, remuneration, indemnities or similar payments based on mass fall within the regulated applications.

Laws & Expert Opinion

Determination of mass for the application of laws or regulations and for expert opinions given in court proceedings is covered.

Medical Weighing

Weighing patients for the purposes of monitoring, diagnosis and medical treatment is a regulated application.

Pharmacy & Laboratory Use

Making up medicines on prescription in a pharmacy and certain analyses carried out in medical and pharmaceutical laboratories are covered applications.

Direct Sales & Prepackages

Determination of price on the basis of mass for direct sales to the public and the making-up of prepackages is regulated.

Intended use determines the regulatory route. A scale intended only for an unregulated internal process can have a different conformity position from an otherwise similar scale intended to determine the price paid by a consumer.
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04
METROLOGICAL CLASSIFICATION

NAWI Accuracy Classes

Non-automatic weighing instruments subject to the essential requirements are assigned an accuracy class appropriate to their metrological performance and intended application.

Special Accuracy

Class I

High-precision weighing instruments used where particularly demanding metrological performance is required.

High Accuracy

Class II

Precision weighing instruments used for applications requiring a high level of measurement accuracy.

Medium Accuracy

Class III

A widely used category covering many commercial, medical and general legal-for-trade weighing applications.

Ordinary Accuracy

Class IIII

Instruments intended for applications where the permitted metrological characteristics correspond to ordinary accuracy.

Accuracy class is not a marketing choice. The instrument’s class must correspond with its design, verification scale interval, capacity, number of verification scale intervals and applicable metrological requirements.
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05
ANNEX I

Essential Requirements for Regulated NAWIs

Instruments intended for the regulated applications identified by the Directive must satisfy the essential requirements established in Annex I.

Units of Mass

Measurement results must use permitted legal units and appropriate symbols.

Accuracy

Errors must remain within the maximum permissible errors applicable to the instrument.

Repeatability

Repeated weighing of the same load should provide sufficiently consistent results.

Eccentric Loading

Positioning a load at different locations on the load receptor must not cause unacceptable measurement variation.

Sensitivity

The instrument must respond appropriately to sufficiently small changes in load.

Durability

Metrological characteristics should remain sufficiently stable throughout normal use.

Influence Quantities

Temperature, power supply and other relevant influences must not cause unacceptable measurement errors.

Protection

Components affecting metrological performance require appropriate protection against unauthorised adjustment or manipulation.

Indication

Weighing results must be accurate, unambiguous, non-misleading and easy to read under normal conditions of use.

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06
METROLOGICAL PERFORMANCE

Accuracy, Repeatability & Eccentric Loading

The core of NAWI conformity is demonstrating that the instrument produces sufficiently reliable weighing results throughout its intended weighing range and operating conditions.

Maximum Permissible Error

The difference between the indicated result and the conventional true value must remain within the limits applicable to the instrument and load range.

Repeatability

Multiple weighings of the same load under substantially identical conditions should produce results within the permitted variation.

Eccentric Loading

The indicated result should remain within the applicable limits when the same load is positioned at different relevant locations on the load receptor.

Sensitivity & Discrimination

The instrument should respond appropriately when the load changes by a relevant amount.

Capacity alone does not define a weighing instrument. Maximum capacity, minimum capacity, verification scale interval, accuracy class and number of verification scale intervals work together to define important metrological characteristics.
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07
WEIGHING FUNCTIONS

Zeroing, Tare, Displays & Printed Results

Functions that appear routine to the user can have a direct effect on the legally relevant weighing result and therefore form part of the conformity assessment.

Zeroing

Zeroing devices must provide accurate zero setting without producing incorrect measurement results.

Tare

Tare and preset-tare functions must permit correct determination of the relevant net weighing value.

Display

Indicated weighing results must be accurate, unambiguous, non-misleading and readable during normal use.

Printing

Printed weighing results must be correct, suitably identified, clear, legible and sufficiently durable.

Direct-sale instruments have additional consumer-facing requirements. Where an instrument determines price for direct sales to the public, essential information concerning the weighing operation and, where applicable, the price calculation must be clearly available to the customer.
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08
OPERATING CONDITIONS

Environmental & Electromagnetic Performance

A weighing instrument must maintain its required metrological characteristics under the operating conditions for which it is intended.

Temperature

Temperature changes must not cause weighing errors beyond applicable limits.

Power Supply

Relevant voltage and power-supply variations must not result in unacceptable weighing behaviour.

Electromagnetic Fields

Electronic instruments must maintain acceptable performance when subjected to applicable electromagnetic disturbances.

Electrostatic Effects

Electrostatic disturbances should not produce misleading or uncontrolled weighing results.

Mechanical Conditions

Installation, levelling, vibration and other physical influences should be addressed where relevant.

Connected Equipment

External equipment connected through an appropriate interface must not adversely affect the instrument’s metrological qualities.

A weighing instrument must remain a compliant measuring system after peripherals are connected. Printers, point-of-sale systems, computers, remote displays and other connected equipment should not compromise legally relevant weighing functions or measurement integrity.
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09
TECHNICAL SPECIFICATIONS

EN 45501 & Harmonised Standards

Harmonised standards provide manufacturers with an important technical route for demonstrating conformity with requirements covered by those standards.

EN 45501:2015, Metrological aspects of non-automatic weighing instruments, is the principal harmonised European standard associated with Directive 2014/31/EU.

Metrological Requirements

EN 45501 addresses technical and metrological characteristics relevant to non-automatic weighing instruments.

Performance Testing

The standard provides structured methods for evaluating weighing accuracy and relevant influence factors.

Technical Design

Its provisions support evaluation of instrument construction, indicating devices and other metrologically relevant functions.

Presumption of Conformity

Correct application of a harmonised standard whose reference has been published can provide presumption of conformity for the essential requirements it covers.

Always verify the current Official Journal reference. Standards can be amended, superseded or have their presumption-of- conformity status changed. The applicable reference should therefore be checked when the conformity assessment is performed.
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10
MARKET ACCESS ROUTE

NAWI Conformity Assessment

Instruments intended for the regulated applications must undergo an appropriate conformity assessment procedure before the required conformity markings can be applied.

Conformity Route Purpose Typical Third-Party Role
Module B + Module D EU-type examination followed by conformity to type based on quality assurance of the production process. Type assessment plus quality-system assessment and surveillance.
Module B + Module F EU-type examination followed by conformity to type based on product verification. Type assessment plus verification of production instruments.
Module G Conformity based on unit verification. Assessment and verification of the individual instrument.
EU-type examination is not required in every permitted case. For instruments that do not use electronic devices and whose load-measuring device does not use a spring to balance the load, the Directive permits the relevant conformity procedures to be followed without Module B where the applicable conditions are met.

The manufacturer should establish the conformity route during product-development planning so that design evidence, testing, production controls and Notified Body activities are aligned from the beginning.

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11
COMPLIANCE EVIDENCE

Technical Documentation

Technical documentation should enable the conformity of the instrument with the applicable requirements to be assessed and should provide an adequate analysis of the relevant requirements and risks.

01
Instrument description. Identify the instrument, model, variants, intended use and weighing applications.
02
Design information. Include relevant conceptual design, manufacturing drawings, schematics and component information.
03
Operating principles. Explain the weighing principle and the operation of metrologically significant functions.
04
Accuracy classification. Document accuracy class, capacities, verification scale interval and other relevant metrological characteristics.
05
Applicable requirements. Map the relevant essential requirements to conformity evidence.
06
Standards. Identify applicable harmonised standards and other technical specifications used.
07
Test reports. Maintain evidence covering weighing and relevant environmental performance.
08
Software information. Document software affecting legally relevant measurement functions where applicable.
09
Markings and inscriptions. Maintain examples of labels, data plates and legally required instrument markings.
10
Certificates and declaration. Maintain applicable conformity certificates and the EU Declaration of Conformity.
The technical documentation should describe the same instrument that is manufactured. Changes to load cells, indicators, software, analogue-to-digital conversion, weighing algorithms or other metrologically significant components should be assessed for their effect on approved conformity.
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12
PRODUCT IDENTIFICATION

CE Marking, Metrology Marking & Instrument Inscriptions

Instruments used for the regulated applications carry the CE marking together with the supplementary metrology marking after conformity has been established.

CE Marking

The CE marking indicates conformity with applicable EU harmonisation legislation requiring that marking.

Supplementary Metrology Marking

The supplementary metrology marking consists of the capital letter “M” and the last two digits of the year in which the marking was affixed, surrounded by a rectangle.

Notified Body Number

The identification number of the Notified Body follows the CE and supplementary metrology markings where required by the applicable conformity assessment procedure.

Metrological Inscriptions

Instruments must carry applicable information such as accuracy class, maximum capacity, minimum capacity and verification scale interval.

Do not confuse the supplementary metrology marking with the restrictive-use symbol. Instruments not intended for the regulated applications identified in Article 1(2)(a)–(f) follow different marking provisions under the Directive and must not be presented as though they have undergone the conformity assessment applicable to regulated use.
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13
SUPPLY-CHAIN RESPONSIBILITY

Manufacturers, Importers & Distributors

Directive 2014/31/EU places obligations not only on manufacturers but also on other economic operators involved in making instruments available on the European market.

Manufacturer

Ensures that the instrument is designed and manufactured in accordance with applicable requirements and completes the required conformity assessment.

Authorised Representative

May perform specified regulatory tasks on behalf of the manufacturer under a written mandate.

Importer

Must verify specified conformity elements before placing an instrument manufactured outside the Union on the EU market.

Distributor

Must act with due care and verify applicable marking, documentation and traceability requirements before making the instrument available.

Traceability

Economic operators must maintain appropriate information identifying relevant parties in the supply chain.

Corrective Action

Where an instrument is non-compliant or presents a risk, appropriate corrective measures and cooperation with authorities may be required.

Rebranding or modifying an instrument can change regulatory responsibility. An importer or distributor that markets an instrument under its own name or trade mark, or modifies it in a way that may affect conformity, can assume manufacturer obligations under the Directive.
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14
COMPLIANCE ROADMAP

From Weighing Instrument Design to EU Market Access

NAWI conformity is most efficient when legal-metrology requirements are incorporated into product development before the instrument reaches final design.

01

Define Use

Establish the instrument’s intended weighing application.

02

Confirm NAWI

Determine whether operator intervention makes the instrument non-automatic.

03

Determine Application

Establish whether the intended use is one of the regulated applications.

04

Define Class

Establish accuracy class and metrological characteristics.

05

Map Requirements

Identify the applicable Annex I essential requirements.

06

Select Standards

Identify appropriate harmonised standards and technical specifications.

07

Verify Performance

Complete weighing, environmental and other required evaluations.

08

Build Documentation

Compile technical evidence supporting the instrument’s conformity.

09

Notified Body

Complete the applicable independent conformity assessment.

10

Declare

Prepare and sign the EU Declaration of Conformity.

11

Mark

Apply the required CE, metrology and instrument markings.

12

Maintain Conformity

Ensure production instruments remain consistent with the assessed design.

Conformity must survive production. A successfully evaluated prototype does not by itself establish continuing conformity. Production instruments must remain consistent with the approved design, metrological characteristics and applicable quality controls.
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From Weighing Capability to Demonstrable Legal-Metrology Conformity

A weighing instrument can display a stable and apparently accurate result without necessarily satisfying the requirements for regulated use in the European Union. NAWI conformity requires the manufacturer to demonstrate that the instrument’s metrological performance, functions, construction and markings satisfy the applicable legal requirements.

The process begins by establishing whether the weighing instrument is non-automatic and determining its intended application. That decision determines whether the essential requirements for regulated use apply.

Where they do, accuracy classification, verification scale intervals, weighing performance, environmental behaviour, software, zero and tare functions, displays, interfaces and protection against manipulation can all become relevant parts of the conformity assessment.

Technical documentation, conformity assessment and production controls should then establish a clear link between the instrument evaluated for conformity and the instrument subsequently manufactured and supplied to users.

The Measurement Question

Does the instrument provide sufficiently accurate, repeatable and reliable weighing results throughout its intended operating range and conditions?

The Regulatory Question

Can the manufacturer demonstrate that the instrument placed on the market corresponds with the metrological design, technical documentation and conformity assessment on which its CE and supplementary metrology markings are based?

The defining NAWI compliance question is: when the weighing result has a legal, commercial, medical or consumer consequence, can the manufacturer demonstrate that the result can be relied upon within the accuracy and operating conditions for which the instrument has been approved?
Technical note: Directive 2014/31/EU establishes requirements for non-automatic weighing instruments and distinguishes instruments intended for the applications specified in Article 1(2)(a)–(f) from instruments intended for other uses. Product-specific conformity requirements depend on intended application, instrument design, accuracy class, metrological characteristics and conformity assessment route. Manufacturers should verify the current legal text, harmonised standards, Notified Body scope, applicable national legal-metrology requirements and any requirements governing putting the instrument into use before conducting a product-specific conformity assessment. This article provides general technical information and does not replace an instrument-specific legal-metrology or conformity assessment.

GLOBAL ALLIANCE REGISTER

How Global Alliance Register Can Support You

Global Alliance Register supports manufacturers, suppliers and responsible economic operators with independent technical-assurance services relevant to harmonised european standards. Based on the article's emphasis on regulatory review, conformity assessment and requirements mapping, GAR can coordinate competent specialists, laboratories, inspectors, auditors and accredited conformity-assessment resources as appropriate to the actual technical need. Within the context of this article, Global Alliance Register can support you in the following areas:

01

Review test records, inspection evidence, calculations, reports and other technical documentation relating to harmonised european standards for completeness, consistency and traceability.

02

Review the applicable regulatory, technical and scope requirements for harmonised european standards and define the responsibilities, classifications and assurance pathway relevant to the product or equipment.

03

Determine the applicable conformity-assessment route for harmonised european standards, coordinate the required technical evidence and support independent third-party or Notified Body involvement where the governing framework requires it.

04

Map the applicable standards, specifications, acceptance criteria and technical requirements for harmonised european standards to the evidence needed to demonstrate compliance, quality or performance.

05

Identify the changes affecting harmonised european standards, perform a structured impact assessment and develop a transition plan covering responsibilities, timing, documentation and implementation evidence.

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