If this advice was followed, then the casual user of an appliance will have no idea from the label whether an appliance has passed it's test by date or is still within it. In every instance, they are going to have to chase after the duty holder and look at the test records to find out.
The benefit of having a label is that anyone in the workplace can quickly identify appliances that have been maintained and are still within the test date. Our advise is to label everything electrical in the workplace even new appliances. In this way it is easy to advise staff that if they spot any electrical items without a label, then they just need to let the duty holder know.
For example, if a member of staff brings in a set of christmas tree lights, and these do not have a label, the duty holder is informed and he or she can carry out an inspection (and test if required) and attach a label before the lights are used.
Whenever a new appliance is brough into the workplace, it is good practice to label it and make sure it has a re-test date on it, even though this might be in a year, 2 years or 4 years time as determined by the duty holder.
In summary, the new advice in the IET Code of Practice is inpractical and is bound to cause confusion in the workplace. It is quite simple to overcome the problem of too frequent testing. If an appliance only needs maintaining every 2 years then it is a simple matter to put the "re-testing date" to 2 years ahead.