Guide to application of the Machinery Directive 2006/42/EC, Edition 2.1 – published in July 2017 and EN 61010-1 equipment

The Guide to application of the Machinery Directive 2006/42/EC, Edition 2.1, was published by the EC Commission in July. The link to the document is here. Be advised that is a direct download link.

The “guideline” is extremely useful and we refer to it often. We have read through the changes and want to highlight what we consider to be pretty significant: the addition of the Low Voltage Directive 2014/35/EU to the Article 3 exclusion in the Machinery Directive 2006/42/EC.

2006/42/EC, Article 3 is below.

Article 3 is interesting because it offers the ability to exclude the Machinery Directive 2006/42/EC if all of the safety risks can be covered in a different Directive: for instance, the Medical Device Directive 93/42/EEC. It has always been a gray area to exclude certain products from the Machinery Directive in favor of the Low Voltage Directive if those products did not meet the criteria established in 2006/42/EC, Article 1 (2) (k).

2006/42/EC, Article 1 (2) (k) is below.

This has caused some confusion because of the inclusion of a main electrical safety standard on the list of harmonized standards for the Low Voltage Directive 2014/35/EU and not the Machinery Directive 2006/42/EC list. That standard is EN 61010-1.

See EN 61010-1 as it is displayed on the EC Commission’s page for the LVD, linked here.

EN 61010-1 is a very thorough and comprehensive safety standard, covering most (0r all) risks presented by a lot of types of machines, but in some cases it could not be applied if the equipment did not meet the exclusion requirements indicated in Article 1 (2) (k).

That brings us to the important change in the guidelines. The previously referenced guideline document is a thorough publication which clearly explains nearly everything required by the Machinery Directive. Since it is published by the EC Commission the text in the document is seen as the official word.

Section 90 of the guidelines indicates the EU Directives that are available for consideration instead of the Machinery Directive, per Article 3.

The EU Directives listed in section 90 of Edition 2.0 are listed below.

  • Toys Directive 2009/48/EC
  • Personal Protective Equipment Directive 89/686/EEC
  • Medical Devices Directive 93/42/EEC
  • Lifts Directive 95/16/EC
  • Cableways Directive 2009/9/EC

And now, in Edition 2.1, the list in section 90 has been revised as indicated below.

  • Low Voltage Directive 2014/35/EU
  • Toys Directive 2009/48/EC
  • Personal Protective Equipment Directive 89/686/EEC
  • Medical Devices Directive 93/42/EEC
  • Lifts Directive 2014/33/EU
  • Cableways Directive 2009/9/EC
  • Regulation (EU) No 167/2013 (this is a new regulation, dealing with agricultural and forestry tractors separately from the Machinery Directive)

This addition of the Low Voltage Directive 2014/35/EU to the list in section 90 of the Edition 2.1 Guideline to application of the Machinery Directive 2006/42/EC makes it clear that the Machinery Working Group considers that some particular equipment can legally satisfy CE marking requirements through the Low Voltage Directive instead of the Machinery Directive. Laboratory and testing equipment with moving parts, within the scope of EN 61010-1, are the best example.

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