Machinery Directive or the Low Voltage Directive… which one?

The Machinery Directive and the Low Voltage Directive: how do I know which one?

The Machinery Directive 2006/42/EC and the Low Voltage Directive 2014/35/EU can both be applied to certain machines or equipment. The Machinery Directive excludes the Low Voltage Directive when it is applicable, but requires compliance with Annex I of the Low Voltage Directive. Confused? Lots of people are. Let’s take a closer look…

Below is Article 1 of the Machinery Directive.

MD.Article.1

The Low Voltage Directive 2014/35/EU applies to the following equipment:

LVD.Article1

Of course, there is broad room for overlap between these two Directives because most machinery operates at voltages within the scope of the Low Voltage Directive. The Machinery Directive addresses this specifically in Annex I, Essential Health and Safety Requirements (1.5.1.).

2006/42/EC, Annex I (1.5.1.) Electricity Supply:

MD.AnnexI.1.5.1

Regarding section 1.5.1. from the Machinery Directive, we note that 73/23/EEC refers to the Low Voltage Directive 73/23/EEC, before it was the Low Voltage Directive 2006/95/EC and before that became the current Low Voltage Directive 2014/35/EU. By law, 1.5.1. refers to the currently applicable Low Voltage Directive.

1.5.1. is saying that your equipment must comply with the technical (i.e., safety) requirements from Annex I of the Low Voltage Directive but in the same section it is telling you that your equipment is excluded from the Low Voltage Directive… the documentation and legal requirements: because the Machinery Directive is applicable.

Huh?

In plain English: The Machinery Directive is fully applicable and you will indicate it on the declaration of conformity. The Machinery Directive has also “rolled in” the safety requirements of the Low Voltage Directive (2006/42/EC, Annex I, 1.5.1.) while at the same time excluding the Low Voltage Directive – so you will not include any reference to the Low Voltage Directive on the declaration of conformity. In fact, it is incorrect to list the Machinery Directive AND the Low Voltage Directive on your declarations of conformity.

We are not finished with addressing this issue. Our next post will focus on the Machinery Directive 2006/42/EC, Article 1 (2) (k) Low Voltage Directive exclusions. These exclusions are for products which technically meet the 2006/42/EC, Article 1 (1) scope requirements for inclusion in the Machinery Directive but can claim compliance to the Low Voltage Directive instead.

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