From time to time we are presented with a device that seemingly “fits” into the Low Voltage Directive 2014/35/EU because it only has electric function and no moving components. This would lead most to apply the Low Voltage Directive instead of the Machinery Directive 2006/42/EC in order to satisfy requirements.
That approach can be incorrect.
See the Machinery Directive 2006/42/EC, Article 1 (1.):
Article 1, Scope
- This Directive applies to the following products:
(b) interchangeable equipment;
(c) safety components;
(d) lifting accessories;
(e) chains, ropes and webbing;
(f) removable mechanical transmission devices;
(g) partly completed machinery.
Next, see the definition of “safety component” indicated in Article 2 (c):
(c) ‘safety component’ means a component:
— which serves to fulfil a safety function,
— which is independently placed on the market,
— the failure and/or malfunction of which endangers the safety of persons, and
— which is not necessary in order for the machinery to function, or for which normal components may be substituted in order for the machinery to function. An indicative list of safety components is set out in
Annex V, which may be updated in accordance with Article 8(1)(a);
Now, we look at Annex V, in particular (4.), (8.), and (10.):
ANNEX V, Indicative list of the safety components referred to in Article 2(c)
- Guards for removable mechanical transmission devices.
- Protective devices designed to detect the presence of persons.
- Power-operated interlocking movable guards designed to be used as safeguards in machinery referred to in items 9, 10 and 11 of Annex IV.
- Logic units to ensure safety functions.
- Valves with additional means for failure detection intended for the control of dangerous movements on machinery.
- Extraction systems for machinery emissions.
- Guards and protective devices designed to protect persons against moving parts involved in the process on the machinery.
- Monitoring devices for loading and movement control in lifting machinery.
- Restraint systems to keep persons on their seats.
- Emergency stop devices.
- Discharging systems to prevent the build-up of potentially dangerous electrostatic charges.
- Energy limiters and relief devices referred to in sections 1.5.7, 3.4.7 and 220.127.116.11 of Annex I.
- Systems and devices to reduce the emission of noise and vibrations.
- Roll-over protective structures (ROPS).
- Falling-object protective structures (FOPS).
- Two-hand control devices.
- Components for machinery designed for lifting and/or lowering persons between different landings and included in the following list:
(a) devices for locking landing doors;
(b) devices to prevent the load-carrying unit from falling or unchecked upwards movement;
(c) overspeed limitation devices;
(d) energy-accumulating shock absorbers,
— non-linear, or
— with damping of the return movement;
(e) energy-dissipating shock absorbers;
(f) safety devices fitted to jacks of hydraulic power circuits where these are used as devices to prevent falls;
(g) electric safety devices in the form of safety switches containing electronic components.
The purpose of this article is to show that even though a device may look like an electrical product, in the scope of the Low Voltage Directive 2014/35/EU and matching the scope of EN 61010-1:2010, it may not be legally correct to use either to show safety compliance for CE marking.
The Machinery Directive 2006/42/EC will be applicable instead of the Low Voltage Directive 2014/30/EU, even with no moving parts, if the application or description matches the above. And in that case you will not be able to apply EN 61010-1:2010 as the applicable standard because EN 61010-1:2010 is harmonized to the Low Voltage Directive and not the Machinery Directive.
If you have a product like the above, or any question regarding applicability of CE marking requirements to your product: call us. We will sort it out.
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