Machinery Directive 2006/42/EC, Article 1 (b) interchangeable equipment

As usual, I opened the RAPEX Weekly Report that delivers to my inbox every Friday morning.

Scrolling through, I reviewed three cases involving saw blades. These are interesting because they were stopped for violating the Machinery Directive 2006/42/EC. Normally when we consider the Machinery Directive, we think of products that have linked parts under other-than-human (meaning electric, pneumatic, or hydraulic) power.

Below are the three saw blades that were stopped:

Model 61H199 – Link.

Model 61h197 – Link.

Model 61H196 – Link.

All three were found to violate the Machinery Directive 2006/42/EC and fail to comply with these harmonized Machinery Directive EN standards:

(Side note: F2 published an article about how to read/understand the above chart, here).

Although these saw blades are not ‘machines’ in the classic sense, they were stopped because they were classified as ‘interchangeable equipment’, which puts them in the scope, fully, of the Machinery Directive 2006/42/EC.

See the scope of the Machinery Directive in Article 1 – in particular, item (b):

Next, see the definition of ‘interchangeable equipment’ in Article 2 (b) of the Machinery Directive 2006/42/EC

However, the European Commission also published the Guide to application of the Machinery Directive 2006/42/EC, Edition 2.1, in 2017 (read it here). This document clearly explains every line of the Machinery Directive in plain text so that a layman can understand. We refer to it constantly at F2 Labs in order to help our customers. Section 41 is dedicated to interchangeable equipment. Paragraph 7 of Section 41 states:

So, we see that saw blades are not considered interchangeable equipment. The authorities noted, however, that there is a picture of an angle grinder on the packaging, included below.

Model 61H199

Model 61h197

Model 61H196

So, the equipment is no longer excluded since it attributes a new function (chainsaw) to a different machine (angle grinder).

Even worse, this equipment is now in Annex IV of the Machinery Directive (included below).

And then see Paragraph 11 from Section 41 of the previously referenced guidelines:

Note this in particular, excerpted from the above:

“It should be noted that the assembly of interchangeable equipment with basic machinery may have the effect of creating a combination that belongs to one of the categories of machinery listed in Annex IV.”

OUTCOME: The use of the indicated blades therefore change an angle grinder into a chainsaw. Chainsaws are listed in Annex IV of the Machinery Directive. The above means that this manufacturer must not only conform with the Machinery Directive, but also follow a more stringent compliance process and probably involve a Notified Body.

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