A lot of our efforts at F2 labs are spent determining the applicability of different regulations to our customers’ products. We help you find out what is applicable and then we suggest the best, fastest, and most cost-effective way to claim compliance. This is a real-life example of how we do it.
WE WANT TO DETERMINE IF A JACK IS IN SCOPE –
The Machinery Directive 2006/42/EC applies to a broad range of categories, see Article 1 –
Next, see the definition of ‘machinery’ in Article 1., (a). That definition is in Article 2, (a) –
Let’s focus in on Article 2, (a), (5th indent) –
This means that equipment can be in scope of the Machinery Directive if it has moving parts under human power, but only if the function is lifting. So, think of it this way — a bicycle is not in scope, but a hand-cranked hoist for lifting livestock is in scope.
It is always helpful to refer to the Guide to application of the Machinery Directive 2006/42/EC, Edition 2.2. Let’s read section 40, which explains the definition of the equipment indicated in Article 2, (a), (5th indent) –
WHAT ABOUT THIS ONE?
The European Commission sends out a list, every Friday, to show some of the products that have either been stopped in customs or pulled from the market. There are many more products that are pulled, but these are the products categorized as extremely dangerous. I look at this report every week and I look at every mechanical and/or electronic device. I was very interested to read the details of Alert number A12/00729/22 from today.
This is a standard automobile jack that many of us have used. Notice that the alert references EN 1494. That link goes to the Estonian source for EN standards. This organization is highly recommended if you are looking to purchase EN standards. They are always in English and usually for the lowest cost. Yes, you can use EVS-EN 1494 to evaluate a jack for CE conformity to the Machinery Directive for all of the EU – not just for Estonia.
See the scope of EN 1494 below –
Further down in the EN 1494 scope section we see this –
Hmmm. I don’t know about you, but this jack looks exactly like the jack delivered with every vehicle I have owned. This means that if the jack is purpose built for a car manufacturer to deliver with their cars then it does not apply. But, that does not necessarily mean that the Machinery Directive is not applicable. It just means that you cannot use EN 1494 to show conformity with (compliance) to the Machinery Directive.
I would be willing to bet that jacks delivered with new vehicles are under a different regulation. That will not be investigated for this article. Confused? Here is another consideration – if Honda or BMW began buying these jacks for their new cars then those jacks would be excluded from EN 1494, but the very same jacks packaged and re-branded on a shelf in an auto-parts store would be in scope.
This jack manufacturer should have a Technical File that includes an evaluation to EN 1494 since this particular model is in a box and on a shelf, presumably. Also, the only CE marking Directive for this device is the Machinery Directive. RoHS is excluded because there is no electric function. The EU REACH requirement is also applicable, but it is not a CE marking Directive.
IF I HAD TO GUESS – THIS IS WHAT HAPPENED HERE…
Why did this product get flagged? Why are we seeing this alert? If I had to guess (and this is all it is, a guess based on years and years of experience): the jack failed and either property or a person was hurt. The authorities became involved and made a request of the Technical File. Then, (likely) it was discovered that the product was not compliant and there was/is no technical report to show compliance to the Machinery Directive 2006/42/EC, including no report to the applicable harmonized EN standard, EN 1494.
WE CAN HELP YOU TO DETERMINE THE SCOPE OF YOUR PRODUCTS
This is what we do. We can work through the use, application, and construction of your equipment to determine the appropriate compliance path.
Want to discuss your project with us?
We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.
F2 Labs is here to help.