Consider a product that consists of a mains powered limited power transformer with an SELV secondary connected via a 2 meter cable to a table top mounted device that contains an electronically controlled dc motor. There are moving parts from which the operator must be protected. The device is activated by the operator when required, otherwise it sits idle with no moving parts. The product as sold consists of the transformer, cable and table mounted unit.
Since there are moving parts, this product is obviously a machine. It must be determined if the product is subject to the Low Voltage Directive. Failing that, it must be subject to the Machinery Directive. One can argue that the product is mains powered and therefore subject to the Low Voltage Directive. It can also be argued that the transformer is subject to the Low Voltage Directive, but the table top unit with the moving parts is powered by a voltage level that is outside the scope of the Low Voltage Directive and is therefore subject to the Machinery Directive. Which argument is correct? Your thoughts would be appreciated. Richard Woods Sensormatic Electronics
