Glen Moffat wrote: 

<<<<<<Technically, the machinery Directive does apply since it meets the
definition of a machine, assuming that it is not excluded by article 1(5),
that is a risk assessment shows that the risks are not mainly of electrical
origin.  However in the UK, I do remember a DTI document which was issued
soon after the MD was released that said that products which have
traditionally fallen within the scope of the LVD in the past may continue
to do so.  I don't know if this advice has been superceded or forgotten or
whether it still applies since domestic electrical appliances within the
scope of EN 60335 have traditionally been in the scope of the LVD.<<<<

This is the way I understand the majority of appliance manufacturers are 
interpreting the requirement.  Household appliances falling under the scope 
of EN 60335 are considered LVD, even though many of them use moving parts 
that would seem to put them within the scope of the machinery directive.  If 
you're concerned about the unlikely case where this decision might be 
challenged, you can always prepare a risk assessment using the 335 report as 
its basis, and follow the more stringent marking/documentation requirements 
of the Machinery Directive.



Greg Galluccio
www.productapprovals.com


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