I am proposing using the harmonized standards as guidance, not as an absolute determination. Article 1, Clause 2(k) gives specific exemptions including "household appliances intended for domestic use". How can you be sure your product is a household appliance reasonably covered by the LVD? If there is a harmonized standard under the LVD, then you at least have a good argument to make for declaring under the LVD. Without the narrow scope of the standard, you are left to argue the overly broad scope of the LVD versus the overly broad scope of the Machinery Directive.
I would also state that your simplest terms are a little too simple. There are plenty of electrical children's toys that could fit within your description. Lego Technic provides motors, transmissions, gears and other parts for a child to make something quite resembling a machine. The Machinery Directive does not exclude toys, but I have yet to see any of these toys declared under anything but the Toy Directive. The Machinery Directive does not exclude medical equipment, yet those products often have complex moving assemblies. However, let me state that I am far from an expert in the Machinery Directive and I encourage all with contrary opinions to respond to set me straight. I am just another person trying to deal with the broad scopes and limited guidance available. Ted Eckert Compliance Engineer Microsoft Corporation [email protected]<mailto:[email protected]> The opinions expressed are my own and do not necessarily reflect those of my employer. From: Nick Williams [mailto:[email protected]] Sent: Monday, April 30, 2012 9:21 AM To: Ted Eckert Cc: [email protected] Subject: Re: Machinery Directive silly question? I've said this before. The status of standard DOES NOT determine whether product is within the scope of a particular Directive or not. To put it in its simplest terms, if a product has powered moving parts then, irrespective of the status or otherwise of any standards, it is within the scope of the Machinery Directive unless it is excluded by one of the clauses in Article 1. That's all there is to it. Nick. On 30 Apr 2012, at 17:00, Ted Eckert wrote: The first question I would ask is whether there is a product specific standard that covers your product. If so, then determine if that product specific standard is a harmonized standard under one of the other directives. In that case, the machinery directive would not apply. For example, an air conditioner has plenty of moving parts. However, a small portable air conditioner intended to be installed and used by general users is covered by EN 60335-2-40, which is a harmonized standard under the Low Voltage Directive. This air conditioner would not fall under the Machinery Directive. On the other hand, a large commercial air conditioner designed to be installed on the roof of a building is not within the scope of EN 60335-2-40. There are general standards covering the mechanical safety and the safety of the pressurized system, but not an overarching product standard for this type of product. As such, it falls under the Machinery Directive. You may need to do some research to see if your product is within the scope of a product specific standard. However, if it is and if that standard is a harmonized standard under the Low Voltage Directive, the LVD would likely apply. These standards are designed to cover potential mechanical hazards specific to certain product types, but they are recognized as covering product where electrical hazards predominate. This is not just the case for the LVD. There are medical products with moving parts and toys with moving parts and those are each covered under their own directives. If your product has a radio, and it is covered by a standard harmonized under the R&TTE Directive, that Directive may be the one that applies. Ted Eckert Compliance Engineer Microsoft Corporation [email protected]<mailto:[email protected]> The opinions expressed are my own and do not necessarily reflect those of my employer. -----Original Message----- From: Mark Hone [mailto:[email protected]]<mailto:[mailto:[email protected]]> Sent: 30 April 2012 14:12 To: [email protected]<mailto:[email protected]> Subject: [PSES] Machinery Directive silly question? Dear Colleagues, I know that you are all patient with what might seem silly questions, so I hope you'll be patient with mine. I have not had to consider the Machinery Directive before, but a new electrical product has a moving part in it. It's a wholly enclosed (inaccessible in the middle of the equipment) fan that blows air through the equipment (not a cooling fan). The MD defines machinery: " an assembly, fitted with or intended to be fitted with a drive system... consisting of... components, at least one of which moves, and which are joined together for a specific application". So the silly question is, if the moving part is wholly contained within the equipment and is inaccessible, does the MD apply or do I apply the LVD? I have Googled this question and have found references that say the MD does apply (it's the enclosure that makes the moving part safe), and references that say the MD does not apply (as the moving part is wholly internal, one doesn't need to even consider it). I strongly suspect the former statement is the correct one. Your authoritative opinions are sought! With thanks in anticipation, Mark -- Mark Hone HESS Manager Wellman Defence Limited Dolphin House Williams Road Portsmouth Hampshire PO3 5FP T: +44 (0)23 9262 9239 F: +44 (0)23 9269 7864 E: [email protected]<mailto:[email protected]> W: www.wellmandefence.co.uk<http://www.wellmandefence.co.uk> ________________________________ Wellman Defence is a limited company registered in England and Wales. Company Registration No. 953609 Registered Offices: Wellman International Ltd., Newfield Road, Oldbury, West Midlands, B69 3ET, England. The contents and any attachments to this email include information that is private and confidential and should only be read by those persons to whom they are addressed. Wellman Defence Limited accepts no liability for any loss or damage suffered by any person arising from the use of this email. 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To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher: <[email protected]<mailto:[email protected]>> David Heald: <[email protected]<mailto:[email protected]>> Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: [email protected]<mailto:[email protected]> ----- Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk<http://www.conformance.co.uk> Registered in England, Company No. 3478646 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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