This seems to come up every time we have a discussion about the Machinery
Directive on this mailing list. Let me say this one more time: the scope of the
CE marking directives is defined only by the wording of the directives, not by
the wording of any standards. There are no products where the mere existence of
a standard moves the product in or out of the scope of the Machinery Directive.
None. At. All.
There are SOME products to which the Machinery Directive does not apply even
though they meet the basic definition of a machine ("an assembly of linked
parts, at least one of which moves…”). Among these, article 1(k) of the
Machinery Directive contains a list of six categories of product which will be
excluded from the scope of the Machinery Directive if they are within the scope
of the LVD.
One of the six categories is "household appliances intended for domestic use”.
The generic standard for such equipment is EN 60335 “Household and similar
electrical appliances. Safety”. Part 1 of EN 60335 contains an annex where the
members of the CENELEC committee responsible for the standard have listed the
part 2’s (“particular requirements”) of the standard and helpfully provided
their opinion as to whether or not the type of equipment generally covered by
the part 2 meets the definition of a "household appliances intended for
domestic use” and hence whether or not the exclusion from the Machinery
Directive can be applied.
Manufacturers can use the Annex as a pretty reliable guide to whether their
product is covered by the LVD or by the Machinery Directive. However, the annex
is only a guide. It has no legal force whatsoever, and it is still the
responsibility of the manufacturer of the product to decide which Directive
they should apply.
Many manufacturers make products which are covered by EN 60335 but are not
''intended for domestic use" and hence even though the Annex may tell them that
the product is covered by the LVD, in fact this is incorrect since the
exclusion defined in the Machinery Directive does not apply to them. (There is,
incidentally, a definition of ‘domestic use’ in the Machinery Guide published
by the Commission.)
With regard to the x-ray sub system which originally started this thread, it
fits none of the categories of exclusion defined in Article 1(k) and so if it
has powered moving parts it is covered by the Machinery Directive. In fact, it
sounds like it is ‘partly completed machinery’ and hence requires a Declaration
of Incorporation rather than a Declaration of Conformity, but that’s probably
better left as a topic for another day.
Nick.
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