Re: [PSES] EU Machinery Regulation official version

[Douglas Nix]

Hi Scott,

At this point, that’s my best guess. There is nothing to say that the UK will 
adopt the new MR, as there is nothing legally binding them to do so.

-- 
Doug Nix
d...@mac.com

"The problem with common sense is that it's not too common." - Mark Twain 




> On Jul 13, 2023, at 23:16, Scott Xe  wrote:
> 
> Dear Doug,
> 
> Thanks for your detailed explanation!  It seems the goods for the UK market 
> do not legally need to change to the new EU MR until an updated regulation 
> replacing the current one (old EU MD) is issued in the UK.
> 
> Best regards,
> 
> Scott
> 
> 
> On Fri, 14 Jul 2023 at 09:13, Doug Nix mailto:d...@ieee.org>> 
> wrote:
>> Hi Scott,
>> 
>> Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I 
>> don’t believe that the UK is quite sure where things will go.
>> 
>> Since the UK is no longer a member of the EU, none of the law relating to 
>> the Machinery Regulation (MR) applies. For EU Members, the MR does not need 
>> to be transposed into national law like the directives did. It simply comes 
>> into force, and the members are expected to enforce it as written. But of 
>> for the UK? It’s anybody’s guess. They could stay with the MD since it’s 
>> already transposed into the The Supply of Machinery (Safety) Regulations 
>> 2008, UK SI 2008 No. 1597. They could modify UK SI 2008 No. 1597. They could 
>> lift the entire MR and adopt it as a new UK regulation.
>> 
>> We’ll have to wait and see. As we get closer to the mandatory date they 
>> should start to tell people what they have in mind.
>> 
>> My concern is that the new MR is considerably modernized, including clauses 
>> on AI and cybersecurity, and the former MD Annex IV list is gone, replaced 
>> with a more rational means of identifying dangerous machinery. If the UK 
>> stays with UK SI 2008 No. 1597, then they will be sliding backward compared 
>> to their closest neighbours. On the other hand, if they get a grip and 
>> decide to rejoin the EU as they likely should, then the new MR will come 
>> into force on the day they join.
>> 
>> We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.
>> 
>> Best, 
>> Doug Nix
>> d...@ieee.org <mailto:d...@ieee.org>
>> +1 (519) 729-5704
>> 
>>> On Jul 13, 2023, at 21:04, Scott Xe >> <mailto:scott...@gmail.com>> wrote:
>>> 
>>> 
>>>> Dear Doug,
>>>> 
>>>> Regarding the UK implementation part in your article, can you elaborate 
>>>> the details of the UK implementation after the end of the transition date 
>>>> of 31/12/2024?
>>>> 
>>>> Thanks and regards,
>>>> 
>>>> Scott
>>>> 
>>>> On Thu, 6 Jul 2023 at 00:59, >>> <mailto:scott...@gmail.com>> wrote:
>>>>> Thanks, Doug!
>>>>> 
>>>>>  
>>>>> 
>>>>> Scott
>>>>> 
>>>>>  
>>>>> 
>>>>> From: Doug Nix mailto:d...@ieee.org>> 
>>>>> Sent: Wednesday, July 5, 2023 2:24 AM
>>>>> To: Scott Xe mailto:scott...@gmail.com>>
>>>>> Subject: Re: [PSES] EU Machinery Regulation official version
>>>>> 
>>>>>  
>>>>> 
>>>>> Hi Scott,
>>>>> 
>>>>>  
>>>>> 
>>>>> If you are using the EM Machinery Regulation for CE Marking then, yes, of 
>>>>> course it does. See articles 23 and 24 of the regulation.
>>>>> 
>>>>>  
>>>>> 
>>>>> Doug Nix
>>>>> d...@ieee.org <mailto:d...@ieee.org>
>>>>> +1 (519) 729-5704
>>>>> 
>>>>> 
>>>>> 
>>>>> 
>>>>> On Jul 4, 2023, at 12:45, Scott Xe >>>> <mailto:scott...@gmail.com>> wrote:
>>>>> 
>>>>>  
>>>>> 
>>>>> Dear Doug,
>>>>> 
>>>>>  
>>>>> 
>>>>> Many thanks for your brief and useful information!  I wonder if this 
>>>>> regulation still requires a DoC.
>>>>> 
>>>>>  
>>>>> 
>>>>> Best regards,
>>>>> 
>>>>>  
>>>>> 
>>>>> Scott
>>>>> 
>>>>>  
>>>>> 
>>>>>  
>>>>> 
>> 
> -
> ---

Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

Dear Doug,

Thanks for your detailed explanation!  It seems the goods for the UK market
do not legally need to change to the new EU MR until an updated regulation
replacing the current one (old EU MD) is issued in the UK.

Best regards,

Scott


On Fri, 14 Jul 2023 at 09:13, Doug Nix  wrote:

> Hi Scott,
>
> Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I
> don’t believe that the UK is quite sure where things will go.
>
> Since the UK is no longer a member of the EU, none of the law relating to
> the Machinery Regulation (MR) applies. For EU Members, the MR does not need
> to be transposed into national law like the directives did. It simply comes
> into force, and the members are expected to enforce it as written. But of
> for the UK? It’s anybody’s guess. They could stay with the MD since it’s
> already transposed into the The Supply of Machinery (Safety) Regulations
> 2008, UK SI 2008 No. 1597. They could modify UK SI 2008 No. 1597. They
> could lift the entire MR and adopt it as a new UK regulation.
>
> We’ll have to wait and see. As we get closer to the mandatory date they
> should start to tell people what they have in mind.
>
> My concern is that the new MR is considerably modernized, including
> clauses on AI and cybersecurity, and the former MD Annex IV list is gone,
> replaced with a more rational means of identifying dangerous machinery. If
> the UK stays with UK SI 2008 No. 1597, then they will be sliding backward
> compared to their closest neighbours. On the other hand, if they get a grip
> and decide to rejoin the EU as they likely should, then the new MR will
> come into force on the day they join.
>
> We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.
>
> Best,
> Doug Nix
> d...@ieee.org
> +1 (519) 729-5704
>
> On Jul 13, 2023, at 21:04, Scott Xe  wrote:
>
>
> Dear Doug,
>>
>> Regarding the UK implementation part in your article, can you elaborate
>> the details of the UK implementation after the end of the transition date
>> of 31/12/2024?
>>
>> Thanks and regards,
>>
>> Scott
>>
>> On Thu, 6 Jul 2023 at 00:59,  wrote:
>>
>>> Thanks, Doug!
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>> *From:* Doug Nix 
>>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>>> *To:* Scott Xe 
>>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>>
>>>
>>>
>>> Hi Scott,
>>>
>>>
>>>
>>> If you are using the EM Machinery Regulation for CE Marking then, yes,
>>> of course it does. See articles 23 and 24 of the regulation.
>>>
>>>
>>>
>>> Doug Nix
>>> d...@ieee.org
>>> +1 (519) 729-5704
>>>
>>>
>>>
>>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>>
>>>
>>>
>>> Dear Doug,
>>>
>>>
>>>
>>> Many thanks for your brief and useful information!  I wonder if this
>>> regulation still requires a DoC.
>>>
>>>
>>>
>>> Best regards,
>>>
>>>
>>>
>>> Scott
>>>
>>>
>>>
>>>
>>>
>>
>

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Re: [PSES] EU Machinery Regulation official version

[Doug Nix]

Hi Scott,

Don’t I wish I could. At this point I’d need a well-tuned crystal ball. I don’t 
believe that the UK is quite sure where things will go.

Since the UK is no longer a member of the EU, none of the law relating to the 
Machinery Regulation (MR) applies. For EU Members, the MR does not need to be 
transposed into national law like the directives did. It simply comes into 
force, and the members are expected to enforce it as written. But of for the 
UK? It’s anybody’s guess. They could stay with the MD since it’s already 
transposed into the The Supply of Machinery (Safety) Regulations 2008, UK SI 
2008 No. 1597. They could modify UK SI 2008 No. 1597. They could lift the 
entire MR and adopt it as a new UK regulation.

We’ll have to wait and see. As we get closer to the mandatory date they should 
start to tell people what they have in mind.

My concern is that the new MR is considerably modernized, including clauses on 
AI and cybersecurity, and the former MD Annex IV list is gone, replaced with a 
more rational means of identifying dangerous machinery. If the UK stays with UK 
SI 2008 No. 1597, then they will be sliding backward compared to their closest 
neighbours. On the other hand, if they get a grip and decide to rejoin the EU 
as they likely should, then the new MR will come into force on the day they 
join.

We shall see. Get your popcorn ready. It’s gonna be a wild ride I think.

Best, 
Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On Jul 13, 2023, at 21:04, Scott Xe  wrote:
> 
> 
>> Dear Doug,
>> 
>> Regarding the UK implementation part in your article, can you elaborate the 
>> details of the UK implementation after the end of the transition date of 
>> 31/12/2024?
>> 
>> Thanks and regards,
>> 
>> Scott
>> 
>> On Thu, 6 Jul 2023 at 00:59, > <mailto:scott...@gmail.com>> wrote:
>>> Thanks, Doug!
>>> 
>>>  
>>> 
>>> Scott
>>> 
>>>  
>>> 
>>> From: Doug Nix mailto:d...@ieee.org>> 
>>> Sent: Wednesday, July 5, 2023 2:24 AM
>>> To: Scott Xe mailto:scott...@gmail.com>>
>>> Subject: Re: [PSES] EU Machinery Regulation official version
>>> 
>>>  
>>> 
>>> Hi Scott,
>>> 
>>>  
>>> 
>>> If you are using the EM Machinery Regulation for CE Marking then, yes, of 
>>> course it does. See articles 23 and 24 of the regulation.
>>> 
>>>  
>>> 
>>> Doug Nix
>>> d...@ieee.org <mailto:d...@ieee.org>
>>> +1 (519) 729-5704
>>> 
>>> 
>>> 
>>> 
>>> On Jul 4, 2023, at 12:45, Scott Xe >> <mailto:scott...@gmail.com>> wrote:
>>> 
>>>  
>>> 
>>> Dear Doug,
>>> 
>>>  
>>> 
>>> Many thanks for your brief and useful information!  I wonder if this 
>>> regulation still requires a DoC.
>>> 
>>>  
>>> 
>>> Best regards,
>>> 
>>>  
>>> 
>>> Scott
>>> 
>>>  
>>> 
>>>  
>>> 


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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

> Dear Doug,
>
> Regarding the UK implementation part in your article, can you elaborate
> the details of the UK implementation after the end of the transition date
> of 31/12/2024?
>
> Thanks and regards,
>
> Scott
>
> On Thu, 6 Jul 2023 at 00:59,  wrote:
>
>> Thanks, Doug!
>>
>>
>>
>> Scott
>>
>>
>>
>> *From:* Doug Nix 
>> *Sent:* Wednesday, July 5, 2023 2:24 AM
>> *To:* Scott Xe 
>> *Subject:* Re: [PSES] EU Machinery Regulation official version
>>
>>
>>
>> Hi Scott,
>>
>>
>>
>> If you are using the EM Machinery Regulation for CE Marking then, yes, of
>> course it does. See articles 23 and 24 of the regulation.
>>
>>
>>
>> Doug Nix
>> d...@ieee.org
>> +1 (519) 729-5704
>>
>>
>>
>> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
>>
>>
>>
>> Dear Doug,
>>
>>
>>
>> Many thanks for your brief and useful information!  I wonder if this
>> regulation still requires a DoC.
>>
>>
>>
>> Best regards,
>>
>>
>>
>> Scott
>>
>>
>>
>>
>>
>

-

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Re: [PSES] EU Machinery Regulation official version

[Doug Nix]

Yes. See articles 23 and 24.

Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On Jul 4, 2023, at 12:45, Scott Xe  wrote:
> 
> Dear Doug,
> 
> Many thanks for your brief and useful information!  I wonder if this 
> regulation still requires a DoC.
> 
> Best regards,
> 
> Scott
> 


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Re: [PSES] EU Machinery Regulation official version

[MIKE SHERMAN]

Still requires a DoC.
 
Mike Sherman
Sherman PSC LLC

> On 07/04/2023 11:45 AM CDT Scott Xe  wrote:
>  
>  
> Dear Doug,
>  
> Many thanks for your brief and useful information!  I wonder if this 
> regulation still requires a DoC.
>  
> Best regards,
>  
> Scott
>  
> -
> 
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> mailto:emc-p...@ieee.org>
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Re: [PSES] EU Machinery Regulation official version

[Scott Xe]

Dear Doug,

Many thanks for your brief and useful information!  I wonder if this
regulation still requires a DoC.

Best regards,

Scott

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Re: [PSES] EU Machinery Regulation official version

[Doug Nix]

Hi All,

I just published  short article that includes links to the official version of 
the regulation and to a guide published in English by ETUI and Eurogip. Hope 
it’s helpful for you. 
https://machinerysafety101.com/2023/07/03/the-new-eu-machinery-safety-regulation-is-coming-are-you-ready/

Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On Jul 1, 2023, at 05:30, Charlie Blackham  
> wrote:
> 
> Brian
> 
> If you’ve not come across it already, I recommend joining the LinkedIn group 
> “Machinery Safety, Regulations and Standards for CE/UKCA”   
> https://www.linkedin.com/groups/3995029/
>  
> Best regards
> Charlie
>  
> Charlie Blackham
> Sulis Consultants Ltd
> Tel: +44 (0)7946 624317
> Web: https://sulisconsultants.com/
> Registered in England and Wales, number 05466247
>  
> From: Brian Kunde  
> Sent: Friday, June 30, 2023 6:54 PM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] EU Machinery Regulation official version
>  
> Is there a good source of information on the application of this new 
> directive?  Are there any good articles or summaries comparing the new 
> directive to the old?  Are there implementation dates? Can we declare 
> compliance to the new directive now, or are their other hurdles that need to 
> be put into place?  
>  
> Is there a source for good comments and discussion on this?  I have only just 
> started to dig into it.  
>  
> Thanks to all.
> The Other Brian
>  
>  
>  
> On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane 
> <1afd08519f18-dmarc-requ...@listserv.ieee.org 
> <mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>> wrote:
> FYI – now published in the OJ -- 
> https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230
>  
> Best Regards,
> -Lauren
>  
> 
> LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any 
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Re: [PSES] EU Machinery Regulation official version

[Charlie Blackham]

Brian

If you’ve not come across it already, I recommend joining the LinkedIn group 
“Machinery Safety, Regulations and Standards for CE/UKCA”   
https://www.linkedin.com/groups/3995029/

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Brian Kunde 
Sent: Friday, June 30, 2023 6:54 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Machinery Regulation official version

Is there a good source of information on the application of this new directive? 
 Are there any good articles or summaries comparing the new directive to the 
old?  Are there implementation dates? Can we declare compliance to the new 
directive now, or are their other hurdles that need to be put into place?

Is there a source for good comments and discussion on this?  I have only just 
started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane 
<1afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>>
 wrote:
FYI – now published in the OJ -- 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230

Best Regards,
-Lauren


LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any 
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Re: [PSES] [EXTERNAL] Re: [PSES] EU Machinery Regulation official version

[Ted Eckert]

Hello Brian,

I can only partly answer your questions. See article 52, “Transitional 
provisions”. It notes that EU member states must accept products declared to 
2006/42/EC until 14 January 2027, so there is a fairly long transition period. 
However, there is additional information on the transition of market 
surveillance and safeguard procedures under the new Directive (Chapter VI) with 
a date of 13 July 2023.

I expect the European Commission to update this 
webpage<https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards/machinery-md_en>
 in the near future. Hopefully, they will include guidelines for the new 
Machinery Directive on that page.

Best regards,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

From: Brian Kunde 
Sent: Friday, June 30, 2023 10:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] EU Machinery Regulation official version

Is there a good source of information on the application of this new directive? 
 Are there any good articles or summaries comparing the new directive to the 
old?  Are there implementation dates? Can we declare compliance to the new 
directive now, or are their other hurdles that need to be put into place?

Is there a source for good comments and discussion on this?  I have only just 
started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane 
<1afd08519f18-dmarc-requ...@listserv.ieee.org<mailto:1afd08519f18-dmarc-requ...@listserv.ieee.org>>
 wrote:
FYI – now published in the OJ -- 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230

Best Regards,
-Lauren


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Re: [PSES] EU Machinery Regulation official version

[Brian Kunde]

Is there a good source of information on the application of this new
directive?  Are there any good articles or summaries comparing the new
directive to the old?  Are there implementation dates? Can we
declare compliance to the new directive now, or are their other hurdles
that need to be put into place?

Is there a source for good comments and discussion on this?  I have only
just started to dig into it.

Thanks to all.
The Other Brian



On Thu, Jun 29, 2023 at 2:12 PM Lauren Crane <
1afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:

> FYI – now published in the OJ --
> https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230
>
>
>
> Best Regards,
>
> -Lauren
>
>
>
> LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any
> documents, files, or previous e-mail messages attached to it,
> (collectively, "E-mail Transmission") may be subject to one or more of the
> following based on the associated sensitivity level: E-mail Transmission
> (i) contains confidential information, (ii) is prohibited from distribution
> outside of Lam, and/or (iii) is intended solely for and restricted to the
> specified recipient(s). If you are not the intended recipient, or a person
> responsible for delivering it to the intended recipient, you are hereby
> notified that any disclosure, copying, distribution or use of any of the
> information contained in or attached to this message is STRICTLY
> PROHIBITED. If you have received this transmission in error, please
> immediately notify the sender and destroy the original transmission and its
> attachments without reading them or saving them to disk. Thank you.
>
> Confidential – Limited Access and Use
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
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> All emc-pstc postings are archived and searchable on the web at:
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[PSES] EU Machinery Regulation official version

[Lauren Crane]

FYI - now published in the OJ -- 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023R1230

Best Regards,
-Lauren


LAM RESEARCH CONFIDENTIALITY NOTICE: This e-mail transmission, and any 
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Thank you.


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