FIND SOME OF OUR CUSTOMER'S ASKED QUESTIONS AND ANSWERES
Question 1. Is it allowed to put into service a machine for lifting goods (forklift or HDS crane), after assembly work platform (basket) for lifting persons? The platform is CE marked by its manufacturer.
At first, we have to emphasis that non-integrated working platforms are not covered by Machinery Directive and may not be CE marked. (CE marking is illegal in this case). Regarding the forklift truck, it may be allowed to work with work platform, provided that the manufacturer's instruction allows assembly of the work platform which meets the conditions specified by the manufacturer of the machine.
On the other hand, generally, forklifts or cranes are not designed to lift persons (do not meet safety conditions) so installing a working platform we create a new machine that is subject to the requirements of the Machinery Directive (and others). Not be assumed that it complies the requirements so you need to conduct a conformity analysis, hazard assessment and adapt the design to the essential requirements. Before being allowed to work the new machine should be marked with the CE mark.
The same applies to the front loader forklift.
However, in the UK there are Health and Safety Executive regulations (PM28) allowing to use of non-integrated working platform on forklift trucks: HSE-Working-platforms-on-forklift
Of course it is allowed by MD as well.
Question 2. Hello, I am a manufacturer of a pneumatic workshop jack called - snowman, should it be CE marked?
A pneumatic jack - a snowman. Yes. This jack is a machine (for vehicle service) is subject to the requirements of the Machinery Directive should therefore bear the CE marking. There is also a standard EN 1494 - Mobile or movable jacks and associated lifting equipment, harmonized with the Directive. The participation of a notified body in the conformity assessment is not a must and depends on the assessment procedure chosen.
Question 3. Does the gearbox assembly with an electric motor need to be CE marked?
It should not. The gear motor alone can not perform a specific function so it is not a machine. But it is a drive system considered as a partly completed machinery and the declaration of incorporation of partly completed machinery should be issued (excluding CE marking). Usually, we meet this drive sets with the CE mark label placed on the electric motor but that's because the motor bears the CE mark meaning conformity with the Low Voltage Directive placed by the motor manufacturer (not by the Manufacturer of the gearbox and motor kit).
Question 4. Is the column type lift for lifting cars a subject of the Machinery Directive and should bear the CE marking?
Yes. The lift is a machine (for vehicle service). It is subject to the requirements of the Machinery Directive - MD (usually also LVD and EMC) and should therefore bear the CE marking. There is also harmonized standard EN 1493 - Vehicle lifts, that specifies the requirements of such machines.
Moreover, such a machine is one of (causing significant hazard) specified in Annex IV of the Directive so choosing the conformity assessment procedure, you can choose full compliance with the standard EN 1493 without the involvement of a notified body or one of the procedures involving the notified body at which full compliance with the standards is not mandatory.
www.inbiuro.com/en/projects/car-lift.html
Question 5. Hi, I have a mobile crane on the chassis of the commercial vehicle and would like to expand it with the function of aerial platform fixed to the end of crane. Is such a machine allowed to be put into operation if I mention the mobile crane is CE-marked and the work plaform attached is also CE marked?
It depends on machine user manual. Typical mobile crane is intended for lifting goods (as purpose of a crane) and is not allowed to lift people. When installing the basket it becomes a different new machine for which safety requirements are significantly different than those referred for cranes. Thus we've got a machine that needs to be examined in the entire process of compliance and CE marking. Only then the machine may be allowed to lift people.
In this example filal machine contains non-CE marked work platform and final machine have been CE marked by manufacturer.
www.inbiuro.pl/uraw-hds-z-koszem.html
In case that user manual allowes for interchangeble attachments like work platforms it is allowed then to fix it. For example: http://manuals.gogenielift.com/parts%20and%20service%20manuals/data/Parts/Telehandlers/645031.pdf
is intended to be attached by a final user and it is CE marked as interchangable equipment. However you should ask national market surveilance authorities as lifting of peaople by machines intended for lifting goods may be treated different in EU member states.
There is a Palfinger machine intended for lifting loads and work platform simultaneously and you can see it here:
https://vertikal.net/en/news/story/27442/crane-option-for-palfinger-nx-platforms
Question 6. Is the use of harmonized standards for the design mandatory?
It is not mandatory. Manufacturer may decide to use the standard or not. Bear in mind that the use of standards can facilitate the process of CE marking. For example, while meeting the 100% of requirements of the standard, we can label the car jack (EN 1494) without the involvment of a notified body but if you decide not to comply the standards then you must engage notified body in the process of CE marking.
Question 7. Hi, I produce wood sawing machine. Sawing machinery are listed in Annex IV of the Machinery Directive 2006/42/EC. Is it mandatory to involve notified body in the conformity assessment process?
It is not mandatory. It depends on conformity assessment procedure chosen by manufacturer. If your design and fabrication process complies type C standards (specific for this type of machine) and the machine is in full compliance with these standards then you can even follow essessment procedure that do not require involvment of notified body (self assessment and production controll).
Question 8. Is a machine produced for own use required to be CE marked?
Yes, it requires a result of this provision. "Manufacturer" means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for conformity of machinery or partly completed machinery with this Directive, with a view to its being placed on the market under his own name or trademark or for his own use.
Question 9. Are grapples and buckets for excavators subject to EC Directives and should they be CE marked?
Further analysis of features of the device should be made to answer this question. We can distinguish several types of grippers
a) buckets and grapples with hydraulic or electric drive (scrap grapples, grippers for handling sheet metal, wood grippers, clamshells with hydraulic drive - the so-called. crocodiles) are subject to the Machinery Directive 2006/42/EC and must bear the CE marking. These grippers are interchangeable equipment mounted by the operator changing the function of the machine.
www.inbiuro.com/en/projects/scrap-grapple.html
b) simple buckets for excavators not having drives - are not subject to the Machinery Directive 2006/42/EC
In the examples of our designs, you can find several types of grippers.
Question 10. Is a machine built on vehicle or on trailer subject to CE marking?
Yes, it is and should be CE marked. Constructions on vehicles and on trailers (eg. Hoists, cranes, sawing machines, concrete pumps, etc) are subject to the Machinery Directive 2006/42/EC, but the trailer or the vehicle itself does not fall under the Machinery Directive (provided that it is a vehicle covered by type-approval and allowed to be driven on public roads).
Question 11. Should any product placed on the market have a CE marking? Is it acceptable to label any product to customer's request or for marketing purposes?
No, you can (even have to) affix the CE mark only the products that are subject to EC Directives and the Directive requires CE marking for the product concerned. It is not allowed to CE mark product not covered by any directive or none of directives it is covered by requires CE marking. There are various products that are subject to the requirements of the EC directives but do not have to (can't) be CE labeled.
Question 12. Is the aerial platform covered by noise Directive 2000/14/EC?
Yes, the aerial platform is specified in the Noise Directive (Art.13) as "working platform" and is subject to noise level marking only that means, noise limits don't apply.
Question 13. What do I do if my product does not fall under any Directive and the client requests a declaration?
The product that is not a subject to any directive must not bear the CE marking. What's more, if the product is subject to the Directive and the Directive does not require CE marking for THIS product or do not require CE marking at all it is also not allowed to be labeled with the CE marking. In such cases, we recoment the manufacturer's to issue a statement in which he describes the explanation of the law. Such a statement should satisfy the purchaser.
Question 14. Is a steam turbine a machine, and should it bear the CE marking?
Yes. The turbine meets the definition of the machine according to the Machinery Directive 2006/42/EC (it has moving parts, is used to drive a generator) so it should bear the CE marking. If a company provides a new turbine then a matter of CE marking is quite simple because the full technical documentation is available and complience can be analyzed. The situation is worse in the case of turbine repairs that usually comes with a greater or lesser modernization. If modernization has a significant influence on the safety then modernized machine should be treated as a new machine.
Also, the steam turbine is not listed in Annex IV of the Directive therefore notified body is not required to be engaged in the process of CE marking.
Question 15. Does a simple grain storage silo have to bear the CE mark? Silos has no power supply or any trays or mechanical loads.
Described as above silo is not a machine within the meaning of Directive MD 2006/42 / EC. This is also not a low-voltage device that could be subject to the LVD Directive 2006/95/EC (no power supply). If you do not find any relevant EC directives for the silo then it is not subject to the CE marking.
Question 16. Should a hydraulic piston be marked with CE mark?
No, a hydraulic piston (as well as any pneumatic) has been recognized as a spare part of a machine and hence due to Machinery Directive 2006/42/EC is not an object of CE marking.
Question 17. Should an electric actuator be marked with CE mark?
That depends on its type. Electric actuator is not a machine according to a definition of Machinery Directive hence it is not expected to be CE marked due to MD 2006/42/EC. Depending on voltage it is driven by it may be subject of Low Voltage Directive 2014/35/WE (previously 2006/95/WE). If voltage range is 50÷1000 V AC or 75÷1500V DC then it should be CE marked. It is also dealt with by EMC Directive 2014/30/WE (previously 2004/108/WE) and should be CE marked regarding this directive.
Question 18. We manufacture smokers' cabins. Is the cabin required to be CE marked?
The cabin is normaly issued with a fan. Regarding to that it should be considered as machine and hence it is required to be CE marked.
Question 19. Are bolts and nuts required to be CE marked?
General use bolts and nuts used for machinary are not covered by any directive and hence can't be CE marked. Besides, there are special non-preloaded (EN 15048) and preloaded (EN 14399) structural bolting assemblies that are a subject of Construction Products Regulation 305/2011 and have to be CE marked. (and SB - Structural Bolt marked).
Question 20. Hi, we are providing portable, engine driven power generating sets. Should they be CE marked? Which European Directives should be considered?
Yes, power generating sets (finished machines) should be CE marked as they are a subject of Machinery Directive 2006/42/EC as well as Low Voltage Directive 2014/35/EU, EMC - 2014/35/EC, and Noise Directive 2005/88/EC.
The relevant EU standard is EN 12601 - Reciprocating internal combustion engine driven generating sets.
Besides, non-finished power generating sets ( intended to be build in another instalation ) should not be declared as complying all Machinery Directive but should be considered as non-finished machine. They should be still CE marked due to LVD and EMC.
Question 21. We manufacture a pneumatic suspension systems built of rubber cushions. Our customers require certifikate. Should our systems be CE marked?
There is no Directive requiring CE marking for such products hence it is not allowed to put CE mark on it. You can issue other "manufacturer's certificate / declaration" but CE marking is not allowed.
Question 22. We supply pneumatic jacks for cars and other purposes. Are such type of jacks a subject of Pressure Equipment Directive (PED) 2014/68/EU (formerly 97/23/EC)?
No. Pneumatic cushions are exluded from PED directive.
Question 23. There are plenty of almost identical pneumatic jacks on the market. How can I choose the right one (the safe one, properly CE marked)?
The first thing that should be checked is manufacturers Declaration of Conformity. Any third party Certificate is not sufficient. Declaration of Conformity should be issued and signed by a manufacturer or his authorized representative in EU. Apart of that User manual should be supplied. We have noticed a common technical bug in many of cheep jacks - the air is supplied and released by a hand operated ball valve. This conctruction does not comply safety rules (EN 1494) as the valve should be self-closing if released in any position.
Question 24. We are producing platforms for lifting of machinery. Are the platforms considered as lifting accessory and should they be CE marked?
No, shuch platforms are not considered as lifting accessory and not covered by machinery directive 2006/42/EC. Should not be CE marked (as well as bulk containers, marine ISO-containers).
Lifting accessories can be found here: www.inbiuro.com/en/ce-marking/lifting-accessories.html
Question 25. Should manualy operated jacks (intended for vehicles liffing) be marked with CE mark? ( e.g. screw jack or hydraulic jack)
Yes, manualy operated jacks are jubject of machinery directive 2006/42/EC and should be CE marked. Be aware that it is not covered by Annex IV as it is not intended for lifting entire vehicle.
Question 26. Is a hydraulic valve block a subject to CE marking?
In general, manually controlled hydraulic valves/blocks are a part of machine and they are not to be CE marked. But very often they have features that make them a subject of CE marking under other directives; i.e. solenoid controlled valves/blocks are a subject of CE mark due to LVD, block containing pressure safety valve are a subject to CE mark due to PED 2014/68/EU formerly 97/23/EC (Pressure Equipment Directive).
Question 27. My company bought a machine that has not been CE marked by its manufacturer. Can we CE mark it?
CE mark means declaration of the machine producer that it complies relevant directives requirements and may be placed by producer (or entitled representative). You (your company) can CE mark the machine if you can declare with full responsibility that the machine complies requirements and then this machine becomes your product with your name on a nameplate.
Question 28. Should LVD Directive be refered to in Declaration of Conformity of machine that is electrically driven? In many cases Low Voltage Directive is ommitted.
If the mashine is supplied at voltage range covered by Low Voltage Directive, LVD (50V ÷ 1000V AC and 75V ÷ 1500V DC) then the machine is a subject to the directive requirements but listing of LVD may be ommitted in declaration. That is written in point 1.5.1. of Annex I of MD 2006/42/EC.
Question 29. I've purchased used hydraulic press that have been CE marked by its manufacturer. Now I need to modify it for different production purposes. Does it need to be CE marked again?
You would not need to CE mark it again provided that your modification (tooling modification) is minor and doesn't exceed purposes covered by user manual. If your modification is not covered by the machine intended use then you definatelly have to CE mark the machine again. That doesn't mean your analysis need to cover all subjects done by its original manufacturer. It is sufficient if your analysis covers all aspects/riscs related with your modification.
Question 30. My product is a tripod support for electric lamp (lamp excluded). The tripod has a small manual winch installed on it for changing its height (lifting and lowering a lamp). Is this a subject to machinery directive or other directives and should that be CE marked?
That product is not considered as a machine. Regardless of a function of changin its height it is not a lifting function as well and should not be CE marked acc to MD. Regarding LVD it is still not an electrical equipment and hense should not be CE marked due to any directive.
Question 31. I am producer of automatic welding machine that uses gases stored in high pressure bottles. The bottles are installed of machine. Is my machine a subject of pressure equipment directive? Besides, the bottles got declaration of conformity with Transportable Pressure Equipment Devices 2010/35/UE
As long as there is no other pressurised gas tank, the machine is not covered by PE Directive just because of presence the bottles . The machine is still a subject to machinery directive.
Question 32. My company instals hook lifting devices on trucks for transport of containers. I know that needs to be CE marked but should the entire vehicle be CE marked or hook lift device only?
Machines installed on vehiles are subject to machinery directive but not the entire vehicles (as long as we are talking about type approved road vehicles excluded from Machinery Directive). So, declaration covers a HOOK LIFT ON A VEHICLE. The vehicle is a part of the entire structure and must be considered in your risk assessment analysis. It still doesn't mean the vehicle is subject of the machinery directive.
Question 33. One of our Customers asked if his tripod stand intended for holding and lifting a lamp or loud system and equipped with a manual rope winch for lifting it needs to be CE marked on not.
This particular product don't need to be (can not be) CE marked under Machinery Directive 2006/43/CE but you it might be CE marked under LVD if the tripod is equipped with electrical equipment for powering the device held on it (provided that it is in voltage range covered by LVD)
Question 34. Another product of our Customers is tripod stand intended for lifting general goods. The tripod is equipped with a manual driven rope winch for lifting. Does it need to be CE marked or not?
Yes, this product (although manually driven) is a machine for lifting loads and it is a subject to CE marking under machine directive.
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OTHER INTERESTING CASES
CE marking of vehicles and machines installed on vehicles
Lets consider different types of vehicles:
- intended for carying goods internally in factory and not allowed to be driven on public roads.
- vehicles intended to be driven on public roads
Regarding the 1st - those vehicles are ‘machines’ and hence should be CE marked. (they are not considered as road vehicles unless they are allowed to move on public roads).
Regarding the 2nd - these vehicles are excluded from Machinery Directive as they are subject of type-approval of motor vehicles and their trailers with exclusion of machinery mounted on these vehicles.
The last part of the above sentence means that any machines installed on vehicles (eg. elevating work platforms, cranes, cement mixers …) or under vehicle (special rail chassis )are still subject to the directive and hence should be CE marked.
CE marking of road trailers and off-road trailers
We are producing a bespoke trailer intended for carrying goods internally in industrial area of a factory. The trailer will be towed by a tractor and is connected to the tractor's pneuatic system to feed braking system. The trailer is equipped with lights (powered from tractor) but is not intended to travel on public road. Is this trailer a subject to CE marking? Whitch directives should be considered? Is that considered as a machine?
Let's analyze; the trailer complies a definition of a 'machine' described in Machinery Directive 2006/42/EC (first indent od Article 2 letter a). It is not fitted to a drive system but it is intended to be fitted to drive systen whitch is a tractor is this case. So, trailers are considered as machine. There are also exclusions from a directive. Is our trailer excluded? Second exclusion of Article 1 (e) states - "motor vehicles and their trailers covered by Council Directive 70/156/EEC..." We said our trailer trailer is off-road and will not be a subject to type approval hence, it is not excluded from MD and need to be CE marked under Machinery Directive.
What about Low Voltage Directive 2014/35/EC? The trailers' ligts are powered by 24 VDC from a tractor. That level of voltage is not covered by LVD hence our trailer is not a cubject to Low Voltage Directive.
CE marking of modified/modernized machinery
A lot of machines have been supplied for a bespoke purposes and after short time of operation you may need to modify it for different purposes. This is a common problem of users. In general, original Declaration of Conformity is not valid as soon as you modified the machine. Sometimes it is clearly written on declaration but don't need to as it is written is Machinery Directive. Hense, the modifier is obliged to CE mark the machine again and then question arises - how can we analyze its conformity with basic requirements when we don't posess desing and calculations?
It is allowed to presume that machine being modified complies its original requirements and you are obliged to analyze the influence of modification. You need to analyze all risks related/raised by your modification.
As the original Declaration of Conformity is no longer valid we are obliged to raise a new one and new user manual. We don't need to redraw it att but it is sufficient to update the original manual. We have to put a new CE nameplate on the machine as well. Besides, we are responsible for the modification and obliged to keep the documentation for 10 years. This documentation should contain: original manual, CE-nameplate, our analisis and risc assessment and all related with the modernization.
CE marking of outdoor mobile LED screen a trailer
Our product is a huge (200 inch diagonal) LED screen installed on a bespoke trailer. The screen has been designed for outdoor events, presentations etc. and is placed on a telescopic and rotating column. The lifting of a column is maintained by hydraulic cylinder supplied from onboard hydraulic power unit. The trailer is a bespoke solution intended to trevel on public roads. Is this the entire device considered as 'machine' and should be CE marked?
CE marking of tractor's and machine's attachments
There are plenty of attachments, usually hydraulically powered eg. front and rear lifts, loaders, forklifts, cranes, backhoes etc.... How do we classify them and should they need to be CE marked? Attachments like these may be provided by tractors' producers' or by third parties. As long as they have been provided with a new tractor as subassembly of the machine (referred to in manual), they don't need to be CE marked separately. In another way, while such a products are placed separaterly on the market they are 'interchangeable equipment' for machines and then they should be CE marked and Declaration of Conformity as well as user manual should be provided.
Regarding attachments like: grapples, grippers etc.... see question 9 above.
to be continued...