The deciding factor is whether the manufacturer has control of compliance with all of the applicable EHSRs and, by extension, whether it is expected that the product will under go a further conformity assessment procedure before it is placed on the market or put into service. If, and only if, the answer to the first question is ‘no’ and to the second question is ‘yes’ then the Declaration of Incorporation route is correct. If the answer to either question is the reverse then compliance with the applicable EHSRs is the responsibility of the manufacturer and the product must be CE marked and have a Declaration of Conformity.
It’s important to realise that ‘control of compliance with the EHSRs’ may just mean that the manufacturer describes the relevant protections in their installation instructions. For example, if the product is a machine tool which is supplied without complete guarding because it is going to be incorporated with other machinery into a manufacturing cell, the manufacturer is still able to describe the guarding requirements within their documentation and hence has control of that EHSR even if they don’t provide the hardware which forms the protection. Thus, the machine must be CE marked, even if the guards are supplied by someone else. Nick. > On 13 Apr 2016, at 23:05, John Allen <jral...@productsafetyinc.com> wrote: > > Hi guys, > > I'm hoping to feedback and clarification if I'm reading the Machinery > Directive correctly. > > The product is a Pulley Block with a brake/ratchet mechanism. It is not > supplied with the rope. It is used for lifting machinery, not people. > > We believe this to be partly completed machinery and should not bear the CE > mark and be supplied with a Declaration of Incorporation. We have heard > different opinions and some believe because it has a brake/ratchet it should > be marked CE and supplied with a Declaration of Conformity. > > Your thoughts and opinions would be appreciated. > > Best Regards, > > John - ---------------------------------------------------------------- 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> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
