Shall Partly Completed Machinery be CE Marked?
Last update 28/02/2022
THE DOUBT: Shall a partly completed machinery bear the CE marking?
There is a straight answer most people know and that is: No, it shall not.
In reality, that answer is misleading! A party completed machinery does not have to be CE marked according to the Machinery Directive since it does not comply with all the applicable Essential Health and Safety Requirements and therefore, in principle, it is a “dangerous machinery”. However, please read the following language from the 2019 Guide to the Machinery Directive:
[2019 Guide to 2006/42/EC] The CE-marking affixed on the machinery signifies that the machinery complies with all of the applicable EU legislation requiring the CE-marking […]. Note that although partly completed machinery must not bear the CE mark under the Machinery Directive, it may bear the CE mark if it also comes under other relevant legislation such as ATEX […].
Normally a partly completed machinery comes with its own control panel and electrical equipment: take as an example a robot with its controller. In that case, despite the partly completed machinery shall net bear the CE Mark with reference to the Machinery Directive, the control panel much be CE marked since it falls under the Low Voltage (if powered at more than 50 Vac) and the EMC Directive.
A partly completed machinery, provided with its own electrical control panel, shall not bear the CE mark as a machinery, however, its control panel must be declared in compliance with the Low Voltage and EMC Directive (that means safe from the hazards tackled by the two Directives) and therefore it must be CE Marked.