Machinery Directive and Partly completed Machinery, Guide 2019

Last edit: 26/04/2024

The new edition of the Guide to the Machinery Directive 2006/42/EC was published in October 2019. The English version can be downloaded from the link at the side of the page.

One of the aspects they tried to clarify is related to partly completed machinery. The definition is as follows:

[Machinery Directive 2006/42/EC] – Article 2 – Definitions

‘partly completed machinery’ means an assembly which is almost machinery but which cannot in itself perform a specific application.

The classic example is a robot. This is built by ABB, Yaskawa, Fanuc or other manufacturers and sold to an integrator, who programs it for the specific application and places it in a robot cell. The robot was not made for a specific application, but it has one once it is programmed by the integrator. The manufacturer of the robot issues a Declaration of Incorporation of Partly Completed Machinery to the integrator who, after installing it into the new production line, CE marks the assembly.

Here is what the Guide to the Machinery Directive writes about this:

[Guide to the Machinery Directive – 2019] §46 Partly completed machinery

As an example, industrial robots are usually designed without a specific application until incorporated into the final machinery […]. The manufacturer of the final machinery takes the necessary measures so that the robot can perform its specific application safely within the assembly.

There is another important passage that the Guide to the New Machinery Directive 2006/42/EC emphasises in order to understand the concept of partly completed machinery:

[Guide to the Machinery Directive – 2019] §46 Partly completed machinery

Machinery that meets the definition in the first three indents of Article 2(a), so it can in itself operate independently, performing its specific application […], but which only lacks the necessary protective means or safety components, such as guards, is not to be considered as partly completed machinery.

Basically, it is not possible to build a machine without certain protections, ‘which the user will then put on’, and call it a ‘partly completed machinery’: in this case, such a product falls under the definition of machinery and must be CE marked.

Unfortunately, there are few such unequivocal examples. A more complex example is the case of a manufacturer of rolling stands. The customer simply wants the cages with all the equipment in the field (motors, hydraulic power unit, etc.) but he will do the integration into his plant control and safety system. It is clear that the cages have a very specific application, but only after being equipped with an automation and safety system. The manufacturer will then sell the product as a partly completed machinery.

Fortunately, the New Machinery Product Regulation clarifies further the issue by slightly modifying the definition of Partly Completed Machinery:

[Machinery Product Regulation] – Article 3 – Definitions
(10) ‘partly completed machinery’ means an assembly which is machinery but for the fact that it cannot in itself function so as to perform a specific application and which is only intended to be incorporated into or assembled with machinery or other partly completed machinery or equipment, thereby forming a machinery product;

In addition, the following clarification is given in the recitals:

[Draft to the New Machinery Directive – April 2021 ] – “Whereas”
(21) Partly completed machinery is a product within the scope of this Regulation which needs to undergo further construction in order to be able to perform its specific application, namely the well-defined operations for which the product is designed. It is not necessary that all requirements of this Regulation apply to partly completed machinery but, in order to ensure the safety of the product as a whole, it is nevertheless important that the free movement of such partly completed machinery be guaranteed by means of a specific procedure.

In essence: a small robot equipped with a start and stop button and which, for example, cuts the grass on a lawn or helps people to walk properly (so-called service robots) is a machine. The scorification robot of a melting furnace is a partly completed machinery, as it needs to receive interface signals from the rest of the plant in order to function properly.

In the attachments section of this page you can download the 2019 Guide to the Machinery Directive 2006/42/EC.