Ready to Go? What You Need to Know About Exporting in 2010

Pilz Automation Safety L.P. answers your questions

Canton, MI - The Machinery Directive is designed to standardize safety requirements across Europe and help to ensure the free flow of goods within the EU. Beginning December 29, 2009 the current version-98/37/EC-will be replaced by the new Machinery Directive 2006/42/EC. No provisions have been made for a transition phase. What exactly does this mean in practice- and what can companies do to prepare themselves? These questions are asked frequently and need an answer.

Generally, all machine operators and machine manufacturers need to be prepared to change over the corresponding documentation on the cut-off day. As a rule, double documentation should be provided for projects taking place close to the cut-off day. As a minimum, references to both directives must be present in the certificates.

The changes in the new Machinery Directive will affect manufacturers of "partly completed machinery" and operators of interlinked machines like robot cells and automated production lines.

How have definitions for machines changed under the new Machinery Directive?

The different machine concepts are being consolidated into a single definition. Accordingly, a machine is defined as "an assembly, fitted with or intended to be fitted with a drive system other than directly applied human or animal effort, consisting of linked parts or components, at least one of which moves, and which are joined together for a specific application." Accordingly, a machine must incorporate a drive system and comprise linked parts or components, such as a mechanical rocker. In addition, the machine must also be designed to perform a specific application, such as the welding of two components.

What is partly completed machinery?

The term "partly completed machinery" describes "an assembly which almost forms a machine, but which when taken by itself is incapable of performing a specific function. [...] Partly completed machinery is only designed to be incorporated machinery or equipment or to be joined together with them in order to form a machine [...]." One example of a "partly completed machine" would therefore be a robot which has not yet been equipped to perform a particular task. Manufacturers of "party completed machinery" must satisfy special processes in the CE conformity process which are different from the processes for machines. These are designed to provide manufacturers and operators who interlink the "partly completed machinery" to form installations with the information required to ensure safe integration in the overall plants.

Have changes been made to the conformity procedures?

In addition to the special procedures for "partly completed machinery", the conformity procedure for machines listed in Annex IV of the Machinery Directive have also changed. Manufacturers and operators who interlink different machines to form plants and therefore assume the role of manufacturer must now perform a risk assessment. This consists of a sequence of accurately defined process steps: determination of hazards, risk assessment, elimination of hazards and risk reduction. The harmonized new standards EN ISO 13849-1 and EN/IEC 62061 must be applied to this self-certification.


As an expert in machine safety, Pilz offers a comprehensive range of services which cover all phases of the machine lifecycle: from the identification of danger zones to the implementation of safety concepts and the integration of safety measures. This also includes planning and implementation of conformity procedures in accordance with the new Machinery Directive 2006/42/EC, both for standalone machines and whole production lines. As an authorized representative, Pilz takes responsibility for the administrative procedures demanded in the directive.

First and foremost, the new Machinery Directive establishes greater legal clarity, as some passages that were unclear have been defined in more detail, and the scope is described more clearly. When implemented accordingly, it will help to improve the safety and transparence of the European Economic Area.


Dana Weeks

Pilz Automation Safety L.P.

Phone: (734) 354-0272 x225


Contact This Company

All Topics