Declarations of Incorporation and partly completed machinery

2010.12.17
Written by: Doug Florence

If a machine is delivered without a control system, incomplete guarding, no access walkways etc., it is “partly completed machinery” in terms of Machinery Directive 2006/42/EC Article 1 Clause 1.g, Article 2 definition g. It should therefore be sold with a Declaration of Incorporation (DOI) rather than a Declaration of Conformity (DOC). It should NOT carry a CE marking for MD because it is not in conformity with all the EHSRs of the Directive. It may carry a CE marking for other relevant Directives.

The DOI should list which EHSRs are met and which are not and advise that the machine must not be put into service until the equipment into which it is incorporated has been assessed for MD compliance.

If the machine is supplied without a control system EMC will not be applicable.

In this case, it would be usual to issue a Certificate of Conformity which will indicate that the machine is in conformity with the applicable requirements of 2006/42/EC.
Under “Subject to the following conditions” we will remark. “Supplied as partly completed machinery without control system and ….. (any other things like incomplete guards)
The equipment meets the following EHSRs of the directive…….. OR The equipment supplied does not include provisions to cover the following EHSRs of the Directive. (Whichever is shorter) “

An advantage of supplying the equipment as partly completed machinery is that the manufacturer can include or exclude whatever he likes, so for instance he can provide a machine without isolators, E stops or guards providing he makes it clear that it is the responsibility of the person who integrates the equipment into the final machine.

The lack of a CE marking on the machine can cause problems with ignorant customs officials in some EU countries e.g. Turkey and elsewhere e.g. India. In this case we can suggest the manufacturer place a CE marking on the equipment nameplate on their own responsibility although they should be aware that is so doing , they may create further problems for themselves.

 


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