- Risk Assessment
- Essential Health and Safety Requirements
- Harmonised Standards
- Bill of Materials
- Assembly Drawings and Schematics
- Declarations of Conformity covering additional legislation?
- Economic Operator established?
On January 20th, 2027, the ‘new’ version of machinery legislation comes into force for machines being placed on the European market. The EU Commission are keen to ensure legislation is applied evenly across each member state as the existing Machinery Directive allows for some ‘wriggle room’. The new Regulations are considered binding legislation, and each member state must implement it in its entirety.
Whilst many manufacturers may already be aware of the technical changes imposed in the new Regulation, I would caution against ignoring some of the administrative changes also required. Buried in the ‘preamble’ of the technical articles of the Machinery Regulations are changes that could create problems if not addressed by the manufacturer.
For any manufacturer based outside the EU, they need to ensure that they have an Importer and/or Authorised Representative, established in the EU. The role of Importer and Authorised Representative have predefined responsibilities under the structure of Economic Operator, which were not included in the current Machinery legislation. They should be considered your partner, based in the EU, who not only fulfils a commercial responsibility, but also act as the first port of call within the EU for all legislation issues, such as responding to European policing authorities.
This constitutes quite a deviation from the previous Machinery Directive requirements and could cause potential stumbling points when exporting from the UK into Europe. The European Union is looking to tighten-up on surveillance of imported goods and the new Regulation gives them the means to challenge importers of equipment that previously might have sailed through port of entry checks. The proposed implementation of Digital Product Passports means that manufacturers will have to make legislation support documentation available to Policing Authorities via cloud-based systems.
This illustrates the ‘direction of travel’ to a more digital intelligence surveillance system by the EU policing authorities. In combination with new pieces of European Legislation, the importance of a ‘robust’ Technical File and accurate Declaration of Conformity documentation become essential when shipping product into the EU.