So, you’ve ordered a new machinery product or a piece of machinery for your production line. What due diligence should you take before you accept it and put it into use?
If a factory owner in the UK is importing a machinery product from Europe, the single most important thing to understand is what legal status the machine has when it is shipped. Everything else flows from this status. There are only two possibilities under the EU/UK Machinery Regulations.
What exactly have you ordered? As an End User what do you need to check?
One key aspect to address is whether the machine is considered complete and ready to go or is intended to be incorporated as part of another piece of equipment or production line. Your next steps will depend on which of these two conditions apply.
| Complete Machine (M/C) CE marked | Partially Complete Machine (PCM) |
| The manufacturer is declaring that they have supplied a machine fully compliant with all relevant legislation. | The manufacturer is declaring that the machine does not meet all applicable legislation. |
| Check for CE or UKCA marking | Check Declaration of Incorporation (DoI) |
| Check Declaration of Conformity (DoC) This is the legal document proving the manufacturer has: · Applied all relevant harmonised standards (EN standards) · Completed a risk assessment · Ensured the machine meets Essential Health and Safety Requirements (EHSRs) | DoI is issued instead of a DoC. It means: · The machine cannot be used safely on its own · It must be completed by the importer or integrator · The manufacturer has applied relevant EHSRs only for the parts delivered
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| The DoC must list, as a minimum, the following: · Manufacturer name and address · Product identification · Applied standards · Authorised Person · Any notified body involvement (if applicable) | Assembly Instructions These must explain: · What safety measures the final manufacturer must add. · What residual risks remain. · How to integrate the PCM into a complete machine.
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| Is the Technical File available? You don’t receive it, but you must ensure the manufacturer has one and will supply it to authorities if requested. | A PCM must not carry CE/UKCA marking for machinery safety. There may be one attached covering other legislation (EMC, etc., etc). |
| Other mandatory checks: · Correct language manuals (UK) · Safety components with CE/UKCA marking · Electrical compliance (EN60204 1) · EMC compliance (if applicable) · Pressure equipment compliance (if applicable)
| PCM are subject to a ‘two-stage’ process before they can be CE or UKCA marked and legally accepted. You become the manufacturer of the final assembled machine, and you must then: · Perform a full risk assessment · Ensure compliance with all EHSRs · Apply CE/UKCA marking · Issue a Declaration of Conformity |
End User suggested next step:
It’s important to recognise that what you assume is being delivered by your supplier is in fact what you need. Factory Acceptance Testing (FAT) or some form of pre-delivery assessment should be seen as a way to ensure delivery, installation and commissioning of new equipment isn’t just functional checks. It should also include some form of compliance assessment to ensure you don’t accept something that is quickly installed and then is quarantined awaiting Health & Safety sign off.
At Technology International, we can help by engaging alongside your procurement department to help ensure new machinery is correctly specified in terms of legal requirements. This could be extended to include pre-shipment checks or factory acceptance tests prior to despatch or final payment.