Understanding Each Directive:
Grey Area: Sometimes it’s still not clear which Directive applies to a product. Here are some additional considerations to help in reaching a decision.
1) LVD – Mechanical Hazards: The LVD doesn’t prohibit products that have mechanical
hazards. Standards listed under the LVD anticipate and include requirements for lower
risk mechanical hazards.
2) Common Standard: The Standard for the Electrical Safety of Machines, EN60204-1, is on both the MD and the LVD Standards List. Therefore, by using EN60204-1 under the MD, you can also declare compliance with the LVD for this standard.
3) Self-Declaration: With the exception of the high hazard product types listed in Annex IV of the Machinery Directive, both Directives are “Self-declaration” – this means that the manufacturer decides which Directives and Standards apply. As a result, no two CE product reviews will be the same. And, as long as you have sound rationale for your choice, documented in your Technical Construction File, there is no “wrong” answer.
4) LVD is Easier: The LVD is a much easier process in determining compliance. There is much more involved with the MD. The MD requires a Risk Assessment, the Annex I review in the MD is extensive and requires a very detailed report, and there are many more standards listed under the MD (harder to determine what standards apply and more likely that multiple standards will apply).
5) Customer requests for MD: Consider where your product will be used. It is common for people purchasing equipment to be used in a Production environment to require compliance with the Machinery Directive. Unfortunately, use of a product on the production floor is not the deciding factor on what directive applies to the product. If your product will be used on the production floor and it meets the definition of a machine in the MD, you may be better off using the Machinery Directive. Otherwise, you may have to frequently explain why you didn’t use the MD. This is especially true if you have a competitor that used the MD and who might try to use that against you with your customers.
6) Electrical & Mechanical Hazards: Regardless of which of the two directives you apply, both aim to achieve the same objective = adequate electrical and mechanical hazard protection. If your product has only a low level of mechanical hazard risk, the LVD is the likely choice. If your product has a higher level of mechanical hazard risk, the MD is the better choice.
7) Apply Both Directives? In general, for an individual product, you should select the LVD or the MD. Article 1, Clause 2, item k of the Machinery Directive specifies that electrical products covered by the LVD are exempt from the Machinery Directive. Note that if you build a system that includes different types of products, each product is evaluated to the CE Directives applicable to that product. For example, a computer is evaluated to the LVD even if it is mounted to a machine that falls under the MD. Do not need to try and source a computer that complies with the MD, because it doesn’t exist – the computer does not meet the definition of a machine. The computer should comply with the LVD.
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