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The Machinery Directive Declarations

The Declaration of Conformity

A Declaration of Conformity should only be issued with a ‘complete’ machine meeting the relevant essential health and safety requirements of the Machinery Directive (and any other relevant European and national legislation relating to that type of machine).

The Declaration of Incorporation

Essentially, the Machinery Directive says that every piece of machinery which falls within its scope must be CE marked to show that it is safe. However, some machines are supplied as components or sub-assemblies for other, bigger machines and cannot be considered as safe when delivered by the manufacturer, so the manufacturer can't legitimately CE mark them. The Declaration of Incorporation plugs this gap.

The Declaration of Incorporation is a piece of paper which accompanies a piece of machinery which is incomplete, and which says words to the effect of:

"this piece of machinery is incomplete and therefore cannot be CE marked by us because the things that the user will do to it are outside our control and will be what really matters in making it safe under the Machinery Directive. However, so long as the machine is used in accordance with our instructions, the bits which we are responsible for will conform with the essential requirements of the Directive".

Of course, the actual wording of the Declaration of Incorporation is rather more formal that this! The Machinery Directive does not specify the exact form of words to be used, but based on the guidance from the UK government, we've prepared a draft Declaration of Incorporation which you can download (in Acrobat PDF format).

This concept of the Declaration of Incorporation only exists within the Machinery Directive, which is a shame since it's actually quite a useful concept which could be extended to other CE marking directives, in particular the Low Voltage Directive.

The basic rule when choosing between the Declaration of Conformity and the Declaration of Incorporation is whether or not the assembly is CE marked under the Machinery Directive. If it is marked, a Declaration of Conformity must be completed. If it is not marked under the Machinery Directive (even if it carries a CE logo to show conformity with other Directives) it must be accompanied by a Declaration of Incorporation.

General points

Declarations must be either typewritten or hand-written in block capitals.

Declarations must be written in the same language as the instructions supplied with the machine.

A unique Declaration should be supplied with each machine in a series production situation.

In the main, the Declaration of Conformity for machines is similar to that required under the Low Voltage and Electromagnetic Compatibility Directives and it is common to combine the declarations for these directives into one document. For further advice on this, see our Declaration of Conformity page.

 

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