DocEUpoint is a Conformance service to help machinery manufacturers based outside the EU comply with the Machinery Directive.
Among other things, the Machinery Directive requires machinery manufacturers based outside Europe to appoint someone within the EU to act as their representative for the delivery of technical documentation in the event of an enforcement action.
DocEUpoint empowers us to hold and be the authorised contact point for your technical file.
Information is provided here to help you understand the background to the requirement, the services we provide to help manufacturers to comply with the requirement, and how to sign up for a DocEUpoint contract.
While there is no requirement for a manufacturer of products requiring the CE mark to appoint an Authorised Representative based within the EU (see our page on this topic for further details), the new Machinery Directive does contain a requirement for non-EU based manufacturers to appoint someone within the EU to act as their representative for the delivery of technical documentation in the event of an enforcement action.
The actual mechanism by which this requirement is established is contained in Annex II of Directive 2006/42/EC, which deals with the content of Declarations. Item 2 of the list for both Declarations of Conformity and Declarations of Incorporation states as follows:
“name and address of the person authorised to compile the technical file, who must be established in the Community”
The purpose of this requirement is to deal with an issue which the enforcement authorities for the Directive have found to be an increasing problem, namely that they have difficulty in obtaining the technical documentation which allows them to assess whether or not a product has been correctly CE marked.
It’s important to understand that this requirement is not about requiring a manufacturer who is based outside the EU to appoint an Authorised Representative. The function of a formally appointed Authorised Representative, and their relationship with the manufacturer, is quite different. This requirement is about ensuring that the enforcement authorities have timely access to the information they need to assess whether the machine has been correctly CE marked.
It’s also worth noting that the Directives do not require the technical documentation to be actually stored in the EU. This is dealt with in Annex VII to the Machinery Directive, which states;
“The technical file does not have to be located in the territory of the Community, nor does it have to be permanently available in material form. However, it must be capable of being assembled and made available within a period of time commensurate with its complexity by the person designated in the EC declaration of conformity.”
To help non-EU manufacturers meet these requirements, Conformance has set up its DocEUpoint service.