Guidelines on the requirements of Directive 73/23/EEC

OTHER DIRECTIVES

There are three other directives which are applicable to switchgear and controlgear:

• Machinery Directive 98/37/EC (originally 89/392/EEC)
• EMC Directive 89/336/EEC
• CE Marking Directive 93/68/EEC

MACHINERY DIRECTIVE 98/37/EC

Certain electrical equipment are also "machinery" within the meaning of Directive 98/37/EC as amended.

Both the "Low Voltage" Directive and the "Machinery" Directive cover a wide range of risks. Therefore, the scopes of the two Directives overlap in the case of certain electrical equipment, and a clarification on how to implement the Directives in those cases is necessary.  

"Where, for machinery, the risks are mainly of electrical origin, such machinery shall be covered exclusively by Council Directive 73/23/EEC of 19 February 1973 on the harmonisation of the laws of the Member States relating to electrical equipment designed for use within certain voltage limits".

In general, in order to determine whether the exclusion from the scope of the "Machinery" Directive under Article 1(5) applies to a specific product which may be considered to be "machinery" in the sense of Directive 98/37/EC and an electrical equipment in the sense of Directive 73/23/EEC, the manufacturer has to perform a risk assessment of that product.

The European Standard EN 1050 (Safety of Machinery - Principles for risk assessment) provides for principles which may be applied for performing such risk assessment.

When the results of the risk assessment by the manufacturer show that the risks are mainly of electrical origin, the machinery equipment will be covered exclusively by the "Low Voltage" Directive, which anyhow deals with all the safety aspects, including mechanical safety.

EMC DIRECTIVE 89/336/EEC

Conformity with an harmonised standards  provides a presumption of conformity with the protection requirements of EMC Directive 89/336/EEC (covering emission and immunity). Harmonised standards are thus designed to satisfy the protection requirements of the EMC Directive.

BS EN 60439-1 was amended in 1996 (amendment A11) in order that it could be recognised as a "Product EMC Standard" and states "No EMC immunity or emission test are required on final assemblies, if the following conditions are fulfilled:"

• the incorporated devices and components are designed for the specific EMC environment in line with the relevant product or generic EMC standards;
• the internal installation and wiring are carried out in accordance with the instructions of the device and component manufacturers (arrangement with regard to mutual influences, cable screening, earthing, etc.).

The standard recognises that "Assemblies are in most cases manufactured or assembled once only, incorporating a more or less random-combination of devices or components."

CE MARKING DIRECTIVE 93/68/EEC

 This directive was introduced in 1993 and amended 12 existing directives, including the LV Directive. Whereas each of these directives provided for the affixing of the 'CE' mark, they were not consistent and did not take into account products which fell within the scope of more than one directive. This directive provided for common rules and a single design for the 'CE' mark:

The 'CE' mark is a mandatory requirement and is not a quality mark. The affixing of a 'CE'; mark to a product purely indicates that the product conforms to all applicable directives, however in order to affix the 'CE' mark a manufacturer must verify that the product does indeed conform to the directives (see assessment).

WARNING Three of the quality assurance modules cited in Council decision 93/465/EEC (Conformity Assessment Procedure) , i.e. modules D, E & H, require that "the manufacturer must operate an approved quality system ". The scope of the quality systems required by these modules addresses:

• Final product inspection and testing (module E)
• Production, final product inspection and testing (module D)
• Design, manufacture and final product inspection and testing (module H)

 As a consequence of this council decision, companies who do not operate an approved quality system are not allowed to affix a 'CE' mark in accordance with the CE Marking Directive, unless they have a technical report or technical certificate issued by a competent body.

IMPORTANT Some clients are under the impression that they can approve the quality system of a supplier. They are wrong. The council decision clearly states " the quality system must be approved by a Notified Body". The council decision goes on to state that compliance with EN ISO 9001 gives a presumption of conformity with the quality assurance module 'H', however manufacturers are free to apply other quality system models than those based on EN ISO 9001 standards for the purpose of complying with these modules.