Case 2.1 : Parallel application of the EMC and Machinery Directives

In order to avoid confusion in the interpretation of the texts of the EMC and the machinery Directives, it is important to point out that the essential requirements stipulated by these two Directives are of very different nature :

• The EMC requirements laid down by the Machinery Directive concern only the emission of radiation, aimed at the user's protection, safety and immunity to external radiation, aimed at ensuring its proper functioning.
• On the other hand, the EMC requirements stipulated by the electromagnetic compatibility Directive (Articles 4a and 4b) are aimed at functional protection of the apparatus itself and other apparatus in its environment, for emissions and immunity. It is definitely not user oriented as such and not limited to radiation, which is only one EMC aspect to be considered.

Their requirements and objectives being clearly different, neither of these two Directives can be regarded as being specific one to the other. Both Directives have to be applied in a parallel and complementary way following the approach described as follows.

Case 2.2 : Criteria of applicability of the EMC Directive

The machinery sector is characterised by a very large range of products of different types, sizes and nature, from small machines produced in series to large and even very large machines sometimes manufactured as "one-off's" according to the technical requirements and needs laid down by the customer. Some are apparatus, others have to be considered as systems, others as installations.

The sector is also characterised by a majority of SMEs (small and medium sized enterprises), experienced professionals in mechanical engineering, but often with limited knowledge of EMC and other related matters, and little or no EMC test equipment.

The manufacturer of the equipment (in this case, machinery), should perform an EMC analysis to define what essential safety and/or protection requirements apply to his apparatus, from which applicable Directive and how to conform to them, using the choices of procedures given in each Directive that applies, which, in turn, may also depend on the extent of use of voluntary harmonised standards.

In all cases, where the machine's manufacturer only uses CE marked apparatus (complying with the EMC Directive) and follows strictly the instructions and limitations of use of the manufacturer of these products who intended them to be used in machinery, the finished machine could be considered in compliance with the EMC Directive and no further verification would then be needed. The EC declaration of conformity as well as the instructions for use must refer to the finished machine as a whole. The manufacturer assumes responsibility for compliance with the Directive in all expected electromagnetic environments and must therefore, provide clear instructions for use. The finished machine as a whole does not need to bear the CE marking (all this applies even if it is offered on the market as a single functional unit, as long as each part bears the CE marking). The addition of electromagnetically irrelevant components should also have the same effect since the EMC characteristics are mainly due to the electrical and electronic devices incorporated in the machine and not the mechanical components, that are 'electromagnetially irrelevant' in this context.

This simplification does not alter the full responsibility of the machine's manufacturer. If the resulting machine needs additional EMC protective measures to fulfil the EMC protection requirements, they must be undertaken by him, but not subject to the procedures of the EMC Directive.

Case 2.3 : Harmonised standards that may be used for machines

The so-called harmonised generic standards for the residential, commercial and light industrial environment and industrial environment can be used by machine manufacturers to bring machines into compliance with the EMC Directive until specific product family standards are available as harmonised standards.