Eurotrans position EU Machinery Directive 2006/42/EC0 pages

2nd January 2010
EUROPEAN COMMITTEE OF ASSOCIATIONS OF
MANUFACTURERS OF GEARS AND TRANSMISSION PARTS

Position paper regarding: The Classifying of Gears, Gearboxes, Geared
Motors, Transmission Elements and Transmission Chains according to the
EU Machinery Directive 2006/42/EC
1. Preliminary remarks
The comments below are intended to provide the industry with a guide as to how gears, gearboxes,
geared motors, transmission elements and transmission chains could be incorporated. In order to
identify criteria for incorporation, the legal requirements are analyzed and reference is made to
publications by the Commission.
2. Legal foundation
2.1 EC Machinery Directive 2006/42/EC
Partly completed machinery is defined in Article 2 g of the Directive as follows:
“g) “Partly completed machinery” is a totality which almost forms a machine but in itself cannot fulfill
any particular function. A drive system may constitute partly completed machinery. Partly completed
machinery is intended only for installation in other machinery or other partly completed machinery or
pieces of equipment or for combination with these, in other then to form machinery within the
meaning of the Directive;”
Partly completed machinery does not as such perform a particular function. Its intended purpose is to be
installed in completed machinery or a totality of machines (system), which will be CE-marked.
Nonetheless, partly completed machinery must already have a character such that it “almost forms a
machine”.
Machinery components: In the draft of the planned Directive, the following is stated under §35 of the
guide of the new Machinery directive with regard to machines :
“The Machinery Directive does not apply directly to machinery components, such as, for example,
valves, hydraulic cylinders or gearboxes,that do not have a specific application as such but are
intended to be incorporated into machinery, although the design and construction of such
components must enable the complete machinery to comply with the relevant essential health and
safety requirements.”
2.2 Electric motors in accordance with the Low Voltage Directive
Electric motors with operating voltages within the voltage limits of the Low Voltage Directive 2006/95/EC
(formerly 73/23/EEC) are exempted from the scope of the Machinery Directive 2006/42/EC and are thus
covered by Article 1 (2) k, item six:

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