Accessing the EU Market: CE Marking for Electrical Furniture Falling under the Machinery Directive
New guidance for the application of the European Union’s (EU) Machinery Directive 2006/42/EC was published in July 2017.
This identified, for the first time, electrically actuated motorized domestic furniture as falling within the scope of the Directive, meaning electrical furniture must now carry the CE mark. In this article, we look at the steps manufacturers of electrical furniture must take to ensure continued access to the European market.
What is the Machinery Directive?
Directive 2006/42/EC, the EU Machinery Directive was passed by the European Parliament and European Council in 2006 and amended, most recently, in 2017. It describes the essential health and safety requirements that apply to all machinery offered onto the EU market.
Machinery is defined in the Directive as:
- An assembly of linked parts or components, at least one of which moves, with the appropriate actuators, controls and power circuits etc. joined together for a specific application
- An assembly of machines which, to achieve the same end, are arranged and controlled so that they function as an integral whole
To comply with the requirements of the Machinery Directive, the manufacturer must prepare the TCF (Technical Construction file) according to ANNEX VII of 2006/42/EC. This mainly includes the following files:
a) a construction file including:
- A general description of the machinery
- The overall drawing of the machinery and drawings of the control circuits, as well as the pertinent descriptions and explanations necessary for understanding the operation of the machinery
- Full detailed drawings, accompanied by any calculation notes, test results, certificates, etc., required to check the conformity of the machinery with the essential health and safety requirements
- The documentation on risk assessment demonstrating the procedure followed the standards and other technical specifications used, indicating the essential health and safety requirements covered by these standards
- Any technical report giving the results of the tests carried out either by the manufacturer or by a body
- A copy of the instructions for the machinery
- A copy of the EC declaration of conformity
b) For series manufacture, the internal measures that will be implemented to ensure that the machinery remains in conformity with the provisions of this Directive
Scope of the Directive
Types of furniture that may come under the scope of the Machinery Directive, include:
- Height adjustable desks/tables
- Operated seating
- Operated beds
- Beds with TV lift systems
- Air mattresses with pumps as part of the product package
- Adjustable storage unit
- Massage chair
Stakeholders should be aware that furniture incorporating springs or gas springs (e.g. office chairs) will remain outside of the scope of the Machinery Directive because the mechanism is not powered, except by manual application.
European Directives are the legal basis for CE marking, which aim to promote and harmonize the requirements for free trade within the EU – a product with a CE Mark has free movement for the purposes of trade within all the countries of the European Economic Area (EEA). The CE mark is a demonstration that the product has been assessed before being placed on the EU market and satisfies the legal requirements to be sold within the EU.
Responsibility for gaining the CE Mark rests with whoever first places the product onto the market in the EU.
Furniture manufacturers have traditionally only considered the scope of the General Product Safety Directive (GPSD), which does not require CE marking. However, with the inclusion of furniture with an electrical function in the new guidance for the Machinery Directive, this form of furniture does now require CE marking. Stakeholders should be aware that furniture without an electrical function is still exempt from CE marking.
Self-certification and CE Marking
The usual process is:
- Identify the applicable directive
- Identify applicable standard
- Assess products against applicable directive requirements and test product to applicable standards
- Complete technical documentation relating to CE marking requirements for all applicable directives to support DoC
- Issue DoC and CE mark product
You should be aware that other directives requiring the CE mark may also apply to furniture with an electrical furniture. These include:
- Low Voltage Directive (LVD) – 2014 / 35 / EU: applies to all electrical products and equipment designed for use with a voltage rating of between 50V and 1000V for alternating current (AC) and between 75V and 1500V for direct current (DC) and whose hazards are primarily of an electrical nature
- Electrical Compatibility (EMC) is the ability of a product to operate within normal conditions in its electromagnetic energy (emissions) and offer protection (immunity) against electromagnetic energy that occurs in the environment of its intended use
- RoHS Directive – 2011/65/EU: restricts the levels of hazardous substances that can be used in the manufacture of electrical and electronic equipment
Our specialists will help you during every step of the CE marking process – from directive and standard identification to the review of technical documentation. With a global network of experts and laboratories, we have the capabilities in place to help you effectively and cost-efficiently deliver functional and compliant furniture to your target markets.
For more information, please contact:
Operation Team & Product Certification team, Hardlines