With electrical furniture now being identified as coming under the scope of the EU Machinery Directive, international inspection, verification, testing and certification specialist SGS explains the CE marking requirements that manufacturers of electrical furniture should be aware of …
In July 2017, new guidance for the application of the EU’s Machinery Directive 2006/42/EC was published. This resulted in electrically-actuated motorised domestic furniture being identified as coming under the scope of the directive – meaning electrical furniture must now carry the CE mark to access European markets.
The EU Machinery Directive 2006/42/EC was passed by the European Parliament and Council in 2006. It has been amended several times – most recently in 2017 – and essentially describes the health and safety requirements that must be applied to all machinery offered onto the EU market.
Most of the countries have recognised the 2017 guideline, but the application for some countries is still unclear.
It defines machinery 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; or an assembly of machines which, to achieve the same end, are arranged and controlled so that they function as an integral whole.
Compliance with the Machinery Directive requires the manufacturer to prepare a Technical Construction File (TCF) according to Annex VII of 2006/42/EC. This includes a construction file, comprising: 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; and a copy of the EC declaration of conformity.
Also, for series manufacture, the internal measures that will be implemented to ensure that the machinery remains in conformity with the provisions of this directive must be presented.
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 units; doors/drawers; and massage chairs.
It does not cover furniture incorporating springs or gas springs (office chairs, for example) because those mechanisms are powered manually, not electrically.
To access the European market, therefore, electrical furniture must now carry the CE mark. European Directives are the legal basis for CE marking. They are designed to promote and harmonise the requirements for free trade within the EU because 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 and satisfies the legal requirements to be sold within the EU.
The identification of electrical furniture as being under the scope of the Machinery Directive represents a major change for furniture manufacturers. Until now, they have normally only considered the scope of the General Product Safety Directive (GPSD), which does not require CE marking. The new requirement for furniture to carry the CE mark only relates to electrical furniture, and does not affect other furniture.
To self-certify for the CE mark, the usual process is to: 1. Identify the applicable directive; 2. Identify the applicable standard; 3. Assess products against applicable directive requirements and test products to applicable standards; 4. Complete technical documentation relating to CE marking requirements for all applicable directives to support the Declaration of Conformity (DoC); 5. Issue DoC and CE mark the product.
Stakeholders should also be aware that other directives requiring the CE mark may also apply to furniture with an electrical component, including: the Low Voltage Directive (LVD) – 2014 / 35 / EU, which applies to all electrical products and equipment designed for use with a voltage rating of between 50-1000V for alternating current (AC) and between 75-1500V for direct current (DC), and whose hazards are primarily of an electrical nature;
Electrical Compatibility (EMC), 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; and the RoHS Directive – 2011/65/EU, which restricts the levels of hazardous substances that can be used in the manufacture of electrical and electronic equipment.
SGS operates through a network of over 2400 offices and laboratories around the world, and can help manufacturers with every step of the CE marking process – from directive and standard identification to the review of technical documentation.