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Members Question: Declarations from Subcontractors

We have had a question from a member regarding a machine that is branded by themselves, but is being fitted with a control panel that has been designed and built by a subcontractor. They wondered whether their subcontractor was required to provide them with a Declaration of Conformity for the control panel.

There are three Directives involved with this scenario that could be considered. 

a) Machinery Directive – The panel may feature safety components (such as an emergency stop button or w safety relay) as defined under the Machinery Directive, but ultimately the end assembly does not come under the scope of this Directive. It would be important for information regarding the design and choice of safety components to be passed on to allow the manufacturer of the machine to complete a safety control system assessment.

b) The Low Voltage Directive – Potentially, the panel could fall into scope of the LVD (depending upon the voltage range and application). However, if the control panel is deemed to be a ‘component’ then it might not be covered, as the Low Voltage Directive only applies to electrical equipment / apparatus. Regardless, as to whether the control panel has been defined as a component or not by the subcontractor, they have no legal obligation to supply a copy of the Declaration of Conformity to anyone other than an enforcement authority.

c) The EMC Directive – Will not be required, as the control panel is intended to be incorporated into the end apparatus. However, it is important to note that the design of the panel and choice of components will have a bearing of whether the manufacturer can meet the EMC Directive for the machine.


If you have any questions regarding this article, or need any support with CE marking, please call us on 01527 595066.

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