Machinery

Markings

In addition to technical requirements, the Machinery Decree sets requirements for markings of machinery. Each machine must bear certain minimum markings.

CE marking

Each machine must have a CE marking. The CE marking is marking that affirms that the machinery’s manufacturer or authorised representative ensures that the machinery is in compliance with all applicable requirements. Products equipped with a CE marking can move freely within the entire EU. The CE marking is affixed to the machinery by the manufacturer or a representative authorised by the manufacturer in writing.

The CE marking must be affixed visibly, clearly and indelibly to the machinery or to its data plate. The marking must be in the immediate vicinity of the name of the manufacturer or their authorised representative and attached with the same technique.

The method of affixing the CE marking must be such that it cannot be removed during the life cycle of the machinery, considering the foreseeable conditions of use.

Example: Consumer machines display quite a lot of CE markings affixed with a sticker. A detachable sticker that comes off easily when using the machine cannot be considered a sufficiently permanent method of attachment.

The CE marking must be at least 5 mm in height, and you are not allowed to change its dimensions. In the case of small machinery, deviations from the minimum height may be allowed.

The machinery’s EC declaration of conformity must show the EU legislation under which the CE marking is affixed. In the case of machinery specified in Annex IV of the Machinery Decree for which the quality assurance procedure approved by a notified body has been applied for demonstrating compliance, the CE marking must be followed by the four-digit identification number of the body in question.

Other markings

In addition to the CE marking, the machinery must bear several other markings specified in the Machinery Decree. These include:

• the business name and full address of the manufacturer and, where appropriate, its authorised representative
• name of the machine (e.g. cordless drill)
• designation of series or type
• serial number, if any
• year of construction

The machinery must also bear information essential for safe use.

The harmonised type C standards that are specific to a type of machinery specify the information that must be marked on each type of machinery. Example: The EN 1493 standard for car lifts specifies that in addition to the markings specified in the Machinery Decree, the car lift must be marked with the nominal load and the warning sign “No transport of persons”.

The information and warnings affixed to the machinery should preferably be presented in the form of easily understandable symbols or pictograms. Written or oral information and warnings must be in Finnish and Swedish.

Like the CE marking, other statutory markings must be affixed visibly, clearly and indelibly to the machinery.

Traceability requirements

Traceability means the ability to trace the history of a product. From the legislator’s perspective, traceability is important, because it enables effective enforcement through corrective market surveillance measures such as recall and withdrawal. With traceability, dangerous or non-compliant products can be tracked in the distribution chain, and the roles and responsibilities of economic operators can be defined in the chain. Traceability allows market surveillance authorities to trace products to the factory and in some cases, from the factory to end users.

Traceability is also important from the manufacturer’s perspective, because it allows effective supervision of the production process and suppliers before the products are placed on the market, as well as supervision of the distribution chain once the products have been placed on the market. In the event of non-compliance, manufacturers may reduce the impact of product recall procedures and withdrawals, depending on how detailed the traceability system is.

1.      Traceability information helps the manufacturer supervise the product’s distribution chain.

2.      Traceability information helps the manufacturer supervise the production process.

3.      Traceability information helps authorities target market surveillance actions at the correct products.

The traceability requirements include that manufacturers must affix at least the serial or type marking, as well as the year of manufacture to the machinery so that it can be identified. The machine can also be marked with a more accurate lot identifier so that individual machines can be traced accurately based on the lot in question.

The manufacturer is required to indicate 1) its name, 2) registered trade name or registered trademark, and 3) the address at which it can be contacted on the product itself. The manufacturer’s information is the same as that contained in the EC declaration of conformity.

Remember:

• The CE marking indicates that the machinery fulfils its requirements.
• The manufacturer affixes the CE marking themselves.
• Each machine must bear certain traceability information such as serial or type marking and the year of manufacture.
• Statutory markings must be affixed visibly, clearly and permanently to the machine. For example, an easily detachable Velcro fastener is not an acceptable way to affix the CE marking or other statutory markings.

Watch the recording of Tukes’ I Know My Product webinar: Practical use of instructions and markings for consumer-operated machines: