Hi Ron, I agree with your assertion. A CE mark and D of C will be required in my opinion. The machinery directive gives a number of definitions for 'machinery' such as "an assembly of linked parts, at least one of which moves" & "interchangeable equipment modifying the function of a machine". For clarity and confirmation however, look at the Supply of Machinery (Safety) Regulations which transposed the directive into UK law. In Part 2 (app) 4.2 (d) it defines machinery to include "components or equipment (including slings) which allow a load to be held" or are "placed between the load and the machine" & "chains, ropes or webbing designed for lifting purposes". Although the CE mark is not the be all and end all, by ensuring it is on the equipment will also act as a starting point for ensuring suitability, safety and compliance with PUWER. Best Regards, Ian