Posted By Kevin Fitzgerald Dear Colleagues, I have a piece of equipment that was manufactured pre 1995 and does not carry a CE mark. Am I required to have it CE marked if it pre dates the original machinery directive? Any help is appreciated? Kevin.

Posted By Ron Hunter Depends whether you want to supply on to others, where the item is (which country) and other variables. This link might help: http://www.netinform.net.../DG/ped_en/bg_2_3_en.htm

Posted By Heather Collins Sorry JGRL I disagree. Making a machine run faster is not a suufficient mod to require CE certification on a machine that did not previously have it. The main legislation applying here would be PUWER, which would require a risk assessment. The previous poster is also quite right that it DOES depend on where the machine is now. If an old machine with no CE mark is imported into the EEA for the first time, it DOES require CE marking and all the other relevant legal requirements as though it were new.

Posted By Heather Collins No Ron, I think what you said was 100% correct but I was trying to be polite....

Posted By JGRL Heather, You are correct in saying that when a machine enters the EU for the first time that it would need to be CE marked whether old or new. I didn't suggest otherwise. However, when a machine that has been overhauled or reconditioned outside must be regarded as being placed on the market and put into service for the first time, therefore CE marking and EC decleration of conformity applies. The point at which the machine becomes 'new' depends on the particular circumstances of each case but in the opinion of the UK authorities it becomes new if the reconditioning changes the specification of the product, the nature of the hazards or increases the levels of risk associated with machinery. Clearly, a machine that runs faster or functions differently can change the nature of the hazards. So, I disagree with you on that one. If the machine in question here is reconditioned and is moved on then CE marking does apply and the machine is treated as new. If not, then PUWER 98 applies. Regards

Posted By Mitch I would check the specifics of your 3) 'significant' alteration or refurbishment comes to mind. As to your last request in my experience there is no good guidance or summaries available in CE marking

Posted By Heather Collins Actually JGRL you did disagree with the point about machinery coming from outside the EEA. Ron made the point in his original response that it depended what country the machine was in and you said he was "100% wrong"! With regard to increasing the speed of a machine requiring a review of CE marking. It's clearly incorrect to say that this will always be the case. I agree that there MAY be circumstances under which this MAY change the functioning of the machine sufficiently to require a review of the CE requirements but I would suggest that as the guarding is likely to remain the same, this is not generally likely to require any such thing. As an example, we recently had a number of machines refurbished to increase their efficiency by increasing their operating speed. This did not in any way change the original safety functionality and so there were no requirements relating to CE marking. Even the PUWER re-assessment was only minor. I think we sometimes get far too hung up on whether a CE mark is needed or not and forget that the most important issue is whether the machine is actually safe to use. Believe me, a CE mark is no guarantee of that!

Posted By Heather Collins Kate The ESRs come into play at the same time as the requirement for CE marking. Any transitional provisions that did not require full compliance have long since ceased to apply. If the Regs apply under the particular circumstances then they apply in total.

Posted By Heather Collins http://www.opsi.gov.uk/S...2/Uksi_19923073_en_1.htm

Posted By Mike Draper You can get all of the DTI publications for machinery on free download at: http://www.dti.gov.uk/in.../strdpubs/page12289.html For other product directives start here: http://www.dti.gov.uk/in.../strdpubs/page10946.html