Machinery Proposal: Mandatory third party certification is a step backwards – Fact 3

19 October 2021

The mandatory third-party certificati...

The mandatory third-party certification on so-called "high-risk" machines is unjustified and disproportionate

In this series of four articles, we will provide 7 facts that demonstrate why some of the supporting arguments mentioned in the European Commission Impact Assessment are unjustified and disproportionate.

Today, when harmonised standards cover all relevant essential health and safety requirements, manufacturers of so-called 'high-risk' machinery can either self-assess conformity or use a third party (known as a 'Notified Body') to do so.

The proposed new Machinery Regulation removes the self-certification possibility, making third party certification mandatory for all machinery products listed in Annex I.

However, the supporting arguments in the European Commission Impact Assessment mainly rely on subjective assumptions not confirmed by any data, and an incomplete measurement of the effects. The proposal is therefore unjustified and disproportionate, as demonstrated below.


Fact 3


Does the cost of third party certification only represent 1% of the total machine price as argued by the Impact Assessment? ​​​​​​​ – NO​​​​​​​

  • The 1% estimation does not cover the additional cost of resources, logistics, planning, or the additional lead time (10-15 weeks, or more depending on availability and resources at test houses)

  • The increased time-to-market delay would have a detrimental impact, especially for machines produced in series and for seasonal use

  • In some industry sectors, the cost of an EC type certification process can range between €10,000 and €40,000, depending on the choice of Notified Body

  • For OEMs that offer tailored solutions (e.g. switchboards tailored to individual customer requests) the cost can reach between 5% and 40% of the value of the machine

  • There is the risk of an accumulation of several assessment procedures before the product is assembled as a safely functioning whole


Access here the list of seven arguments supporting our views that the mandatory third party certification of the so-called "high-risk" machines is unjustified and disproportionate.