Machinery Proposal: Mandatory third party certification is a step backwards – Facts 1 & 2

12 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.


Facts 1 & 2


Are third party certified machines safer and of better quality? – NO

  • There is no data showing more accidents with 'high-risk' self-certified vs third party certified machines

  • The quality level of the machine has nothing to do with the type of conformity assessment


Do third party certified machines show better conformity? – NO

  • There is no data showing less conformity with 'high-risk' self-certified vs third party certified machines

  • Notified Bodies use the same standards as manufacturers to meet the requirements of the legislation


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.

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