Machinery Proposal: Mandatory third party certification is a step backwards – Facts 6 & 7

2 November 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 6 & 7


Would mandatory third party certification undermine the harmonised standard system?  YES

  • There will be no added value for manufacturers to conform to the standard, resulting in increased divergences between products

  • Industry experts will have no market motivation to produce standards, which will result in lower technical quality and decreased market relevance of new standards

  • Mandatory third party certification would be a return to the concept of external control, an approach which was popular in the 1980’s. Since then, European legislation has evolved in the direction of greater responsibility for the manufacturer


Does third party certification support SMEs?  NO

  • SMEs want to retain the business choice to self-assess or use a Notified Body according to their business needs and resources 


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.