Orgalim position paper on the integration of pressure equipment into machinery

In the context of discussions in the European Commission Working Group Pressure Equipment concerning the applicable regulatory framework and the relevant conformity assessment for the integration of pressure equipment into machines, Orgalim would like to set out its views and recommendations to ensure a level playing field and the necessary legal certainty for machinery manufacturers.

The two main relevant pieces of legislation are the Pressure Equipment Directive (2014/68/EU) and the Machinery Directive (2006/42/EC); the latter will be replaced by the Machinery Regulation (EU) 2023/1230 in 2027.

According to current practice, manufacturers apply conformity assessment according to the Pressure Equipment Directive for pressure equipment. However, when integrating pressure equipment in the final machinery, manufacturers apply the conformity assessment of the Machinery Directive. Furthermore, the current legal framework has proven to be effective, and the analysis of available data reveals a downward trend of incidents. In France, no machinery accident was attributed to pressure-related issues in the last years and most nonconformities are related to administrative issues rather than safety.

Given this evidence, we call on authorities to maintain the current interpretation and market practice, which has been successfully applied for over 20 years. Changing this practice, and consequently applying procedures required by the Pressure Equipment Directive to machinery integrating pressure equipment, would not enhance health and safety. Instead, such a change will put at stake well-established assessment processes, increase the administrative burden and raise conformity costs for manufacturers without any safety benefits.

To read our recommendations in full please download the document above.