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European Union CE Compliance for Hydraulic Equipment

Mike McDonald | August 9th, 2016

CE compliance should be thought of as your “passport” to sell your manufactured product in the European Union (EU)“CE” literally is French for “Conformite Europeanne.” If you want to export your hydraulic powered equipment into Europe, it’ll have to be CE compliant!

CE compliance requires adherence to standards for health, safety, and environment. The EU – as of writing – consists of 28 countries with a population of over 510 million people, so the market is quite large and tempting. However, failure to comply with CE standards, through random checks, could include fines, removal of your equipment from the EU marketplace (at your expense of course!), or even imprisonment.

At this juncture, I should let you know there are many “consultants” that are available and eager to take your money to guide you through CE compliance.

Pros and Cons of CE Compliance Self-certification

European Union CE Compliance for Hydraulic Equipment 1

I recently worked with a mobile equipment OEM who opted to do its own standards research, acquired applicable standards, and incorporated design changes to an existing machine sold in the U.S. This machine was modified to comply with the applicable standards as a CE prototype, then turned over to a CE compliant lab service to certify compliance. This approach saved a lot of time dealing with consultants, in which case you probably would do most of the leg-work anyway.

In the end, your compliance liability is shared by the certifying lab. The price tag was still $60K from start to finish, but the silver lining in their investment was that they can now “self-certify” going forward with their additional product line.

If you’re still reading, you must be curious about doing most of this yourself and saving some cash.

First off, there is no “list” of products that require CE conformance. You are responsible for the research on your product type to identify which standards, via “directives,” are applicable. Also, some directives can be “self-certified,” while others require a laboratory that is EU/CE affiliated to test and certify compliance from the beginning. It should be noted that even products that allow self-certification, upon completion of the prototype, must still use a lab to test that its product has met the appropriate CE standards.

Fortunately, there are websites like Export.gov that have directive lists so you can determine which topics apply to your product and whether or not you can self-certify. It’s kind of like a “pay me now” or “pay me later” type of scheme, but the “pay me now” is much more expensive on the front end. It has been said by others that the EU governing commissions writes standards on how to brush your teeth! This, of course, is an exaggeration, but be prepared, there may be many standards to read through before ultimately dealing with the compliance process.

Obtaining CE Compliant Hydraulic Standards

An example directive most hydraulic powered machinery would need to comply with is “safety of machinery” and maybe “electromagnetic compatibility (EMC).” After going to these directives, they take you through nine phases of inquiry as you develop the scope of work required to make your product CE compliant.

  • Phase 1: Does the Safety of Machinery Directive apply to your product?
  • Phase 2: Check to see if your product is listed in Annex IV of the Safety of Machinery Directive.
  • Phase 3: Overview of CE marking requirements for the Safety of Machinery Directive.
  • Phase 4: Identify the European Standards for the Machinery Directive that applies to your product.
  • Phase 5: Meet the appropriate Essential Health and Safety requirements (EHSR’s) and establish a Quality Control System.
  • Phase 6: Assemble a Technical file.
  • Phase 7: Affix the CE Marking to your product.
  • Phase 8: Create the Declaration of conformity.
  • Phase 9: Keep Posted on updates of Standards which might affect your product.

Many of these phases, including 1 and 2, will direct you to lists of specific machinery with specific standards required to meet the safety of machinery directive. And, yes, in turn, these specific machinery standards may direct you to even more standards that are applicable.

My customer and I used BSIgroup.com to purchase applicable published standards like the very general “BS EN ISO 4413:2010” “Hydraulic fluid power-General rules and safety requirements for systems and their components” and BS EN 1915-1:2013 “Basic Safety Requirements.” These standards would be a good starting point to help you understand what will be required to make your product’s hydraulic system CE compliant.

My customer found a few surprises, but for the most part, the standards follow universally accepted fluid power system design standards. Much of the preparation is drilling through general lists, which lead to more specific machinery listings, and then determining which standards you will need to purchase. More than likely, there will be more standards in addition to the hydraulic system standards that deal with your specific equipment. An example cost of standards like these ranges from $152 to $212 each. You may end up with 10 or more standards to meet on a particular product.

Hard Work Pays Off

When you have a machine that conforms to the proper standards and has obtained a certificate from a lab to prove conformance, you can affix that coveted “CE” marking on your machine. Unfortunately, it often does not end there. A “declaration of conformity”, complete with a company official’s signature, must be included with each machine shipped into the EU. There are “technical files” required that you must maintain that prove conformity and can be inspected by EU officials at a moment’s notice. It is also a CE requirement to stay in conformance with the relevant standards as they are updated, including any new standards written which apply to your machine.

Access to a very large marketplace with your CE passport is the reward for all your hard work. Here’s hoping that your CE experience was both manageable, educational, and rewarding, with those new sales dollars rolling in!

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