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Interpretation Paper "Substantial Modification to Machinery"

Interpretation of the term "substantial modification to machinery"

Here you will receive information that represents an interpretation of the term "substantial modification to machinery" with regard to the application of the Machinery Directive to modified machinery.

In the case of modifications or modernisations, it is often necessary to make extensive modifications to machinery in order to adapt them to the current state of the art. For example, the machinery is equipped with new, more powerful drives and/or protective devices or with new control software. The question arises whether these changes are so far-reaching that one has to consider it a new machine then. If these changes are substantial, this newly created machine is also subject to today's requirements for placing it on the market.

The interpretation paper has been prepared by a working group under the aegis of the Federal Ministry of Labour and Social Affairs (BMAS), with the participation of the Federal Institute for Occupational Safety and Health (BAuA), the Ministry of the Environment, Climate Protection and the Energy Sector of the State of Baden-Württemberg as representative of the Federal States for the EC Machinery Directive 2006/42/EC (MRL) in consultation with the market surveillance authorities of the Federal States, the German Statutory Accident Insurance (DGUV), the individual accident insurance fund, the German Engineering Federation (VDMA) and VGB PowerTech e.V. as a specialist association for electricity and heat generation.

It has been published as an official notification (notification of the BMAS of 9 April 2015, IIIb5-39607-3) in the Joint Ministerial bulletin GMBl 2015, page 183