It's bad wording; I think it means 'placed on the market as a single
item of commerce', i.e. you can buy one or more for a stated list price.
I don't think it means 'made available to the general public'. Maybe
someone knows what the authors of the document actually meant by those
words.
On 2024-08-10 00:05, Peter Tarver wrote:
In reviewing the Machinery Regulation, Article 3 defines a safety
component as
"...means a physical or digital component, including software, of a
product within the scope of this Regulation, which is designed or
intended to fulfil (sic) a safety function and */_which is
independently placed on the market_/*, the failure or malfunction of
which endanger the safety of persons, but which is not necessary in
order for that product to function or for which normal components may
be substituted in order for that product to function;
(emphasis added.)
The component falls under Annex I, Part, B but is only sold to OEMs
1) whose equipment would clearly fall under the Regulation, and
2) who integrate the component into other equipment before that other
equipment is placed on the market, but
3) is not "independently placed on the market," for general sale,
is there any reason to conclude that the Regulation does not apply to
the component?
The product is sold into the EU for applications other than those that
would be subject to the Regulation, so it seems that applicability
could depend on the interpretation of "independently" in the context
of the regulation. Or is the use of "independently" intended to mean
"not manufactured by the OEM for their own use?"
I note that similar language existed in the Machinery Directive.
My approach is to apply an abundance of caution and presume the
Regulation applies, but I'd appreciate the input of the group.
A final couple of questions: should it be assumed that the same
standards published in the EU OJ for the Machinery Directive will
satisfy the Regulation until a separate list of standards is published
and linked to the Regulation? Also, is there a view on when such a
list will be published?
Regards,
Peter Tarver
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