Last edit: 03/08/2023
THE DOUBT:
My Machine will be installed in Zone 2 (22). Do I need to involve a Notified Body?
CONSIDERATIONS:
Here what the ATEX Directive 2014/35/EU states regarding the CE Marking of the machine:
[2014/35/EU] Article 13 – Conformity assessment procedures
- The procedures to be followed for assessing the conformity of equipment and, where necessary, the devices referred to in point (b) of Article 1(1) shall be as follows:
[…]
- for equipment-group II, equipment category 3, internal production control set out in Annex VIII;
Equipment-group II means machineries that are not for use in mines, therefore the Machine in our example..
Equipment Category 3 means that they are installed in Zone 2 (22).
The internal production control is a manufacturer self-declaration, what the manufacturer is used to do, when he complies with the Machinery Directive. Here the language from the Directive:
[2014/35/EU] ANNEX VIII – MODULE A: INTERNAL PRODUCTION CONTROL
- Internal production control is the conformity assessment procedure whereby the manufacturer fulfils the obligations laid down in points 2, 3 and 4, and ensures and declares on his sole responsibility that the products concerned satisfy the requirements of this Directive that apply to them.
CONCLUSIONS:
If your Machinery will be installed in a Zone 2 (22), you need to CE Mark it not only according to the Machinery and EMC Directive, but to the ATEX 2014/35/EU Directive as well. During the risk assessment, you need consider all aspects related to potential sources of ignition given by your product. The components used, like Motors and Solenoid valves must be properly CE marked for the same ATEX directive. Once you are confident to have considered all possible risks and properly reduced then, you can CE Mark your Machinery according to the 2014/35/EU without the involvement of any Notified Body. Please notice that the same approach was followed by the manufacturers of the Motors and the Solenoid Valves: a self declaration.