Type A/B standards and presumption of conformity, Directive 2006/42/EC.

Presumption of conformity is clearly evident in the case of type C standards (specific to a group of machines). Type A and B standards are broader and may include general principles or requirements with different implementation options (leading to different levels of risk). Type B standards are usually applied as part of type C standards, and references to type C standards clearly indicate how a specific type B standard should be applied, as a type B standard may include alternative risk reduction methods that lead to different levels of risk.

If there is no Type C standard, the situation is different. In this case, each manufacturer must independently assess and decide, based on its own risk assessment, how to comply with any additional principles or requirements that may be presented in Type A or B standards. In such situations, the presumption of conformity guaranteed by the Machinery Directive may not always be fulfilled. The independent use of type B standards without the guidance provided in type C standards may require in-depth knowledge of safety to avoid incorrect decisions.

In practical situations, the manufacturer should periodically check the list of harmonised standards. If the current standard has lost its harmonised status (e.g. a revised version of the standard has been published that requires a higher level of safety), manufacturers should also adapt the design and manufacture of their machinery in accordance with the new standard if they wish to maintain the presumption of conformity.

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