Welding machine
Arc welding equipment is electrical equipment first, with its own product standard, and machinery where it is automated; the fume and radiation hazards shape the instructions.
Regimes engaged, per market
Standing when pasted with its name: mapped
What the file has to hold
- Technical file (13 of the 19 regimes, including GPSR, Machinery Reg, LVD)
The technical documentation: design, drawings, bill of materials, the standards applied, the conformity assessment route, and the evidence that the requirements are met. Kept for the retention period the regime sets, typically ten years from the last unit placed on the market. - Declaration of conformity (9 of the 19 regimes, including Machinery Reg, LVD, EMC)
The EU or UK declaration of conformity (or the food-contact declaration of compliance), signed by the manufacturer, naming the product, the legislation and the standards, and the notified or approved body where one was involved. - Risk assessment (7 of the 19 regimes, including GPSR, Machinery Reg, LVD)
The documented hazard identification and risk assessment for the product across its lifecycle, updated when the design, the use or the field data changes. - Test reports (12 of the 19 regimes, including GPSR, Machinery Reg, LVD)
Test reports from an accredited or accepted laboratory against the standards the technical file names, tied to the exact model and revision tested. - Labelling and instructions (15 of the 19 regimes, including GPSR, Machinery Reg, LVD)
Markings on the product and packaging (conformity mark, identification, warnings, manufacturer and importer details) and the instructions and safety information in the language of the market. - Traceability records (GPSR, Machinery Reg, UK GPSR, UK Machinery)
Batch, lot or serial identification on the product, the records that tie a unit to its production and supply chain, and UDI where the device rules require it. - Third-party certificate (OSHA/ANSI, UL/NRTL)
A type-examination certificate, notified or approved body certificate, or listing from a recognised laboratory, with the scope and the expiry. - FCC authorisation (FCC Part 15)
The FCC Supplier's Declaration of Conformity, or the grant of certification with the FCC ID, and the compliance statement in the manual. - Substance declarations (5 of the 19 regimes, including RoHS, REACH, UK RoHS)
Safety data sheets for mixtures and supplier material declarations for articles: the trail that shows what is in the product against the restricted lists. - Registrations (WEEE, UK WEEE)
Producer, establishment, device or product registrations in the databases the regime names (EUDAMED, EPREL, CPNP, the WEEE and battery registers, FDA registration and listing).
Duties that continue after sale
- Market surveillance cooperation (GPSR, Machinery Reg, UK GPSR, UK Machinery)
Answer an authority's request for the technical file, the declaration and the supply chain within the time it sets, in a language it accepts, and cooperate with any corrective measure it requires.
Licensed controls: GPSR Art.14, 15, 17 · GPSR Art.23, 24 · Machinery Reg Art.10 · Machinery Reg Art.43, 44 - Incident reporting (GPSR, UK GPSR)
Notify the authority when a product has caused, or could cause, an accident, injury or serious incident, through the channel the regime names (the Safety Business Gateway, the MHRA, the FDA, SaferProducts.gov) and within its clock.
Licensed controls: GPSR Art.20 · GPSR Art.25, 26, 27 - Recall readiness (GPSR, Machinery Reg, UK GPSR, UK Machinery)
Be able to identify affected units, reach the customers who hold them, issue a notice in the required form, offer the remedy the rules require, and show the authority the effectiveness of the action.
Licensed controls: GPSR Art.35 · GPSR Art.36, 37 · Machinery Reg Art.45, 46 - Traceability records (GPSR, Machinery Reg, UK GPSR, UK Machinery)
Keep the records that identify which batch went to which customer, and the identification on the product that lets a unit be traced back, for the retention period the regime sets.
Licensed controls: GPSR Art.18 · GPSR Art.9 · Machinery Reg Art.17, 18, 19 - Producer responsibility for take-back (WEEE, UK WEEE)
Keep producer registrations current in each market, report the quantities placed, and finance collection and treatment of the product and its batteries at end of life. - Substance list watching (5 of the 19 regimes, including RoHS, REACH, UK RoHS)
Track additions to the restricted and candidate substance lists, re-check supplier declarations against them, and update customer communication and labels when a substance in the product is added.
This week
Confirm the product standard named on the declaration is the arc welding equipment standard and not a generic one.
What holding one is evidence for
Requirement text and evidence artefacts from a human-verified corpus. Data licensed to Conformity Sheet by The Art of Service Pty Ltd, revocable, non-transferable.
GPSR: EU General Product Safety Regulation (Regulation (EU) 2023/988)
GPSR Art.9 Obligations of manufacturers (Article 9)Article 9 imposes the central manufacturer obligations: (a) carry out internal risk analysis and draw up technical documentation containing the analysis + identification of relevant European standards or risk-assessment elements (kept for 10 years); (b) place safe products on the market that comply with Article 5 + Art...
Common gap: Product placed on market without Article 9(2) risk analysis + technical documentation
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.5, 6, 7, 8 General safety requirement and assessment criteria (Articles 5-8)Article 5 establishes the general safety requirement: economic operators shall place or make available on the market only safe products. Article 6 sets the criteria for assessing safety: the characteristics of the product including its composition, packaging, instructions for assembly and, where applicable, installatio...
Common gap: Placing on market without an Article 6 assessment file
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.10, 11, 12 Authorised representatives, importers and distributors (Articles 10-12)Article 10 governs authorised representatives (written mandate; tasks include keeping the EU declaration / technical documentation available for 10 years + cooperation with market surveillance). Article 11 sets importer obligations: place safe products + verify Article 9 manufacturer compliance + place importer identit...
Common gap: Non-EU manufacturer placing products without an authorised representative + responsible person in the Union (Article 16)
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
GPSR Art.13, 16 Cases where manufacturer obligations apply to other persons + responsible person in the Union (Articles 13 and 16)Article 13 provides that an importer, distributor or other economic operator is considered to be a manufacturer + subject to Article 9 obligations where the operator places on the market under its own name or trademark, modifies the product in a way that may affect compliance with Article 5, or carries out other Articl...
Common gap: Non-EU manufacturer placing products on the Union market without an Article 16 responsible person
EU General Product Safety Regulation (GPSR, Regulation 2023/988) on compliance.theartofservice.com
Machinery Reg: EU Machinery Regulation (Regulation (EU) 2023/1230)
Machinery Reg Art.10 Obligations of manufacturers of machinery and related products (Article 10)Article 10 imposes the central manufacturer obligations: (a) ensure the EHSR Annex III compliance + carry out risk assessment per Annex III 1; (b) draw up the technical documentation per Annex IV + retain for 10 years; (c) carry out the applicable conformity assessment procedure (Article 25); (d) draw up the EU declara...
Common gap: Machine placed without Annex IV technical documentation
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.8, 9 Essential health and safety requirements and sectoral coordination (Articles 8-9 + Annex III)Article 8 imposes the central requirement: machinery and related products placed on the market or put into service shall comply with the essential health and safety requirements (EHSR) set out in Annex III. Annex III covers: 1.1 general principles of safety integration (eliminate / reduce / inform), 1.1.9 protection ag...
Common gap: Product placed without Annex III EHSR compliance file
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.21, 22 EU declaration of conformity and EU declaration of incorporation (Articles 21-22)Article 21 requires the manufacturer to draw up the EU declaration of conformity per Annex V before placing on the market or putting into service. By drawing up the EU DoC the manufacturer assumes responsibility for compliance. The EU DoC is kept for 10 years. Article 22 sets the EU declaration of incorporation for par...
Common gap: Machine placed without EU DoC
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.23, 24 CE marking principles and affixing rules (Articles 23-24)Article 23 applies the general principles of the CE marking per Regulation (EC) 765/2008 to machinery. Article 24 sets the affixing rules: CE marking visible, legible, indelible, affixed before placing on the market; for high-risk products subject to Annex I requiring notified-body assessment, the NB identification num...
Common gap: CE marking on partly completed machinery
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.25 Conformity assessment procedures (Article 25)Article 25 sets the conformity assessment routes. (1) Default (non-Annex-I): manufacturer self-assessment via Annex VIII (internal production control) + Annex IV technical documentation. (2) Annex I high-risk products: mandatory third-party involvement. The manufacturer chooses among Annex IX (EU type-examination + pro...
Common gap: Annex I (Class B) product self-declared without notified-body involvement
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
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