End of the transition period: Twelve MRL standards lose their presumption of conformity
The transitional period for a total of twelve standards harmonized under the Machinery Directive 2006/42/EC ends on November 15, 2025. At the end of this period, the presumption of conformity that previously existed for these standards due to their listing in the EU Official Journal will no longer apply. Manufacturers must take this into account and adapt their conformity assessment accordingly.
Affected standards
Affected by the removal of the presumption of conformity are in particular
- EN 1218-1, -2 and -5 (woodworking machinery)
- EN 1417 (plastic and rubber machinery)
- EN 1501-4 (waste collection vehicles)
- EN 15700 (belt conveyors for winter sports)
- EN 16307-5 (pedestrian-propelled industrial trucks)
- EN 1915-1 (aircraft ground support equipment)
- EN 16590-1 to -4 (tractors and machinery for agriculture and forestry)
Successor standards and presumption of conformity
When new standards are published, there is usually a transitional period of around 18 months during which manufacturers can adapt their designs, technical documentation and test reports to the new state of the art. This transition period is intended to ensure the orderly integration of normative changes into the manufacturer's own conformity assessment.
Clarifying which successor standard is actually relevant for a specific product poses an initial challenge - regardless of the subsequent technical implementation of the new requirements. This can be well illustrated using the example of the EN ISO 19085-12 series of standards.
New editions now exist for some of the standards concerned, e.g. EN 1281-1:1999, such as EN ISO 19085-12:2024-12: in the field of woodworking machinery. This edition reflects the current state of the art, but has not yet been listed in the Official Journal of the European Union and therefore has no presumption of conformity. The older version EN ISO 19085-12:2021-04, on the other hand, has been withdrawn by the publisher, but remains presumptive due to its listing in the EU Official Journal.
Manufacturers are therefore well advised to already take the current 2024-12 edition into account in terms of content, but at the same time to keep in mind that the presumption of conformity continues to be based exclusively on the 2021-04 version published in the Official Journal. If the new version is applied, it must also be documented how the essential requirements of the Machinery Directive are met, as there is no presumption of conformity in this respect. This example shows how complex the interaction between versions of standards, listing in the EU Official Journal and presumption of conformity can be - and how important a systematic, technically sound assessment is. GLOBALNORM supports manufacturers in classifying these relationships in a structured manner.
Steps required to implement a standard
The following points in particular must be considered as part of the internal audit:
- Materiality test: Determine whether and to what extent technical requirements have changed.
- Editorial changes: In the case of purely structural adjustments, it is sufficient to update the documentation.
- Changed limit values or test methods: Require a new metrological or testing assessment of the product.
- New or extended safety requirements: May require design adjustments up to and including redesign or re-engineering.
All changes should be fully and comprehensibly documented in order to be able to demonstrate continued conformity with legal certainty, even if the basis of the standard has changed.
Conclusion
Standards are subject to continuous technical and regulatory adjustments. Those who recognize these developments early on and systematically integrate them into their processes reduce costs, avoid delays and ensure the long-term conformity of their products.
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Author's note
This article has been machine translated into English.
TERMS AND ABBREVIATIONS
MRL: Machinery Directive
