Machinery Directive is changing...

Directive 2006/42 goes to Regulation 2023/1320 from 20.01.2027 with immediate effect…

Directive - 2006/42 - EN - Machinery Directive - EUR-Lex

1.5.7.   Explosion

Machinery must be designed and constructed in such a way as to avoid any risk of explosion posed by the machinery itself or by gases, liquids, dust, vapours or other substances produced or used by the machinery.

Machinery must comply, as far as the risk of explosion due to its use in a potentially explosive atmosphere is concerned, with the provisions of the specific Community Directives.

Regulation - 2023/1230 - EN - EUR-Lex

1.5.7.   Explosion

Machinery or related products shall be designed and constructed in such a way as to avoid any risk of explosion presented by the machinery or related product itself or by gases, liquids, dust, vapours or other substances produced or used by the machinery or related product.

Machinery or related products shall comply, as far as the risk of explosion due to its use in a potentially explosive atmosphere is concerned, with the provisions of the specific Union harmonisation legislation.

So the Assessment

Aspect	2006/42/EC – Machinery Directive	(EU) 2023/1230 – Machinery Regulation	Change
Legal form	Directive	Regulation	Major (direct applicability)
Annex	Annex I – Essential Health and Safety Requirements (EHSR)	Annex III – Essential Health and Safety Requirements	Renumbered annex
Explosion clause	1.5.7 Explosion	1.5.7 Explosion	Numbering remained
Section title	Explosion	Explosion	No change

Key point:

The explosion requirement keeps the same internal numbering (1.5.7), deliberately preserving continuity for manufacturers, notified bodies, and compliance engineers.

Textual comparison – clause by clause

First sentence (risk of explosion)

2006/42/EC	(EU) 2023/1230	Assessment
"Machinery must be designed and constructed…"	"Machinery or related products shall be designed and constructed…"	Scope expanded
"…risk of explosion posed by the machinery itself…"	"…risk of explosion presented by the machinery or related product itself…"	Editorial + scope
"…or by gases, liquids, dust, vapours or other substances produced or used by the machinery."	Same wording, extended to "related product"	No technical change

Engineering meaning

• Explosion protection against internal sources (hot surfaces, sparks, friction, static, reactions) remains mandatory
• Dust, vapours, gases still explicitly covered
• No relaxation or simplification

Second sentence (use in potentially explosive atmosphere)

2006/42/EC	(EU) 2023/1230	Assessment
"specific Community Directives"	"specific Union harmonisation legislation"	Legal modernisation
"due to its use in a potentially explosive atmosphere"	Same wording	No change

Engineering meaning

• Machinery used in Ex zones must comply with ATEX/other Ex legislation
• Machinery Regulation does NOT replace ATEX
• Confirms dual compliance obligation

Terminology evolution – why it matters

Community → Union harmonisation legislation

Old term	New term	Practical consequence
Community Directives	Union harmonisation legislation	Covers Regulations + Directives
ATEX Directive 94/9/EC	ATEX Directive 2014/34/EU	Explicitly included
Future Ex regulations	Automatically included	Future-proofing

The Regulation anticipates future ATEX-like legislation without needing amendment.

Scope expansion: "machinery OR related products"

This is one of the most important changes. What are "related products"?

• Safety components
• Interchangeable equipment
• Digital / control elements affecting ignition risk
• Accessories influencing explosive behaviour

Explosion protection impact

• Explosion risk assessment now explicitly applies beyond classic "machines".
• Avoids gaps where parts that could cause ignition were previously not assessed for Ex risks
• Aligns with modern modular machinery design.

Compliance logic – unchanged but reinforced

Few point that remains exactly the same: Machinery must not create an explosion risk itself. If used in a potentially explosive atmosphere, ATEX Directive applies with immediate effect. Machinery Regulation does NOT grant ATEX compliance.

BUT reinforced for legal clarity, broader scope, direct enforceability (no national transposition).

Practical Ex-engineering interpretation

Topic	2006/42/EC	(EU) 2023/1230
Internal explosion risk	Mandatory	Mandatory
External Ex atmosphere	ATEX required	ATEX required
Dust ignition	Explicit	Explicit
Static electricity	Implicit	Implicit
Hybrid machinery	Grey area	Clearly included
Legal enforceability	National transposition	Directly applicable EU-wide

One-sentence executive conclusion

The explosion protection requirement (1.5.7) remains technically unchanged, but the Machinery Regulation (EU) 2023/1230 strengthens it legally by expanding scope, modernising references, and ensuring direct, uniform enforcement—while fully preserving the ATEX interface.

Manufacturer vs End-User Responsibility Matrix

Explosion Protection (Machinery Context)

Design & Engineering Phase

Topic	Manufacturer	End-User
Explosion risk generated by machinery itself	Full responsibility	None
Identification of ignition sources (hot surfaces, sparks, friction, static, reactions)	Mandatory	None
Dust, gas, vapour generation by machinery	Must be assessed and controlled	None
Internal explosion prevention measures	Mandatory	None
Selection of suitable materials to avoid ignition	Mandatory	None
Machinery risk assessment (Machinery Reg.)	Mandatory	None
Definition of limits of use	Mandatory	None

Key rule: The manufacturer is responsible for all explosion risks originating from the machinery itself, regardless of where it is installed.

Use in Potentially Explosive Atmospheres

Topic	Manufacturer	End-User
Declaring whether machinery is intended for Ex use	Mandatory	None
ATEX equipment compliance (if intended for Ex zones)	Mandatory	None
ATEX marking (II 2G, II 3D, etc.)	Mandatory	None
Equipment Protection Level (EPL) definition	Mandatory	None
Installation environment definition (zones)	None	Mandatory
Zone classification (0/1/2 – 20/21/22)	None	Mandatory
Matching machinery category to zone	Advisory only	Mandatory

Key rule: ATEX applies only when machinery is intended for Ex atmospheres, but zone definition is always the end-user's duty.

Documentation & Information

Topic	Manufacturer	End-User
Explosion-related design assumptions	Must be documented	None
Residual explosion risks	Must be declared	Must consider
Instructions for safe installation	Mandatory	Must follow
Instructions for operation & maintenance	Mandatory	Must follow
Limits of use (non-Ex / Ex restrictions)	Mandatory	Must respect
Declaration of Conformity	Mandatory	None
Explosion Protection Document (EPD)	None	Mandatory

Installation & Commissioning

Topic	Manufacturer	End-User
Correct installation concept	Must define	None
Installation according to Ex rules	Advisory	Mandatory
Grounding / bonding implementation	Advisory	Mandatory
Verification before first use	None	Mandatory
Compliance with ATEX 1999/92/EC	None	Mandatory

Important: Even ATEX-certified machinery can become non-compliant if installed incorrectly.

Operation, Maintenance & Modifications

Topic	Manufacturer	End-User
Safe operation concept	Must define	Must implement
Maintenance intervals	Must specify	Must perform
Spare parts specification	Must define	None
Use of non-original parts	No responsibility	Full responsibility
Modifications / upgrades	No responsibility	Full responsibility
Re-assessment after modification	None	Mandatory
Maintaining ATEX integrity	None	Mandatory

Golden rule:

The moment the end-user modifies the machinery, they assume manufacturer-level responsibility for explosion risks.

Legal Liability Summary

Scenario	Responsible Party
Explosion caused by machinery design flaw	Manufacturer
Explosion caused by incorrect zone classification	End-User
Explosion due to misuse outside defined limits	End-User
Explosion due to missing ATEX certification	Manufacturer
Explosion after unauthorized modification	End-User
Explosion due to missing EPD	End-User

Executive One-Line Rule

The manufacturer controls explosion risks created by the machine; the end-user controls explosion risks created by the environment and its operation.

Keep up the good work!

Arpad
veress@exprofessional.com