Use of LCD for Point 5.1 of Annex I of the EU Lifts Directive

Use of LCD for Point 5.1 of Annex I of the EU Lifts Directive

ID 21579 | 26.03.2024

Use of LCD for Point 5.1 of Annex I of the EU Lifts Directive - Document date: 16/12/2022 - Created by GROW.01.DIR - Publication date: 22/03/2024

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Dear chairman of the ADCO Lifts, Dear Mr Achillides,

After discussions at various occasions, you had invited the European Commission to clarify its views concerning the use of display technology (“LCDs”) instead of a “traditional” plate inside the lift car to indicate the rated load in kilograms and the maximum number of passengers that may be carried, in addition to any other markings. With this letter, we would like to respond to your request.

In our view, the use of LCDs is not prohibited by the wording of Directive 2014/33/EU (“the Lifts Directive”), provided that the technology allows for markings to be “visibly, legibly and indelibly” affixed to the lift car at all times during the lifetime of the lift. It is up to the manufacturer to ensure that its technological solution satisfies these requirements. We elaborate below.

The question originates from Point 5.1 of Annex I on the Essential Health and Safety Requirements of the Lifts Directive which requires that the rated load and maximum number of passengers are indicated in each car on “an easily visible plate.”

Furthermore, Point 5.1 refers to Directive 2006/42/EC (“Machinery Directive”) stating that the previously mentioned information should be provided “in addition to the minimum particulars required for any machine pursuant to 1.7.3 of Annex I to the Machinery Directive 2006/42/EC.”

Point 1.7.3 of Annex I to the Machinery Directive 2006/42/EC provides that “all machinery must be marked visibly, legibly and indelibly the following minimum particular:

- the business name and full address of the manufacturer and, where applicable, his authorised representative,
- designation of the machinery,
- the CE Marking (see Annex III),
- designation of series or type,
- serial number, if any,
- the year of construction, that is the year in which the manufacturing process is completed” (emphasis added).

It is a long-standing principle of EU product legislation that the essential requirements define the results to be attained but do not specify the technical solutions for doing so. This flexibility allows manufacturers to choose the way to meet the requirements. It allows also that, for instance, the materials and product design may be adapted to technological progress.

For this reason, it is the Commission’s view that the word “plate” in Point 5.1 of Annex I on the Essential Health and Safety Requirements of the Lifts Directive can include LCD displays as long as the resulting markings are “visibly, legibly and indelibly” affixed to the lift car.

In particular, the word of “indelibly” suggests that it must be a permanent indication that cannot disappear due to an electronical failure, power outage or effaced over the lifetime of the lift car. As is the case for all essential requirements, it is the manufacturer’s responsibility to ensure that the LCD display markings comply with these factual requirements for the markings.

Mehdi HOCINE
Head of Unit

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Fonte: CE

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