Marking of Cranes, Hooks and Hook Blocks considering European Legislation / FEM 2022
ID 21424 | 24.02.2024 / Document FEM CLE N 0371 Frankfurt, 24.03.2022
FEM CLE: Marking of Cranes, Hooks and Hook Blocks considering European Legislation
This position paper aims to provide guidance on how to correctly mark cranes, hooks, hook blocks.
1. Introduction
In the market today, several different ways of marking hooks and hook blocks can be observed. Some of these markings are not compliant with EU legislation, especially the Machinery Directive (2006/42/EC), thus creating confusion and uncertainty amongst crane customers and other market participants.
This position paper aims to provide guidance on how to correctly mark cranes, hooks, hook blocks. (1)
2. Marking of cranes
Cranes incorporating hook and hook blocks fall under the scope of the Machinery Directive (see Article 1 (a) machinery) and therefore must be CE marked in accordance with the rules of the MD and pursuant to Article 5. The responsibility of the CE Declaration and Proof of competence is on the manufacturer of the crane as a complete.
Cranes shall be CE marked!
3. Marking of hooks and hook blocks
Hooks and hook blocks are often built according to standards. Typical standards include DIN 15401, DIN 15402, DIN 15404 (Marking) or BS 2903 (withdrawn). Proof of competence for the hook should be made according to EN 13001-3-5 (Limit states and proof of competence of forged hooks) taking into account the applicable product standard and manufacturer provisions, according to the specific application into equipment also covering the hook block as an assembly including hook. In these standards the correct hook marking is clearly defined.
According to the Blue Guide, a "product may not be CE marked, unless it is covered by a Union harmonisation legislation providing for its affixing", CE marking is not specified for hooks in the Machinery Directive or another directive. Hook and hook block form part of the crane, as without hook and hook block the crane cannot perform a specific operation. Hook and hook block are not separate items in the scope of the MD. This has also been clarified by the Commission in § 43 of the MD Guide Version 2.2:
"Lifting machinery usually has a device for holding the load such as, for example, a hook. Such load holding devices incorporated into lifting machinery are not to be considered as lifting accessories."
According to Article 17 paragraph 1 affixing CE marking to products not covered by the MD leads to non-conformity.
Hooks and hook blocks are therefore components of the crane and should not be CE marked! CE Marking of hooks and hook blocks leads to non-compliance!
CE Marking and related Declaration of Conformity (DoC) issuing is of importance not only to the common market, where it is legally binding, but also to export markets, where it is taken as a technical safety assurance and contractual document even if it is not legally required in such countries. Therefore, incorrect marking can lead to disturbances and contractual issues.
In order to correctly assess the safety and reliability of hooks and hook blocks, manufacturers may issue own certification different from the DoC, and any relevant certificates, proofs or similar documents according to the standards.
(1) It should be noted that lifting accessories are placed between the machine (i. e. the hook in case of a crane) and the load and are not permanently attached to the crane. For this reason, they are also referred to as "under hook accessories" or "non-fixed load lifting accessories". In the Machinery Directive, lifting accessories are also designated by the term ‘machinery’ – used in the broad sense – and fall under the scope of the Machinery Directive (see Article 1 (1) (d). Lifting Accessories shall be CE marked!
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