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Machinery compliance glossary: 30 EU and U.S. terms, and the false friends between them

Most cross-Atlantic compliance mistakes are not engineering mistakes. They are translation mistakes — a word in one system that looks like a word in the other, and is not.

An American engineer reads “Notified Body” and hears NRTL. A European reads “approved” and hears “certified”. Both are reasonable readings, both are wrong, and both cost money at the point where the machine is already built.

So this glossary is arranged in pairs rather than in definitions. Every entry gives the term, what it means in its own system, and the false friend: the nearest thing in the other system, and what breaks if you treat them as the same. Terms are alphabetical, tagged 🇪🇺 or 🇺🇸 (or 🇨🇦), and each links to the page that covers it properly.

Acceptable 🇺🇸

OSHA’s defined term for electrical equipment in a workplace. Equipment is acceptable if it is certified by a laboratory OSHA recognises; or inspected by a public authority, but only for equipment of a kind no such laboratory will handle; or — for genuinely one-off equipment — if the manufacturer determines it is safe on the basis of test data the employer keeps.

False friend: it is not a synonym for “OSHA approved”. OSHA approves nothing.

AHJ — authority having jurisdiction 🇺🇸

The person who actually signs off the installation: usually the local electrical inspector. OSHA states that local governments determine for themselves whether they accept a given certification.

False friend: satisfying OSHA and satisfying the AHJ are two different exercises, and it is the second one that decides whether your machine gets energised on Monday morning.

Annex IV 🇪🇺

The list, in the Machinery Directive, of machine categories treated as higher risk.

False friend: the most expensive one in the European system. Being on the list does not by itself require a Notified Body — if the machine is built fully to harmonised standards covering all the relevant requirements, internal control is still allowed. From 20 January 2027 the equivalent list is Annex I of the Regulation, and its Part A does force a third party regardless of standards.

ANSI B11 🇺🇸

The American series of machine safety standards. Voluntary: no federal law compels them.

False friend: an ISO 12100 risk assessment is not an ANSI B11 risk assessment. The American committee says so about its own base document, in a Foreword that declares itself not part of the requirements: complying with ISO 12100 will not assure compliance with B11.0, while the reverse is automatic.

Approved 🇺🇸

The word that carries the legal force in an American workplace: conductors and equipment are acceptable only if approved. Approved means acceptable to the authority enforcing the rule, which leads to the three branches under acceptable.

False friend: nothing is “OSHA approved” — and the obligation is addressed to the employer, not to you.

Assembly of machinery 🇪🇺

Machines or partly completed machines arranged and controlled so that they function as an integral whole for the same end are themselves a machine — with their own CE marking and their own Declaration.

False friend: a line made of individually CE-marked machines is not automatically a compliant line. The line is a new machine, and it needs its own assessment.

Authorised representative 🇪🇺

A person established in the Union holding a written mandate to perform defined tasks for a manufacturer outside the EU. Under the Regulation, drafting the technical documentation cannot be part of that mandate.

False friend: your European distributor or importer is not automatically your authorised representative — and the two roles carry different duties under different articles.

CE marking 🇪🇺

A mark the manufacturer affixes to declare the product meets all applicable EU legislation. There is no “CE certificate” and no authority issues one.

False friend: it is not a quality mark and not a certification — and it does not travel. OSHA has written that the CE mark is unrelated to the requirements for product safety in the United States.

Custom-made equipment 🇺🇸

The narrow third branch of acceptable: a single unit built for a specific customer. Repeated production of the same design for different customers does not qualify, and OSHA quotes its own rulemaking — “custom-made equipment, by its nature, is very rare.”

False friend: “every machine we build is bespoke” is a sales sentence, not this definition.

Declaration of Conformity, EU 🇪🇺

The document the manufacturer signs, with ten mandatory elements. From 2027 it must state expressly that it is issued under the sole responsibility of the manufacturer.

False friend: the American SDoC looks like the same instrument — and for the FCC it is. For OSHA it is not, and that was decided rather than overlooked.

Declaration of Incorporation 🇪🇺

What partly completed machinery travels with instead of a Declaration of Conformity — together with assembly instructions. Partly completed machinery is an assembly which is almost machinery but cannot on its own perform a specific application.

False friend: it does not carry CE marking. Builders shipping subassemblies into Europe routinely CE-mark them, which is the wrong document for the thing being shipped. And this declaration too requires a person established in the Community.

Energy isolating device 🇺🇸

Defined by OSHA as “a mechanical device that physically prevents the transmission or release of energy” — and the same definition closes with “push buttons, selector switches and other control circuit type devices are not energy isolating devices.”

False friend: interlocked guards and safety-rated stop functions, which carry a European machine through maintenance access, do not by themselves satisfy the American rule for servicing and maintenance. It is a design decision, not a procedure written afterwards.

Essential Health and Safety Requirements (EHSR) 🇪🇺

The requirements a machine must meet — Annex I of the Directive, Annex III of the Regulation. The technical file must show which requirements each standard applied actually covers, a line almost everyone omits.

False friend: there is no single American list to compare them with. The nearest thing is spread across OSHA rules, electrical standards and voluntary consensus standards, and no one document collects it.

Field evaluation / field labeling 🇺🇸

Inspection of equipment already installed, performed by a field inspection body.

False friend — and the most expensive one on this page. It is sold across Europe as the answer for one-off machines. OSHA has written that a field inspection body is not an NRTL, so its approval would not make the equipment acceptable for the purposes of the electrical subpart. It may still satisfy the local AHJ, which is a different question. Canada works differently: in Ontario a field evaluation on one sample extends to units of identical design and construction.

Harmonised standard 🇪🇺

A standard whose reference has been published in the Official Journal. Building to it gives presumption of conformity — limited to the requirements that standard covers.

False friend: no American standard produces anything similar. Certification against a UL or ANSI standard creates no presumption in Europe; and in the other direction, OSHA has written that international standards are usable only once harmonised to American requirements by a U.S. standards body.

Listed / Labeled 🇺🇸

Equipment named in a list published by an organisation OSHA recognises (listed), or bearing that organisation’s mark (labeled). Both definitions require periodic inspection of production.

False friend: a one-off machine has no production to inspect — which is precisely why the one-off route is the third branch of acceptable and not a listing.

NFPA 79 🇺🇸

The American standard for the electrical equipment of industrial machinery — the counterpart of EN 60204-1.

Two false friends. It is not incorporated by reference into OSHA’s rules, and it does not appear in OSHA’s list of appropriate test standards for the NRTL programme, where UL 508, UL 508A and UL 61010-1 do. It reaches you through the electrical code as adopted locally, and through your customer’s purchase order — which makes it no less binding in practice.

Notified Body 🇪🇺

A body designated by a Member State to carry out conformity assessment where the law requires a third party. It issues an EC type-examination certificate.

False friend: a Notified Body is not an NRTL and an NRTL is not a Notified Body. Neither designation carries into the other jurisdiction, and neither one issues a “CE certificate”, because no such document exists.

NRTL — Nationally Recognized Testing Laboratory 🇺🇸

A private laboratory OSHA has recognised as competent to test and certify products against American test standards. Around twenty are recognised, several of them European.

False friend: “UL” is one NRTL, not the category — and OSHA does not require manufacturers to have their products certified by any of them, because its authority reaches employers.

Person authorised to compile the technical file 🇪🇺

Named in the Declaration of Conformity, and required to be established in the Community.

False friend: not the same role as the economic operator established in the Union under the market surveillance regulation — two obligations, two different laws, and one does not discharge the other. Nor is it the U.S.-agent concept from FDA rules, which solves a different problem.

Placing on the market 🇪🇺

The moment a product is first made available on the EU market. It is the criterion that decides which law applies: before 20 January 2027 the Directive, after it the Regulation, with no overlap.

False friend: it is not the date of design, not the date of the order, not the date of manufacture. A machine you are quoting today for 2027 delivery is a Regulation machine.

Pre-Start Health and Safety Review 🇨🇦

An Ontario review by a professional engineer, required before certain machinery is put into service. It is triggered by features a modern European machine has as standard — light curtains, interlocked guards, devices that command a stop — and the duty sits with the owner or employer, not with you.

False friend: it is not an electrical approval, and neither one substitutes for the other. An exemption exists, and the builder can enable it by supplying the right documentation — which is worth knowing before your customer receives an unexpected bill.

SCCR — short-circuit current rating 🇺🇸

The fault current a control panel can withstand. NFPA 79 requires it on the machine nameplate, and separately requires that the fault current available at the supply not exceed it.

False friend: European practice arrives without a marked value, legitimately — the European assembly standard exempts assemblies up to 10 kA from the short-circuit verification. There is no field fix for a missing number. But a low SCCR is usually the default the UL 508A method assigns to components with no declared rating: redoing the calculation with real component data often raises it without touching the hardware.

Scope of recognition 🇺🇸

An NRTL is recognised for specific test standards and specific sites — never in general.

False friend: “certified by a recognised body” proves nothing until you know which standard and which site. A control panel certified against a Canadian standard was the subject of a written OSHA interpretation that pointed to the American standard instead. This catches the builder who did more work than average, not less.

SDoC — Supplier’s Declaration of Conformity 🇺🇸

A manufacturer’s own statement that a product complies. The FCC accepts it for radio-frequency devices.

False friend: OSHA does not. The European Commission formally asked OSHA to accept it, and OSHA declined in the Federal Register, concluding that self-declaration would not provide the high degree of protection required by the Occupational Safety and Health Act of 1970. The same instrument is therefore valid in one American regime and refused in another.

Special evaluation 🇨🇦

In Quebec, for specialised equipment or equipment produced in limited quantity, the evaluation is done at the manufacturer’s plant.

False friend: for a European builder this reverses the American pattern entirely — the evaluation happens in Europe, before shipping, rather than on the customer’s floor after delivery. It is the single most useful fact on this page for anyone shipping one-off machines to Canada.

Substantial modification 🇪🇺

A change that makes the modified machine a new machine in law, with a new assessment and a new Declaration. Under the Directive it is a matter of national guidance and is not defined in the text; the Regulation defines it in law, and its Declaration names the substantially modified machine expressly.

False friend: an American “retrofit” or “rebuild” carries no equivalent EU-wide test — and whoever performs the modification can become the manufacturer of the result.

Technical file 🇪🇺

The evidence that the machine meets the requirements. It must be capable of being assembled before the machine is placed on the market, kept available for ten years, and it need not be located in the EU nor exist permanently in physical form.

False friend: it is not “the manual and the drawings”. Under the Regulation it can extend to the source code or programming logic of safety-related software, on a reasoned request from a national authority.

Type-examination certificate, EC/EU 🇪🇺

Issued by a Notified Body where third-party assessment applies. It is the only certificate in the CE marking system.

False friend: it is not a “CE certificate”, and it does not certify the machine’s overall compliance. You still sign the Declaration, and you still hold the liability.

Utilization equipment 🇺🇸

OSHA’s category for equipment that uses electrical energy. OSHA has confirmed in writing that an industrial machine using electrical energy is utilization equipment covered by the electrical rules.

False friend: “all our components are UL listed.” The machine as a whole is the object of the requirement, not its parts — and in Ontario the regulation says expressly that approved components do not make an approved assembly.

Two systems, one machine. If a term in this list is standing between you and a shipment, send us the machine and the destination market — we will tell you which of your existing documents count as evidence there, and which have to be produced again.

Advolo C-Corp is a New York company.