PED 2014/68/EU Directive & European In-Service Regulations
While European Directive 2014/68/EU (PED) harmonises how manufacturers design, test, and CE-certify pressure equipment across the EU Single Market, national Member State laws independently govern operational in-service use: mandatory pre-commissioning examinations, periodic recertification, and strict employer liability.
The Distinction Between Manufacturing (OEM) and In-Service Operation (Employer)
A widespread misconception among buyers and fleet managers is that a CE mark on a high-pressure steam trailer guarantees the machine is “ready to operate legally without further requirements”. European law strictly separates the manufacturing phase from in-service deployment:
Manufacturer Conformity
The manufacturer guarantees the equipment meets European essential safety requirements (Annex I). For Category IV assemblies, this requires supervision by an accredited Notified Body (NoBo) and affixing the CE mark with the 4-digit NoBo identification. Once the machine is delivered, the OEM’s legal obligations cease regarding operational permits and in-service audits.
Employer Operational Strict Liability
As soon as the equipment is put into operation on job sites, national occupational health & safety acts place strict liability on the employer. OEM user manuals universally contain legal clauses stating the buyer is solely responsible for commissioning audits and recurrent recertifications.
Major European Jurisdictions Compared
Germany: Betriebssicherheitsverordnung (BetrSichV) & TRBS Standards
BetrSichV Anhang 2 Abschnitt 4 • TRBS 1201 / TRBS 1203TÜV SÜD, TÜV Rheinland, TÜV NORD, DEKRA, GTÜ.
Mandatory on-site examination by ZÜS prior to first commercial operation.
Äußere Prüfung (12 months), Innere Prüfung (max 36 months), and hydrostatic tests.
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