declaration of conformity or declaration of the manufacturer?

[Messerschmitt]

in my company we have to realize and install a hydraulic drive system. the part of our competence includes carpenters, mechanical parts, control units and hydraulic actuators, carpenters installation and installation of the hydraulic system.
remain out of our supply electrical and control systems, including all sensors: without these plants our part obviously does not move. If you want, by direct current to the framework of the oleodynamic control units and manually manoeuvring the electrovalves, you can move the various paratories, but it is not an activable mode of use in practice, so as for me it does not exist precisely.
In my view, for such a system of machinery, which as well as the delivery we will lack fundamental parts for the operation, we must not provide the declaration of conformity (Annex I to the old directive) but the declaration of the manufacturer (Annex I(b)). Is such an interpretation correct?
Are there any major differences between the new and old machine directive?

 

[gerod]

differences?
the old does not exist anymore and from today also in Italy vige d.lgs. 17/2010.
therefore there is no declaration of the manufacturer.
I call on you to give an eye to the new directive and perhaps the definitions.
I remind you to read well the definition of "machine" or as a system of organs of which at least one mobile equipped or predisposed for drive systems!
I would say that if you sell a car without a motor you are still in the field of application of the "machines".
even if you don't provide the electric picture because your machine is ready to...

in other forums/blogs I discussed it with illustrious colleagues and I must say that definitions are interpretable. from one eye to the guidelines on the new directive (I am in English).
so on two feet it is not easy to give an opinion and generally an opinion given on the forum is passible of error because you do not touch with hand the object!

 

[Messerschmitt]

I immediately unload the new directive then... so I take a little forward on how much I will see at the Monday course.

the thing that does not return to me is that the electrical part, which is not of our supply, defines the logic of operation and the interface with the user. if it is done badly, it can generate dangerous situations, or can put under stress the mechanical part. then, if there is no user interface, what do I write in the manual about it?

By the way, moat or madness?