PED Guidelines EN v1.6

Guidelines related to the Pressure Equipment Directive
97/23/EC (PED)
In order to ensure a coherent application of the Pressure Equipment Directive 97/23/EC (PED),
Guidelines are developed and agreed by the Commission's Working Group "Pressure" (WGP).
This working group, created as a result of Article 17 of the PED, which requests the Member
States to cooperate in order to assist the functioning of this Directive, is composed of
representatives of Member States, European federations, the Notified Bodies Forum and CEN
and chaired by a representative of the Commission services.
Remarks or questions concerning this document should be addressed via the email to the unit in
the European Commission dealing with the Pressure Equipment Directive:
[email protected]
Status of the guidelines

The PED Guidelines are not a legally binding interpretation of the Directive. The legally binding
text remains that of the Directive. However, the PED Guidelines represent a reference for
ensuring consistent application of the Directive. They represent, unless indicated differently in
the respective guideline text, the unanimous opinion of the Member States.
Classification of the guidelines
The guidelines carry a x/y type numbering. The first number (x) relates to the subject, the second
(y) is a sequential numbering. The numbers x relate to the following subjects:
1. SCOPE AND EXCLUSIONS OF THE DIRECTIVE
2. CLASSIFICATION AND CATEGORIES
3. ASSEMBLIES
4. EVALUATION ASSESSMENT PROCEDURES
5. INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON
DESIGN
MANUFACTURING
MATERIALS
8. INTERPRETATION OF OTHER ESSENTIAL SAFETY REQUIREMENTS
9. MISCELLANEOUS
10. GENERAL-HORIZONTAL QUESTIONS
Document history
Version Date Comment
1.0 1/12/2010 Includes PED Guidelines up to WGP meeting of 24/11/2010
1.1 19/7/2011 Quality check, correction of links, introduction
1.2 30/8/2011 Quality check
PED_Guidelines_EN_v1.6.doc Page 1 of 263

1. SCOPE AND EXCLUSIONS OF THE DIRECTIVE
1 SCOPE AND EXCLUSIONS OF THE DIRECTIVE
2 CLASSIFICATION AND CATEGORIES
3 ASSEMBLIES
4 EVALUATION ASSESSMENT PROCEDURES
5 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON DESIGN
6 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON

MANUFACTURING
7 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON MATERIALS
8 INTERPRETATION OF OTHER ESSENTIAL SAFETY REQUIREMENTS
9 MISCELLANEOUS
10 GENERAL-HORIZONTAL QUESTIONS

1.1. Guideline 1/1
Guideline related to: Article 3 paragraph 1.1; Article 1 paragraph 3.19; Annex II, Table 2
Question: Are portable extinguishers within the scope of the Pressure

Equipment Directive or are they covered by the exclusion in Article
1.3.19 for equipment covered by the ADR?
Answer: They are covered by the Pressure Equipment Directive.
Reason: Portable extinguishers are specifically mentioned in Article 3 paragraph

1.1.a) second indent and Annex II, Table 2 of the Pressure Equipment
Directive.
Furthermore, fire extinguishers are specifically mentioned in special

provision 594 of ADR as an exclusion when appropriately packed for
transport.
Thus, these extinguishers are not covered by the exclusion in Article 1

paragraph 3.19 of the PED.
Accepted by WPG on: 2010-09-21
Accepted by Working Group "pressure" on: 2010-11-24

1.2. Guideline 1/2
Guideline related to: Article 1 paragraph 2.1
Question: Are tanks intended for the transport of non-dangerous goods (as
defined by ADR), which are not pressurised during carriage but are
pressurised during other foreseeable operations, e.g. filling, emptying
or cleaning, within the scope of PED?
Answer: Yes. If the PS of the tank is more than 0,5 bar.
Reason: Such tanks are not excluded by Article 1 paragraph 3.19.
Note: Refer also to guidelines 1/14, 1/34 and 8/7.

1.3. Guideline 1/3
Guideline related to: Article 1, Annex I section 3.4
Question: Are replacements, repairs or modifications of pressure equipment in

use covered by the Pressure Equipment Directive (PED) ?
Answer: 1) Entire change: the complete replacement of an item of pressure

equipment by a new one is covered by the PED.
2) Repairs are not covered by the PED but are covered by national
regulations (if any).
3) Pressure equipment which has been subject to important modifications

that change its original characteristics, purpose and/or type after it has
been put into service has to be considered as a new product covered by the
directive. This has to be assessed on a case by case basis.
Note 1: Operating instructions in the sense of the PED (see guideline 8/3) cover
documentation concerning safe operation including maintenance, but not
necessarily detailed information concerning repair or modification of the
equipment (e.g. material certificates or qualification of welding
procedures). Such information may be provided by a specific contractual
agreement between manufacturer and user.
Note 2: The directive applies only to the first placing on the market and putting
into service.
See “blue guide” chapter 2.1

1.4. Guideline 1/4
Guideline related to: Article 1 paragraph 2.1.2
Question: When is a modification of a piping system not covered by the PED?
Answer: When the content, main purpose and safety systems remain essentially the
same, it may be regarded as a non important modification of an existing
piping system and is therefore not covered by the PED.
Reason: See Guideline 1/3

1.5. Guideline 1/5
Guideline related to: Article 3; Annex II
Question: Which conformity assessment category applies to vessel with a volume

less than or equal to 0.1 litre?
Answer:
Vessels referred to in Table in Category

Article 3 (volume less Annex II
than or equal to 0,1 litre) (Volume less than or equal to 0,1 litre)
1.1(a) first indent 1 If PS ≤ 200 bar, then Article 3.3 applies
otherwise see point 3 below
1.1(a) second indent 2 If PS ≤ 1000 bar, then Article 3.3 applies
1.1(b) first indent 3 If PS ≤ 500 bar, then Article 3.3 applies
1.1(b) second indent 4 If PS ≤ 1000 bar, then Article 3.3 applies
Reason: 1. The conformity assessment categories for vessels with a volume less
than or equal to 0,1 litre cannot be determined from Tables 1, 2, 3 and 4
because the Tables are not specified for volumes less than 0,1 litre.
However, Article 3 paragraph1 together with Article 3 paragraph 3 can be
used to determine which vessels must satisfy the essential safety
requirements and those that must be designed and manufactured according
to the Sound Engineering Practice (SEP) of a Member State.
2. If a vessel has a volume less than or equal to 0,1 litre, and a value of PS
above the limits defined in Article 3 paragraph 1, then the vessels must
satisfy the essential safety requirements of Annex I.
3. In the absence of specific information in the Tables of Annex II for the

conformity assessment of vessels described in point 2 above, the
manufacturer may choose any module‚ or single combination of modules,
set out in section 1 of Annex II.
Accepted by WPG on: 1999-04-21, editorially corrected on 2002-06-18
Accepted by Working Group “pressure” on: 1999-11-08, confirmed by WGP on 2002-10-03

1.6. Guideline 1/6
Guideline related to: Article 1 paragraph 2.1.3; Annex I point 2.10
Question: How will pressure gauges be classified?
Answer: A pressure gauge may possibly be regarded as a protective device within

the meaning of Annex I, point 2.10 b.
The Directive does take account of these items of equipment but they are
not safety accessories within the meaning of Article 1, paragraph 2.1.3.
They are pressure accessories within the meaning of Article 1, paragraph

2.1.4, which may be covered by CE marking for high pressure (cf WPG
1/5 on Article 3 on low volume-high pressure equipment).
Accepted by Working Group “pressure” on: 1999-01-28

1.7. Guideline 1/7
Guideline 1/7 has been withdrawn.

1.8. Guideline 1/8
Question: What is a pressure accessory?
Answer: According to the definition (see Article 1 Paragraph 2.1.4) pressure

accessory means a device with an operational function and having an
identifiable pressure-bearing housing - i.e. the device has a function
additional to that of containing pressure.
The pressure accessory can be attached to other pressure equipment for

example by bolting, brazing, soldering or welding. A pressure accessory
has a specific operational function (or functions), which could be for
example: measurement, change the mechanical characteristics of the fluid
flow, taking a sample, removal of sediment or gas. A pressure accessory
does not necessarily have moving parts.
Typical examples of pressure accessories are: valves, pressure regulators,

measurement chambers, pressure gauges, water gauge glasses, filters,
expansion joints and manifolds.
The following examples are not pressure accessories:
- safety valve (a safety accessory)
- cover, collar, gasket, flange, bolt (components of a pressure

equipment)
- sight glass with its frames (components of a pressure equipment)
- Y-shape or similar fittings (piping components)
Accepted by Working Group "pressure" on: 1999-01-28, editorially amended on 2005-03-16 by

WPG, confirmed on 2005-06-28 by WGP

1.9. Guideline 1/9
Question: Are piping components, such as a pipe or system of pipes, tubing,

fittings, expansion joints, hoses, or other pressure bearing
components, considered to be piping when they are placed on the
market as individual components?
Answer: Individual piping components, such as a pipe or system of pipes, tubing,

fittings, expansion bellows, hoses, or other pressure bearing components
are not “piping”.
However, a single pipe, or a system of pipes, for specific application, may

be classed as “piping”, provided all appropriate manufacturing operations
such as bending, forming, flanging and heat treatment, have been
completed. Some piping components (e.g. expansion joints) may be
considered to be pressure accessories (see Guideline 1/8).
Remark: Please note the definitions related to expansion joints and to expansion
bellows.
Expansion joints are devices containing one or more bellows used to

absorb dimensional changes such as those caused by thermal expansion or
contraction of a pipeline, duct or vessel.
Expansion bellows are flexible elements of an expansion joint consisting

of one or more convolutions and the end tangents.

1.10. Guideline 1/10
Guideline related to: Articles 1 paragraph 3.19, Article 3 paragraph 1.1 second indent
Question: Are the bottles for breathing equipment covered by the Pressure
Equipment Directive?
Answer: Bottles/gas cylinders for breathing apparatus are covered by the Pressure
Equipment Directive, for example:
- bottles/gas cylinders for compressed air, oxygen or other breathable

mixtures, such as portable cylinders for divers, fire fighters and
asbestos workers
The following bottles for breathing equipment are not in the scope of the
Pressure Equipment Directive:
- gas cylinders to be installed in oxygen/air centres of hospitals
- cryogenic receptacles
According to the circumstances of the transport, the requirements of

ADR/RID/IMDG/ICAO may also be applicable.
If the manufacturer intends bottles to be used both for breathing

equipment and also for transport of dangerous goods, they shall meet the
requirements of both directives and bear both the CE-mark and the π-
mark (see guideline 1/30).
Reason: The specific reference to bottles for breathing apparatus in Article 3 limits
the general exclusion in Article 1, section 3.19.
Furthermore the Transportable Pressure Equipment Directive (TPED)

specifically excludes gas cylinders for breathing appliances (Recital 9 and
Article 2, section 1).
Note: A breathing apparatus is a personal protective equipment and therefore

designed to be worn or held by an individual.

Question: How can article 1.3.10 more specifically be understood, especially the
wording “for which pressure is not a significant design factor”?
Answer: 1. Article 1.3.10 excludes pressurized equipment comprising casings or

machinery from the scope of the PED
a) if this equipment is primarily dimensioned for loads other than pressure,
i.e. for which pressure is not the significant design factor
and
b) if it is primarily designed to move or rotate or fulfil other functions than
pressure containment.
2. Such equipment may include

- engines including turbines and internal combustion engines;
- steam engines, gas/steam turbines, turbo-generators, compressors,
pumps, actuating devices and curing moulds for tyres.
3. For such equipment, pressure can be considered as not being a
significant factor, if other factors alone or together are more significant
than pressure. Other factors are, e.g.:
- dynamic loads with vibrations or very high number of cycles;
- thermal loads together with a complicated form of structure;
- stiffness of the structure because of external mechanical loads or
requirements related to high weight;
- requirements related to low elongation, low change of diameter or low
other deformation because of functional requirements to rigidity.
This shall be decided on a case by case basis, taking into account
established safe industrial practice.
4. An over-dimensioning as such shall not result in exclusion from the

PED with regard to article 1.3.10.
Accepted by Working Group “pressure” on: 1999-11-08, editorially amended on

2003-05-15 and confirmed on 2003-11-03
EXPLANATORY NOTES
(1) No factor is included in the requirements of the PED. Any factor given in a
guideline would therefore go beyond the PED and should be avoided.

(2) If a factor were used to decide whether the requirements of the PED are
applicable or not, overdimensioning could result in a case where pressure
equipment need not fulfil the requirements of the PED. This is not acceptable.
(3) To decide on the exception with a factor of overdimensioning would

consequently result in the necessity of a detailed stress analysis, especially if this
factor would have been connected to the primary membrane stress. This is far
beyond the present established industrial practice.
(4) Furthermore, there is a danger that the more important influences explained in
paragraphs 1 to 3 could be overlooked if the decision whether the pressure is a
significant design factor were based on a factor of overdimensioning only.

Guideline related to: Article 1 paragraphs 3.6 and 3.10
Question: Are hermetically sealed and semi-hermetic compressors in the scope

of the directive?
Answer: 1) Equipment classified as no higher than category I as defined by PED

and falling in the scope of one of the directives as listed in article 1,
paragraph 3.6, e.g. for low voltage or machinery, is excluded from the
scope of PED. This applies to hermetic and semi-hermetic compressors no
higher than category I.
2) The exclusion in article 1, paragraph 3.10 is not applicable to hermetic

compressors because pressure is a significant design factor since their
external envelope has as its principal function to ensure that the refrigerant
is confined.
3) For semi-hermetic compressors which include moving parts and for

which the external envelope is primarily designed for mechanical loads
(speed and vibration), thermal load (to limit the possible deformation due
to temperature), stiffness of the structure (external mechanical loads and
weight of the equipment), an exclusion based on article 1 paragraph 3.10
is to be assessed on a case by case basis (see guideline 1/11).
Note: In application of the definition of “volume” given in article 1, paragraph

2.5, the volume of the mechanical parts is to be excluded from the volume
to be taken into account but not the volume of the oil contained.

Guideline related to: Article 1
Question: Is the pressure equipment directive applicable to vacuum insulation

of pressure vessels?
Answer: Yes.
Reason: Vacuum casings which do not have a maximum allowable pressure greater
than 0.5 bar are therefore not pressure equipment in their own right.
However as structural elements attached to pressurized parts, they are part
of pressure equipment and any negative effects of the vacuum casing and
insulation on the pressurized parts must be taken into account and
avoided.
Accepted by Working Group “pressure”: 1999-01-28

Question: If transport tanks for use in any mode of transport have been
designed, manufactured and approved for the carriage of dangerous
goods under the ADR, RID, IMDG code or the ICAO convention, will
it also be necessary for them to comply with the PED when they are
placed on the market?
Answer: No. Article 1.3.19 of the PED excludes transport tanks covered by ADR,
RID, IMDG code or the ICAO convention.
If a manufacturer declares that transport tanks designed, manufactured and

approved for the carriage of dangerous goods under the ADR, RID, IMDG
code or the ICAO convention, are intended to be used for both dangerous
and non-dangerous goods then the exclusion in Article 1.3.19 may still
apply (see guideline 1/30).
On the other hand, if a transport tank is not designed, manufactured and

approved under the ADR, RID, IMDG code or the ICAO convention, then
it will be limited to the transport of non-dangerous liquids and solids.
These transport tanks will not be excluded from the PED and will be
covered if they are in the scope.
All transport tanks covered by the agreements and conventions in Article

1.3.19 must be designed and built to a maximum allowable working
pressure, satisfy the requirements for initial pressure testing and undergo
periodical examination throughout their service life.
These requirements deal with safe containment and hazards due to

pressure, but primarily only for the safety of transport. With regard to the
use of a transport tank, for example as a storage tank, or being emptied
outside the scope of the transport codes, consideration should be given to
applicable national legislation. For example, the question of safety valves
in the tank itself or in the emptying station should then be considered. This
paragraph does not apply to tanks bearing both CE-mark and π-mark (see
guideline 1/30).
Note: Refer also to guideline 1/2

Question: Is the operational function of a pressure accessory, as described in

article 1 section 2.1.4 covered by the directive?
Answer: Yes, if a pressure related hazard is identified in relation with the

operational function of the pressure accessory (see also guideline 1/8).
Examples for valves:
– Where a valve is intended to be used as the sole mean of isolation of the

content of an item of pressure equipment from the atmosphere, or from
downstream equipment which is not designed to withstand the upstream
pressure, the internal parts of the valve which contribute to the isolation
must satisfy the relevant essential safety requirements in Annex 1;
– Where a valve is intended to be fitted between a pressure vessel and

pressure piping and both are designed to contain pressure, no pressure
related hazard exist in relation to the operational function of the valve,
therefore internal parts of the valve do not have to satisfy the relevant
essential safety requirements in Annex 1.
The intended use of the valve shall be described in the operating

instructions, and where it is to be used as a sole mean of isolation, it shall
meet the essential safety requirements of the directive.

Question: Article 1, paragraph 3.2 excludes from the directive “networks for the
supply, distribution and discharge of water and associated
equipment”. Clarification is required in respect of water, networks
and associated equipment in this context?
Answer: ‘Water’ means: potable water, waste water and effluent, and sewage.
‘Networks and associated equipment’ means: complete systems for the

supply distribution and discharge of water. They extend up to the point of
use in buildings, industrial sites and plants, and include equipment closely
related to these networks such as water meter and line valves. Pressure
vessels, such as expansion vessels, however are not considered to be part
of such ‘networks and associated equipment’ and are therefore not
excluded.
NOTE For district heating water, refer to guideline 1/18
Reason It was clearly the intention of the Council. It should be noted that some
linguistic versions are unclear on this point.

Question: What is the meaning of the expression "standard pressure

equipment" in article 1 § 3.1 on pipelines
Answer : A standard pressure equipment is not specially designed and manufactured

for a specific conveyance pipeline, but is intended for use in a number of
applications, including other conveyance pipelines or, for example,
industrial piping.
Typical examples of standard pressure equipment annexed with pipelines,

pressure reduction stations or compression stations may include:
measuring devices, valves, pressure regulators, safety valves, filters, heat
exchangers, vessels.
Such equipment is covered by the directive.

Question: Are pipelines for conveyance of district heating water covered by the
directive?
Answer: No. According to article 1 point 3.1 "…a system of piping designed for
the conveyance of any fluid …to or from an installation (onshore or
offshore) …." is excluded from the directive. This covers pipelines for
district heating, whereas standard pressure equipment in e.g. boiler houses
and pumping stations are included (refer to guideline 1/17).
Reason: It has from the beginning been the intention that these pipelines should be
excluded from the directive. This is obvious from the original Commission
proposal from 1993-07-14, where, in the definitions (article 1 point 2.1.2),
it is stated that "Piping" does not include pipelines and their accessories
specifically designed for the conveyance of district heating fluids. This
was later moved to the generalised exclusion in article 1 point 3.1.
Accepted by Working Group "pressure" on: 2000-03-23,

confirmed on 2000-06-29

Guideline related to: Articles 1 paragraph 3.6, Article 1 paragraph 3.10
Question: Are fluid power components and systems using liquids or gases of
group 2 covered by PED ?
Answer : For fluid power components and systems using liquids or gases of group 2
according to Article 9.2.2, the following applies :
(1) Excluded from PED
(1.1) due to exclusion 3.6 of Article 1 (e.g. machinery directive)
- piping and connecting devices for liquids of group 2 when DN ≤ 200

whatever the pressure is, and when DN > 200 and PS ≤ 500 bar
- piping and connecting devices for gases of group 2 when DN ≤ 100 or

PS DN ≤ 3500 bar
- pressure accessories (e.g. filter housing) no higher than category I
- fluid power actuators, pumps and control valves no higher than category
I.
(1.2) due to exclusion 3.10 of Article 1 (refer to guideline 1/11)
- fluid power actuators (e.g. motors, cylinders, …)
- fluid power pumps
- fluid power control valves (distributors).
(2) Included in the PED
- all accumulators (bladder, piston and diaphragm types)
- pressure equipment not excluded by (1) above.

Guideline related to: Article 1 paragraph 2.1.3; Annex I sections 2.10 and 2.11
Question: When is a measuring or control system considered as a safety

accessory under the PED?
Answer: A measuring system alone cannot be considered as a safety accessory, as a

safety accessory as defined in PED necessarily requires :
– a measuring or detection function and
– an activation function for correction, or shutdown, or shutdown and

lockout.
In order for a control system to be classified as a safety accessory, it shall

be designed and placed on the market as an ultimate means of protecting
pressure equipment from exceeding allowable limits, and therefore it shall
meet the corresponding essential requirements of Annex I, section 2.11.
Note: It is foreseeable that some measuring or control devices could be

inadvertently used as safety accessories. Where this is possible
manufacturers should include an appropriate warning in their instructions
for use.
See also Guidelines: 1/25 and 2/16

Under development

Question: What guidance can be given regarding the application of the Directive
to component parts of pressure equipment such as flanges, dished
ends and nozzles?
Answer: If these component parts are incorporated to an item of pressure

equipment, the relevant requirements of the directive will apply.
However, these component parts do not meet the definition of pressure

equipment in Article 1.2.1, therefore they shall not bear the CE mark.
It is the responsibility of the pressure equipment manufacturer to ensure

that the component parts enable the pressure equipment to meet the
essential safety requirements of the directive.
(See also guideline 1/8)
Note: Another example of a component part is a split tee.
Accepted by WPG on: 2000-05-04,

editorial amendment by WPG 2014-01-28, adopted by WGP 2014-03-20

Guideline related to: Article 3 paragraph 1.1a
Question: Is the operational function of portable extinguishers covered by PED?
Answer: No, only the aspects of pressure-related hazards are covered.
(see also guideline 1/1)
Accepted by Working Group ” pressure” on: 2000-03-24

Question: According to the definition of Article 1 paragraph 2.7 fluids may

contain a suspension of solids. Is a system of solid pieces or liquid
drops distributed in a gas still a fluid in the sense of the PED?
Answer: Yes
Note Despite the use of the term suspension in Article 1 paragraph 2.7, which in
some languages only refers to a liquid containing solids, it is obvious from
the context of this definition that a gas containing pieces of solids or drops
of liquid is also to be considered a fluid.

Guideline related to: Articles 1 paragraph 2.1.3 and Article 1 paragraph 2.1.4
Question: Are the sensors which are used as part of a safety system to protect
pressure equipment covered by the PED ?
Answer : A sensor alone does not meet the definition of a pressure accessory, as per
Article 1.2.1.4 (see guideline 1/8), nor the definition of a safety accessory,
as per Article 1.2.1.3. Consequently, no CE marking (due to the PED) is to
be put on the individual sensor.
The conformity assessment procedure and essential safety requirements of

the directive relate to the complete safety system. The requirements to the
sensor may be different depending upon the safety concept employed (for
example redundancy or fail safe, see Annex I point 2.11.1).
NOTE For the purpose of this guideline, sensor means “element of a measuring
instrument or measuring chain that is directly affected by the measurand”
as defined in the International Vocabulary of Basic and General Terms in
Metrology, prepared by BIPM, OIML, ISO, IEC.

Guideline related to: Article 1 paragraph 3.6 first indent
Question: Which rules apply for pressure equipment which also meets the
definition of machinery in the machinery directive or which is
intended to be installed in machinery?
Answer: The Pressure Equipment Directive (PED) applies to pressure equipment in

the sense of Article 1 paragraph 2 of the PED in general, but also the
exclusions of Article 1, paragraph 3 have to be considered.
Article 1, paragraph 3.6 first indent states that:
"equipment classified as no higher than category I under Article 9 of this

Directive and covered by one of the following Directives: [among others
the machinery directive] are excluded from the scope of this Directive".
That means, when a product which is placed on the market is covered by

the machinery directive, the exclusion of Article 1 paragraph 3.6 first
indent applies to any item of pressure equipment not higher than category
I which is a part of that machine (i.e. the pressure equipment directive
does not apply).
The exclusion also applies to items of pressure equipment not higher than
category I separately placed on the market, if their intended use is to be
part of machinery which must be laid down in the operating instructions.
In those cases, the essential safety requirements of PED are an appropriate

way to obtain the required safety level regarding the pressure hazard.
Pressure equipment of higher categories than category I is within the

scope of the PED even when it is machinery in the sense of the machinery
directive or intended to become part of machinery. See therefore article 3
of the machinery directive 2006/42/EC:
“Where, for machinery, the hazards referred to in Annex I are wholly or

partly covered more specifically by other Community Directives, this
Directive shall not apply, or shall cease to apply, to that machinery in
respect of such hazards from the date of implementation of those other
Directives.”
The PED is such a “Community Directive” in the sense of Article 3 of the

machinery directive 2006/42/EC.
Note: (1) This does not prohibit the inclusion of CE-marked items of pressure
equipment in machinery.
(2) See also guideline 1/11 for exclusion 3.10 of Article 1
REASON FOR THE REVISION OF THE GUIDELINE:
The new machinery Directive 2006/42/EC no longer excludes boilers and

pressure vessels from its scope

Question: What is meant by the term mobile offshore unit?
Answer: A mobile offshore unit is an offshore unit that is not intended to be placed
permanently or long term on the field, but is designed to be moved from
location to location whether or not it has a means of propulsion or of
lowering legs to the seafloor (e.g. a unit used solely for exploration).
For example, floating units intended for production, such as FPSO's

(Floating Production, Storage and Offloading installations usually based
on tanker designs) and FPP's (Floating Production Platforms based on
semi-submersible vessels), are not considered to be mobile.
Note Items of pressure equipment specifically intended for mobile offshore

units are excluded from the PED. However, items of pressure equipment
intended to be installed on both FPSO’s/FPP’s and mobile offshore units
are not excluded from the PED.
Accepted by Working Group ” pressure ” on: 2002-05-23

Question: Are conveyance pipeline stations such as compressor, reduction,

metering stations covered by PED?
Answer: These stations contain pressurised systems which may include

compressors, heat exchangers, valves, filters, piping, etc. When they are
specifically designed for pipelines, they are considered as annexed
equipment, and as such are excluded from PED, according to Article1,
paragraph 3.1.
However, this exclusion does not apply to standard pressure equipment

which may be found in these stations, see guideline 1/17.
Accepted by WPG on: 2001-02-21 (editorially amended by WPG of 2012-04-25 + WGP 2013-03-
07)
Accepted by Working Group "pressure" on: 2001.04.03

Guideline related to: Article 1, paragraph 3.1
Question: Where does the exclusion under Article. 1, paragraph 3.1 end when a
pipeline crosses the perimeter of an industrial installation ?
Answer: The exclusion of Article 1 paragraph 3.1 ends at the outlet isolation device
of the annexed equipment contained in stations supplying the fluid to the
industrial installation.
Outlet isolation devices

at the disposal of the
flow
industrial installation
pipeline
Outlets with
Isolation device different operating
pressure
outside inside
Perimeter of the
industrial installation
annexed PED applies

Annexed equipment
equipment contained in e.g. a
contained in e.g. a pressure reduction
pressure reduction and metering station
station
See also Guidelines 1/28 and 1/17.
Note: The installation beyond the outlet isolation devices detailed in the above
diagram, is covered by the PED; this includes any pressure equipment, any
piping between individual operating units or plants, or storage facilities.
Accepted by WGP on: 2013-03-07

Question: Is it permissible to affix both the CE marking for the PED and the π
mark for the TPED on an item of pressure equipment?
Answer: Yes.
This double marking proves that the item of pressure equipment complies
with both directives, and can be used in both contexts without further
assessment.
A similar item bearing only the π mark could also be used for pressure
purposes outside the scope of ADR/RID but consideration would need to
be given to possible national regulations, or to PED if included in a PED
assembly.
Hence, if a manufacturer intends a product to be used in both contexts and

designs and manufactures it accordingly so that it complies with both
applicable Directives, it shall bear both markings , to the extent foreseen
by each Directive (e.g. no CE marking for SEP equipment (Article 3
paragraph 3), and no π-marking for certain accessories).
If the manufacturer of the product only foresees it to be used in the scope

of one of the Directives, only one Directive applies and one marking (as
far as applicable) shall be affixed (see also guideline 1/33).
See also guidelines 1/14 and 1/33.
Reason: While in principle, Article 1.3.19 of the PED excludes equipment covered
by ADR/RID, it is not always possible for the manufacturer to know
whether or not a particular item of equipment he manufactures will during
its use come into the scope of these International Transport Agreements.
This is in particular true for accessories, which may well be used for both
purposes with no technical alterations. In such a case, it would only be
possible after the user has taken the product into service, to know, which
of the two Directives does not apply to the product. Until then, both
Directives shall be considered to be applicable. Such double marking
would not violate the provisions of Article 16 of the PED, as, up to the
moment the product was placed on the market, it was not excluded from
the scope of the PED. When at a later point in time the product is de facto
used in the context of a transportation of dangerous goods, the fact that it
bears the CE marking is insignificant.

Guideline related to: Articles 1, paragraph 3.1, 1, paragraph 3.10
Question: Are NGV (Natural Gas Vehicles) filling stations covered by the PED?
Answer: NGV filling stations are covered by PED. They are not excluded by
Article. 1 § 3.1as annexed equipment designed specifically for pipelines.
However, compressors are considered machinery as specified under
Article. 1 § 3.10 and thus may be excluded from PED (see guideline
1/11).

Guideline related to: Article 1 paragraphs 3.1 and 3.20
Question: Are substations for district heating pipelines to be considered as

“assemblies” in the Pressure Equipment Directive (PED) ?
Answer: Yes.
These substations are located after the last isolation device, normally
within the confines of the building or industrial installation, and thus are
not covered by exclusion 3.1 of Article 1.
Note: See also guideline 3/2 when the items of the substation are joined under
the responsibility of the user.
See also guideline 3/8 for the definition of an assembly.
Accepted by Working Group “ pressure ” on: 2003-01-27

Question: Can receptacles (in the meaning of Article 2 of Transportable

Pressure Equipment Directive) that are « pi » marked be used as
static pressure equipment without being CE marked?
Answer: Yes, provided the « pi » marked receptacle has been placed on the market
and used as transportable pressure equipment, it can then be used
permanently as static pressure equipment without being CE marked.
Note 1: For static use the receptacle may be subject to national regulation dealing
with conditions of use, installation and periodic inspection. (see also
Article 3 of TPED 2010/35/EU- On-site requirements)
Note 2: The term “static pressure equipment” has to be understood as “pressure

equipment under the scope of Pressure Equipment Directive”, even though
these receptacles fall under exclusion 3.19 of Article 1 of PED.
Note 2: See guideline 1/30 for receptacles with double CE-mark and π-mark.
Accepted by WPG on: 2002-12-04, editorially revised 2014-07-01

Guideline related to: Article 1 paragraph 3.19; Article 3 paragraph 1.1 and Annex II
Question: Is a slurry tanker that is emptied by compressed air within the scope
of the Pressure Equipment Directive?
Answer: Yes, if the PS of the compressed air is greater than 0,5 bar. The PS
of compressed air and internal volume of the tank determine the
category according to the table 2 of Annex II.
Reason : Slurry tankers are not excluded from the scope of the PED due to Article 1
section 3.19. They are not tanks intended for carriage of dangerous goods.
NOTE “Slurry tanker” is used in farms to fertilize the fields with liquid manure.
It is a tank on wheels usually pulled by a tractor in the fields and from one
field to another. Compressed air facilitates the emptying of the tank.
See also guideline 1/2.

Guideline related to: Article 1 paragraph 3.19 and Article 3 paragraph 1.1(a)
Question: Are propellant gas cartridges *) for portable extinguishers in the

scope of the Pressure Equipment Directive?
Answer: No, those cartridges are covered by ADR and consequently

excluded from PED due to Article 1, paragraph 3.19.
Note: See guidelines 1/1 and 2/14.
*) the term used in the context of the ADR is different: non refillable and refillable
propellant gas cartridges are called cylinders in the ADR. Gas cartridges defined
by ADR are limited to a pressure of 13,2 bar which is exceeded by the receptacles
concerned by this guideline.
Accepted by WPG on: 2002.01.15
Accepted by Working Group "pressure" on: 2002.02.27, editorially reviewed on 2002.03.14

Guideline related to: Article 1 paragraph 3.19, Article 3 paragraph 1.1 second indent,
Annex II, table 2
Question: Are gas cylinders, which are placed on the market to be used for fixed
fire extinguishing installations, covered by the Pressure Equipment
Directive (PED) or by the Transportable Pressure Equipment
Directive (TPED)?
Answer: If they are transported in a pressurized condition (e.g. to or from the

filling station) they are covered by the ADR convention. Such gas
cylinders are therefore excluded from the PED by virtue of Article 1
paragraph 3.19. Such cylinders are covered by the TPED.
Note 1: They do not fall under the case of Article 3 paragraph 1.1 second indent,
which only refers to portable extinguishers.
Note 2: If they are not transported in pressurised condition but filled/refilled at the
installation site they are covered by the PED.

Question: Are items of pressure equipment such as manifolds, valves and piping
used as well-control equipment and placed between a subsea well
template and the processing platform for the oil and gas extraction
and processing industry covered by the Pressure Equipment Directive
(PED) ?
Answer: No
Reason: The exclusion of Article 1 paragraph 3.9 applies to all the well-control
equipment listed therein, plus all equipment UPSTREAM in relation to
that well-control equipment.
Note 1: In some cases, processing equipment is interposed on the seabed (e.g.

separators) between the equipment listed in Article 1 paragraph 3.9 and
the pipeline(s). In such cases, the processing equipment is covered by the
PED.
Note 2: The PED in general, and Article 1 paragraph 3.9 in particular, does not
distinguish between subsea and surface equipment.
Note 3: Specific solutions to essential safety requirements shall take account of the
subsea use of this equipment, as a result of the hazard analysis.

Guideline related to: Article 1 paragraph 2.1.2, Article 1 paragraph 3.2, Annex II Table 7
and Table 9
Question: Is piping in fire extinguishing systems in the scope of the Pressure

Equipment Directive (PED)?
Answer: Yes.
Reasons: 1) Even though extinguishing gas (such as CO2 or inert gas) piping will be
only momentarily pressurised during activation of the extinguishing
system and such piping is open at the discharge end, it will be exposed to
a pressure PS above 0,5 bar.
2) The piping of a sprinkler system is not considered to be covered

by exclusion 3.2 of Article 1, as it is not a network for the supply,
distribution and discharge of water.
Note 1: The location where the pressure PS is specified shall be such to be

representative of the maximum pressure to which the piping will be
exposed.
Note 2: Table 7 of Annex II is to be used for classification if content is CO2, or

inert gas. For sprinkler systems, table 7 is to be used for "dry piping
installation", and table 9 for water.
Note 3: The PED is limited only to pressure-related hazards. Function and

performance of fire extinguishing systems are not covered by the PED.
Accepted by Working Group ”pressure” on: 2002-05-23

Question: Article 1, section 3.6 states that all "equipment classified as no higher
than category I under Article 9 of this Directive and covered by one of
the following Directives: [….] are excluded from the scope of this
Directive:". Does this exclusion also cover assemblies?
Answer: Yes.
Reason: While the categories are defined in Article 9 for items of pressure
equipment, the same categories are applied to and used in the context of
Assemblies in Article 10. The Directive clearly defines a category for
each assembly in Art. 10.2.b and requires that the applicable conformity
assessment modules are used as per 10.1.3.
Consequently there is no problem to determine, which assemblies are

excluded from the pressure equipment directive by article 1, section 3.6.
Note: There is ambiguity in some language versions of the directive regarding

Article 10 paragraph 2.b.

Question: What does pressure bearing housing mean in the definition of

pressure accessory in Article 1 paragraph 2.1.4?
Answer: The term pressure bearing housing refers to an envelope in which fluid
under pressure (PS > 0,5) is contained or transported (volume V > 0).
Therefore, a product whose only pressure-bearing surface is a flange or

screwed fitting is not a pressure accessory but is a component of an item
of pressure equipment under the Pressure Equipment Directive (PED)
when used on such equipment.
Typical examples of components which are not pressure accessories:

Level Switch, Flush Mounted Pressure Transmitter and Thermowell.
Note: This does not apply to such devices when employed in a safety function.
See also guidelines 1/8, 1/22, 1/25 and 7/19.
Accepted by WPG on: 2002-04-10, editorially amended by WPG on 2006-10-18
Accepted by Working Group "pressure" on: 2002-05-23, with editorial amendment on 2004-03-17,
and 2006-11-21

Guideline related to: Article 1 paragraph 3.5, Article 1 paragraph 3.19
Question: Is a liquefied petroleum gas (LPG) or compressed natural gas (CNG)

vessel (tank) permanently installed in an engine powered fork lift
truck in the scope of the PED?
Answer: Yes, such an LPG or CNG vessel is in the scope of the PED and must be
assessed according to its maximum allowable pressure and volume.
Reason: An engine powered fork lift truck is not a motor vehicle in the sense of
Council Directive 70/156/CEE, so the exclusion of the Article 1 paragraph
3.5 does not apply.
Note 1: Transportable gas cylinders which can also be used for fork lift trucks are
in the scope of ADR and as such are excluded from the PED, due to
Article 1 paragraph 3.19.
Note 2: The same applies to similar machinery not covered by Directive

70/156/CEE.
Accepted by Working Group "pressure" on: 2003-01-27, editorially amended by WPG on 2007-01-
30, confirmed by WGP on 2007-04-18

Guideline related to: Article 1 paragraph 2.1.2 and Annex I section 2.2.1
Question: Is the discharge piping from a pressure safety accessory, which will be
exposed to a pressure PS above 0,5 bar, in the scope of the Pressure
Equipment Directive (PED) when exhausting to ambient atmosphere?
Answer: Yes.
Reason: Even though discharge piping will be only momentarily pressurised, and
such piping is open at the discharge end, it fulfils the definition of piping
in paragraph 2.1.2 of Article 1.
Note 1: A silencer installed in the discharge piping is excluded according to

Article 1 paragraph 3.16.
Note 2: The location where the pressure PS is specified shall be such to be

representative of the maximum pressure to which the piping will be
exposed.

Guideline related to: Article 1 paragraph 2.1.3, Annex I section 2.10a and 2.11
Question: Are safety accessories as defined by the PED limited to equipment

which prevents hazards due to overpressure?
Answer: No.
Safety accessories are devices designed to protect pressure equipment

against exceeding the allowable limits (pressure, temperature, water level,
…). The suitability of the device or combination of devices is determined
on the basis of the particular characteristics of the equipment or assembly.
For example:
a) A combination of a level gauge and a pressure relief system
b) A combination of a low level water gauge and the burner shutdown
device installed on a steam boiler, including all elements of the safety
logic
c) A safety-related system detecting the rate of a chemical reaction to
avoid a run away reaction and initiating corrective action.
See also guidelines 1/20


Question: Is breathing apparatus, such as SCBA (self-contained breathing
apparatus, generally composed of a bottle, a regulator, a flexible hose
and mouth or face piece) in the scope of the PED?
Answer: Yes, breathing apparatus shall be considered as an assembly in the sense

of the PED, the items of which have to be conformity assessed according
to their individual design pressure and other characteristics, and the
assembly shall be subjected to a global conformity assessment.
Reason: Breathing apparatus is personal protective equipment and, as such,

covered by the PPE directive 89/686/EEC. This does however not exclude
it from the scope of the PED dealing with the associated pressure risk.
See also guidelines 1/10, 2/16 and 3/8.
Note: The same reasoning applies for diving breathing apparatus.

Question: When does the exclusion of Article 1, paragraph 3.5 apply?
Answer: Where the pressure equipment is directly contributing to the functioning

of the vehicle (see guideline 1/46) and the vehicle is defined in one of the
directives 70/156/EEC, 74/150/EEC and 92/61/EEC and the item of
pressure equipment is assessed by type approval under one of these
directives or by single approval of the vehicle under national regulations,
it is excluded from the PED.
If not, the PED applies.
WPG: directly discussed in Working Group "Pressure Equipment" on: 2007-12-07

Question: Are items of pressure equipment installed on vehicles covered by the

PED?
Answer: Article 1 paragraph 3.5 excludes from the scope of the directive
"equipment intended for the functioning of vehicles defined by the
following Directives and their annexes:
- Council directive 70/156/EEC of 6 February 1970 on the approximation

of the laws of the Member states relating to the type-approval of motor
vehicles and their trailers;
- Council directive 74/150/EEC of 4 March 1974 on the approximation of

the laws of the Member states relating to the type-approval of wheeled
agricultural or forestry tractors;
- Council directive 92/61/CEE of 30 June 1992 relating to the type-

approval of two or three-wheel motor vehicles"
For example, the following items directly contributing to the functioning

of the vehicles are within this exclusion: tanks such as the auxiliary tanks
for braking energy systems (which may be covered by the directive
87/404/EEC on simple pressure vessels that does not contain an exclusion
for equipment installed in vehicles), LPG, CNG or hydrogen tanks, those
hydraulic systems contributing to the functioning of the vehicle such as
shock absorbers.
An item of pressure equipment not contributing directly to the functioning

of the vehicles is covered by the PED (e.g. air conditioning system, fire
extinguisher, fixed LPG tanks in camping-cars for heating or cooking
purposes only). For hydraulic systems see also guideline 3/13.
Note: Article 1 paragraph 3.15 excludes pressure equipment consisting of a

flexible casing. Tyres and airbags (air cushions) are within this exclusion.

Guideline related to: Article 1 paragraph 2.1.1, Article 9 paragraph 3, Article 15

paragraph 2
Question: Is it correct to have a spare bundle of a shell & tube heat exchanger
CE marked separately from the CE-marking of the heat exchanger ?
Answer: No.
Reason: A shell & tube heat exchanger is one vessel with two chambers (guideline
2/19); it is not permissible to have one chamber of a vessel separately CE-
marked. A bundle is a component of a heat exchanger, it is not an item of
pressure equipment
See also guidelines 1/3, 1/22, 4/9 and 7/19

Guideline related to: Article 1 paragraph 2.1.4, 2.3 and 3.6, Annex I section 2.2.1
Question: Are Flame Arresters and flash back arresters covered by the Pressure
Answer: Yes, when the maximum allowable pressure PS they can be exposed to is
above 0,5 bar, flame arresters and flash back arresters are covered by the
PED and, in general, should be considered as pressure accessories.
Such flame arresters are generally also covered by ATEX directive ; in

that case, they are excluded from PED if they do not exceed Category I
(Article 1 paragraph 3.6).
Specific solutions to essential safety requirements shall take account of the

potential explosion, as a result of the hazard analysis; the essential safety
requirements from ATEX directive need also to be taken into account.
Note 1: In accordance with Article 1 paragraph 2.3, PS would be the maximum

pressure for which the flame arrester housing is designed. PS is not
necessarily the explosion pressure; in any case the explosion pressure
shall be taken into account and may be considered as a load case
following the hazard analysis (see Annex I section 2.2.1).
Note 2: In general, the flame arresters will be classified using Annex II table 6.
Note 3: For the definition of flame arresters, see EN 12874:2001.

Question: Are fluid power accumulators intended for the operation of high-
voltage electrical equipment covered by exclusion 3.12 of article 1?
Answer: No, these accumulators are covered by the Pressure Equipment Directive.
Reason: The exclusion of article 1 paragraph 3.12 covers only the enclosures of the
high-voltage electrical equipment and not the items of pressure equipment
supplied with these high voltage electrical products.
See also Guideline 1/19.
Accepted by the Working Group "pressure" on: 2004-03-17

Question: Is the flare tip at the end of piping in the scope of the Pressure
Answer: The flare tip is covered by the PED, when the internal pressure exceeds
0,5 bar, in which case it is a pressure accessory.
Note 1: A flare (or flare system) can be considered as two parts: the lower part,
which essentially comprises discharge piping and the upper part, at the
extremity of the piping (usually joined by a flanged connection), which is
the flare tip, where the flame is ignited. In some designs a device is
installed as part of the flare tip to regulate flow.
Note 2: The discharge piping is covered by the PED (see guideline 1/42).

Question: What is meant by high-voltage in the context of Article 1 paragraph

3.12 ?
Answer: High voltage means that the highest voltage in normal conditions, either
between the two connectors or between one connector and the ground,
exceeds the following values:
- for alternating current : 1000 V;

- for direct current : 1500 V.
Reason: The Low voltage directive 73/23/EEC and its amendment 93/68/EEC say:
"Article 1 For the purposes of this Directive "electrical equipment" means
any equipment designed for use with a voltage rating of between 50 and 1
000 V for alternating current and between 75 and 1 500 V for direct
current."


Guideline related to: Article 1 paragraph 3.6, Article 3 paragraph 1.2, Annex II, Table 5
Question: Article 3 paragraph 1.2 states that all pressure cookers shall satisfy
essential requirements set out in Annex I ; Article 1 paragraph 3.6
excludes from the scope of the Directive equipment classified as no
higher than category I and covered by Directive 73/23/EEC (as
replaced by Directive 2006/95/EC). How to apply these two Articles to
electrical pressure cookers?
Answer: All electrical pressure cookers with a maximum allowable pressure above
0,5 bar are also in the scope of the Directive 97/23/EC, irrespective of
their product pressure-volume.
Reason: The pressure hazard of pressure cookers could be high if the design is not
adequate. It is the reason why their design must be subject to a conformity
assessment of at least one of the category III modules. This applies to
electrical pressure cookers as well as externally fired pressure cookers.
The sixth recital of the Directive explains that the exclusion laid down in
Article 1 paragraph 3.6 is intended for equipment where the hazard due to
pressure remains small.

Question: Are dryer rolls for the paper industry covered by the PED ?
Answer: Yes
Reason: Even if thermal, dynamic and other non-pressure loads are important for
the design of dryer rolls, for most pressure is a significant design factor
when dimensioning the equipment.
Note 1: However some dryer rolls with a specific design such as the incorporation
of many small holes may be excluded from the PED on the basis of Article
1 paragraph 3.10 because pressure is not a significant design factor.
Note 2: Some dryer rolls are regularly ground to meet the process requirements.
This loss of thickness can eventually oblige the user to reduce pressure
loads according to a curve called "derating curve" provided by the
manufacturer.

Not yet adopted

Guideline related to: Article 1, paragraphs 2.1.2, 3.6 and 3.10
Question: Is turbine piping covered by the Pressure Equipment Directive

(PED)?
Answer: Turbine piping defined as “connecting lines between different casings of

the turbine train and connecting line between two positions at a single
turbine casing and internal piping” is evaluated as follows:
Note 1: The manufacturer has the ultimate responsibility to perform a hazard analysis
and to determine the Directives applicable to the equipment.
Note 2: Inlet and outlet piping is not part of the turbine, so it shall be evaluated
separately against PED.
Note 3: See also guidelines 1/11, 1/26 and 8/4.

Guideline related to: Annex I Section 2.2.1
Question: Is equipment with a maximum allowable pressure PS ≤ 0,5 bar in the

scope of the PED if it is also designed to take account of an explosion
pressure in an abnormal condition?
Answer: No
Reason: The classification under the PED is based on PS in normal or foreseeable

operating conditions.
When the manufacturer classes an explosion as an incident, rather than as

operation as intended, the explosion pressure shall not determine the
classification according to the PED.
When an explosion is considered included as part of the intended

operation of the equipment, if the resultant pressure PS is greater than 0,5
bar then the equipment is covered by the PED.
Examples of such equipment could be e.g. grain silos.

Question: Are vessels designed to operate under vacuum conditions in the scope
of the PED?
Answer: No.
However if there are other foreseeable conditions such as cleaning,

transport, maintenance etc. where the vessel is subject to a pressure greater
than 0,5 bar, the PED does apply.
See also Guideline 1/2, 1/13 and 8/7
Reason: According to Article 1 the PED directive applies to the design, manufacture
and conformity assessment of pressure equipment and assemblies with a
maximum allowable pressure PS greater than 0,5 bar.
Further, section 2.2 defines pressure relative to atmospheric pressure, i.e.

gauge pressure. As a consequence, vacuum is designated by a negative
value.

2. CLASSIFICATION AND CATEGORIES
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

2.1. Guideline 2/1
Guideline related to: Article 3 paragraph 1.4 and Annex II point 3
Question: There is a contradiction between the requirements in article 3

paragraph 1.4 and those in annex II point 3.
Can pressure accessories be classified as “article 3.3” as indicated in

the tables in annex II or must all of them satisfy the essential
requirements as indicated in article 3 paragraph 1.4 ?
Answer: In accordance with annex II point 3, pressure accessories have to be

classified using the appropriate table(s) of annex II on the basis of their
PS, their V and/or DN, and the group of fluids for which they are
intended. Pressure accessories with low PS, volume and/or DN will
therefore fall under the requirements of article 3.3. Such pressure
accessories do not have to satisfy the essential requirements but only
sound engineering practice.
Reason: Requirements in annex II are more precise and should prevail.

When the directive was developed, it was clearly not the intention to
require that all pressure accessories intended for equipment which have to
satisfy the essential requirements also have to satisfy those requirements.
Accepted by Working Group “pressure” on: 1999-01-28 (re-edited 01-2001)
Reservation from Sweden and Denmark

2.2. Guideline 2/2
Guideline related to: Article 1, paragraph 2.6; Article 3, paragraph 1.3
Question: The Directive uses the notion of DN (defined in Article 1, paragraph

2.6) for the classification of piping or piping accessories (cf. Article 3,
paragraph 1.3). How to apply the Directive for classifying the tubular
products or accessories for which the notion of DN does not exist
(copper tubes, plastic valves, pressure regulators, hollow sections…)?
Answer: In the absence of DN in the standards, it shall be assumed that DN

corresponds to the internal diameter in millimetres for circular products or
the diameter in millimetres of the equivalent flow section for non-circular
products.
In case of pressure accessories this assumption is made regardless of the

diameter of the connection (which is usually expressed by DN).
For non-circular piping a comparative diameter must be determined from

the existing cross-section. This comparative diameter must be used as the
basis for classification.

2.3. Guideline 2/3
Guideline related to: Article 3 paragraph 1; Annex II
Question: How should vessels and piping for superheated water be classified?
Answer: Vessels for super-heated water are covered by article 3, paragraph 1.1 a),
second indent and table 2 applies.
Piping for super-heated water is covered by article 3, paragraph 1.3 a),

second indent and table 7 applies.
These replies are applicable to unheated vessels or pipes with

temperatures > 110° C.
Fired or otherwise heated vessels or piping with the risk of overheating

that are intended for generation of steam or super-heated water at
maximum allowable temperatures > 110° C are covered by article 3,
paragraph 1.2 and table 5 applies.

editorially corrected on 2002-04-10

2.4. Guideline 2/4
Guideline related to: Article 1 paragraphs 2.1.1 and 2.1.2
Question: Which type of pressure equipment is a heat exchanger?
Answer: Heat exchangers are considered to be vessels.
As an exception, heat exchangers which consist of straight or bent pipes

which may be connected by common circular header(s) made also from
pipe are classified according to Article 1 paragraph 2.1.2 last sentence as
piping if, and only if, the 3 following conditions are met:
- air is the secondary fluid,

- they are used in refrigeration systems, in air conditioning systems or
in heat pumps,
- the piping aspects are predominant.
For such heat exchangers with headers, the piping aspects are pre-
dominant if Catp ≥ Catv where:
Catp = Abstract category that would be applicable according to 97/23/EC

if the heat exchanger were classified as piping using DN of the biggest
header.
Catv = Abstract category that would be applicable according to 97/23/EC
if the biggest header, without the connecting piping, were classified as a
vessel (i.e. for determining Catv, not the total volume V of the heat
exchanger is taken into account, but only the volume VH of the biggest
header).
When the result is Catv>Catp, the appropriate vessel classification shall be
determined by using the volume of the entire heat exchanger (headers plus
connecting tubes).
The abstract category approach for determining the predominant aspect is
limited to this specific application dealt with in Article 1 paragraph 2.1.2.
The use of this concept outside this context is not supported by the
directive and thus is not permissible.
Note: Piping heat exchangers which do not meet the requirements of the
exception are not to be classified according to the last sentence of Article
1 paragraph 2.1.2 as piping; they are to be classified as vessels. For
example:
- Heat exchangers which are not used in refrigeration systems, in air

conditioning systems or in heat pumps, and for which the main
purpose is to heat or cool the contained fluid by using the surrounding
air;
- Half-pipe coil or a similar « jacket » construction that heat or cool a
vessel;
- Pipe coil that is inside a vessel to heat or cool its content.

Accepted by Working Group "pressure" on: 2003-11-03, editorially amended by

2004-09-07, Swedish reservation updated on 2005-03-16
Swedish reservation on the determination of Catv based only on the biggest header and
not on the sum of the header volumes, and on the inclusion "refrigeration systems" and
condensers in the second indent of the answer.

2.5. Guideline 2/5
Guideline related to: Article 1 paragraph 2.4, Article 3 paragraph 1.2, Annex II table 5
Question: Some warm water generators having a volume greater than 2 L are
intended to generate water at a temperature less than 110 °C, but are
fitted with a safety temperature limiter which is set to a temperature
of 120 °C.
What value of maximum allowable temperature, TS, shall be declared

by the manufacturer?
Answer: If the equipment is designed to operate at a temperature up to, but not

exceeding 110 °C, then 110 °C shall be the value of TS, as defined in
Article 1.2.4, specified by the manufacturer. In this case, the temperature
limiter shall be set to ensure that the water temperature will not exceed
110 °C.
In the example given in the question, TS is 120 °C.
Accepted by WPG on : 2000-02-08
Accepted by Working Group “ pressure ” on : 2000-03-24, editorially

amended on 2006-11-22, confirmed by WGP on 2007-04-18

2.6. Guideline 2/6
Guideline related to: Articles 3. paragraphs 1.1, 2.1, 2.2
Question: How should a fired or otherwise heated equipment be classified if a

fluid other than water is being heated ?
Answer: This equipment shall be considered as vessel in accordance with article

3.1.1 of the directive. It may also be considered as assembly in accordance
with article 3.2.2.
The definition of assemblies in article 3.2.1 concerns only the assemblies
intended for generating steam or superheated water and does not concern
equipment where a fluid other than water is heated.
As a consequence, the classification shall not be made using table 5.
Examples of such equipment are oil heating furnaces, heat exchangers

(refer also to guideline 2/4), and induction heaters.
Note: The essential requirements of annex I section 5 are applicable to such

pressure equipment, if it presents a risk of overheating, unless the
equipment is covered by Article 3.3.
Accepted by Working Group “ pressure ” on : 2000-03-24

2.7. Guideline 2/7
Guideline related to: Articles 9 paragraphs 2.1 and 2.2
Question: Article 9 classifies fluids with reference to Article 2 (2) of Directive

67/548/EEC. Does this mean that all fluids classified as dangerous are
group 1?
Answer: NO, only those fluids the properties of which are cited in Article 9
paragraph 2 of the Pressure Equipment Directive (PED) are to be
classified as group 1. According to the classification of Annex VI of the
latest amendment of Directive 67/548/EEC they have one or more of the
following risk phrases.
(This list relates to the version dated November 2005)
- R2, R3 for explosive
- R12 for extremely flammable
- R11, R15, R17 for highly flammable
- R26, R27, R28, R39 for very toxic
- R23, R24, R25, R39, R48 for toxic
- R7, R8, R9 for oxidising.
For flammable fluids, see guideline 2/20.
Note 1: The reference to the directive 67/548/EEC is used for the definitions of
the risks of the substances. Annex I of this directive is not exhaustive
whatever the version is. The fact that a substance is not listed in Annex I
of this directive does not imply its classification in Group 1 or 2. It is
advisable then to refer to the safety data sheet supplied with the product in
accordance with the directive 91/155/EEC to identify whether the risks of
Group 1 are included or not. The classification of substances according to
directive 67/548/EEC may also be checked on the website of the
European Chemical Bureau http://ecb.jrc.it
Note 2: Fluids which have the symbol T or T+ are not necessarily group 1. As an
example, fluids that are classified carcinogenic may have the symbol T.
However, they don’t belong to Group 1 fluids of the PED because they are
not classified toxic (e.g. 2-naphtylamine salts, index no. 612-071-00-0). In
directive 67/548/EEC, the symbols and classification are not the same.
The symbols are defined in article 6 of Directive 67/548/EEC (article 16
of amendment 79/831/EEC) and this article is not mentioned in Article 9
of the PED. Classification and symbols are listed separately in the lists of
fluids, Directive 93/21/EEC, and amendments.

editorially amended on 2005-11-28
agreed 2006-03-31

2.8. Guideline 2/8
Guideline related to: Article 9 paragraph 3
Question: How should a vessel which is intended to contain water below 100 °C
be classified when there is a marginal gas cover?
Answer: This type of vessel is classified according to Table 4, provided the gas is
being continuously removed.
Examples of such vessels are domestic warm water vessels, where

entering air is accumulated on the top, and is normally being removed by
operation.

2.9. Guideline 2/9
Guideline related to: Article 3 paragraph 1.1 and Article 9 paragraph 3
Question: Which pressure and volume values must be used to determine the
category of vessels used as gas-loaded accumulators, or other vessels
with a flexible or non fixed membrane, given that these are made up
of two chambers with different fluids?
Answer: The maximum allowable pressure (PS) of the vessel and the total volume
of the vessel shall be used according to Article 9.3.

Guideline related to: Article 3 paragraph 1.1 and Article 9 paragraph 3
Question: If a vessel contains a fluid which meets the conditions of the

introductory paragraph to Article 3, paragraph 1.1(a) (e.g. air) and a
liquid which meets the conditions of the introductory paragraph to
Article 3, paragraph 1.1(b) (e.g. water) - how shall the vessel be
classified?
Answer: Article 9, paragraph 3 states that the classification shall be on the basis of
the fluid which requires the higher category. The total volume (V) of the
vessel, as defined in Article 1, paragraph 2.5, shall be used to determine
the conformity assessment category, not the actual volume occupied by
the individual fluids at any particular time.

Guideline related to: Article 10, section 1.4, Annex II, Annex III
Question: When is it possible for a manufacturer to apply a module from a

higher category and what are the consequences ?
Answer: Article 10.1.4 states that manufacturers can choose to apply one of the
procedures which apply to a higher category if available. The words ‘if
available’ make it clear that if an item of pressure equipment was
classified as category IV, then a module from a higher category is not
available. Even for those tables in Annex II where categories III and/or IV
are not listed, such procedures can be chosen.
The procedures available are the modules or module combinations

described under Article 10.1.3.
If a module (or a module combination) from a higher category is chosen,

all the requirements of that module must be met, including the marking of
the identification number of the Notified body.
However, the use of a module (or a module combination) from a higher

category does not change the actual classification of the equipment. The
requirements of Annex I are those resulting from the actual classification
unless the module itself gives specific requirements.
Note: When particular modules are explicitely referenced in the text of the
directive, they cannot be substituted, as for example in Table 4 of Annex
II.

Question: For warm water boilers which are controlled by a temperature

thermostat and protected by a safety temperature limiter, does the
maximum allowable temperature (TS) mean:.
(a) the maximum intended operating temperature under normal

conditions as controlled by the thermostat; or;
(b) the temperature setting of the ultimate over-temperature safety

device i.e. the limiter?
Answer: (b) is correct.
Note: manufacturers must ensure that the equipment is sufficiently robust to deal
with any residual heat after activation of the limiter.
See also WPG 2/5
Accepted by Working Group “pressure” on : 2000-03-24

Guideline related to: Article 3 paragraphs 1.1, 1.2, 1.3 and Annex II
Question: How can manufacturers use Article 3.1 to determine the appropriate
conformity assessment Tables in Annex II?
Answer:
V e sse l a nd /or
piping con taining
a ny flu id
No O the rw ise No
Is it fire d ?
h ea ted ?
Y es Yes
Y es R isk o f No
o ve rh ea tin g?
No
In te nd ed fo r the g en eration
o f ste am or sup er-h ea te d
w a te r a t tem p era tures
g rea ter th an 1 100 C ?
Y es V essel P iping
Yes Y es
No Q Y es No Q Yes
(see b elo w ) (see b elow )
Ta ble 5 Ta ble s 1 & 2 T a b le s 3 & 4 Ta bles 6 & 7 T a b le s 8 & 9
Q . D o es th e ve ssel o r p ip in g co nta in liqu id w h ose va po ur p re ssure at th e m axim u m

allo w ab le te m p eratu re is no t m o re th an 0 ,5 ba r ab ove n orm a l a tm osph eric p re ssu re ?

Guideline related to: Article 3, paragraph 1.1(a) and Annex II, Table 2
Question: Article 3, section 1.1(a) second indent, states that all portable
extinguishers must comply with the essential safety requirements
(ESRs) and be assessed according to Annex II, Table 2. In addition,
Table 2 states that portable extinguishers must exceptionally be
classified at least in category III. To what parts of a portable
extinguisher do these requirements apply?
Answer: Article 3, section 1.1(a) and Annex II, Table 2 are applied to vessels and
therefore the requirements are relevant to the cylinder (bottle) of the
portable extinguisher. The other parts of the portable extinguisher which
are pressure equipment are classified according to Article 3 and assessed
according to the appropriate Tables.
Note: A portable extinguisher is an assembly referred to in Article 1, section

2.1.5 and Article 3, section 2.2. It shall be subjected to a global conformity
assessment procedure of Article 10, section 2 and it shall bear the CE
marking as an assembly.
The global conformity assessment procedure of Article 10, sections 2 (b)

and 2 (c) is determined by the highest category applicable to the
equipment concerned other than that applicable to any safety accessories.
Because the cylinder (bottle) of a portable extinguisher is classified at
least in category III the global conformity assessment procedure to be
applied must be chosen among those laid down at least for category III.

Guideline related to: Article 3 paragraph 1.2, Annex II table 5
Question: Does the classification of the pressure cookers in category III for the
assessment of the design mean that also the essential safety
requirements are linked to category III?
Answer: No
In accordance with Article 3 paragraph 1.2, all the pressure cookers shall
satisfy the essential safety requirements of the directive and shall bear the
CE marking.
The determination of the category of the pressure cookers regarding

essential safety requirements following Article 9 paragraph 1 is made in
accordance with table 5 of Annex II, i.e. :
- Category I for the pressure cookers for which the product PS.V is not
greater than 50 bar.L
- Category II for the pressure cookers for which the pressure is not greater
than 32 bar and the product PS.V is over 50 bar.L and not greater than 200
bar.L
The only differences in essential safety requirements with regard to

category are stated in Annex I sections 3.1.2, 3.1.3, 3.2.2, 4.2c and 4.3
(see also guideline 2/11).
The design assessment shall be made in accordance with a module of

Category III or IV, i.e. modules B, B1, G, H or H1.
Note: When module B or B1 is used and no notified body is involved at the

production phase, there shall be no marking of the identification number
of the notified body.

Guideline related to: Article 1, paragraph 2.1.3, Annex I, section 2.11
Question: Are pressure regulators safety accessories in the sense of PED?
Answer: In general pressure regulators are pressure accessories.
Only in the case where they fulfil the definition of safety accessory and
consequently have a specified safety function, they are to be considered
safety accessories and they shall meet requirements of Annex I, section
2.11.
When a pressure regulator is installed in an assembly where the design

pressure of the system downstream of the device is lower than the
pressure which can occur upstream of the device, and the system
downstream is not protected by a safety accessory, the manufacturer of the
assembly must ensure that this pressure regulator fulfils the requirements
of a safety accessory.
Note: It is foreseeable that some pressure regulators without specific safety

function could be inadvertently used as safety accessories. The
manufacturer of the pressure regulator must include an appropriate
warning in their instructions for use.
Acceptedby WPG on: 2001-01-10
Accepted by Working Group "pressure" on: 2001-06-26, editorially amended by WPG on 2007-
03-27, confirmed by WGP on 2007-04-18

Guideline related to: Article 9 and annex II point 3
Question: How are pressure accessories classified?
Answer: The guiding factor should be based on the characteristic of the

pressure accessory.
In some cases both volume and DN are considered appropriate. In such

cases, the pressure accessory must be classified in the highest category.
In the case of valves, DN is normally the more appropriate.
Reason: It should be noted that some linguistic versions are unclear on this point.
Acceptedby Working Group "pressure" on: 2001-06-26

Guideline related to: Article 3 paragraph 3 and Article 10 paragraph 1.4
Question: Article 10, section 1.4 states that a manufacturer may choose to apply
one of the conformity assessment procedures which apply to a higher
(conformity assessment) category if available. Does this mean that a
manufacturer of pressure equipment covered by Article 3, section 3,
referred to as Sound Engineering Practice (SEP), can choose to apply
Module A for example and hence apply a CE Marking?
Answer: No.
Article 9, section 1 deals with the classification of pressure equipment

referred to in Article 3, section 1 (not section 3) and Article 10 sets out
how the conformity assessment procedures should be determined for such
equipment. Therefore Article 10, section 1.4 does not apply to SEP
pressure equipment and it does not provide any derogation to the
provision in Article 3, section 3 that specifically prohibits CE Marking of
SEP pressure equipment.

Guideline related to: Article 1 paragraph 2.1.1; Article 3 paragraph 1.1; Article 9
paragraphs 1 and 3, Annex I section 2.2.3b first indent, Annex I section 3.3(a)
Question: Do two housings, designed to contain fluids under pressure and which
have a common boundary (e.g. separating wall), constitute two
vessels, or two chambers of the same vessel and what requirements
apply to such an item of pressure equipment?
Answer: They constitute two chambers of the same vessel.
Technical requirements and conformity assessment procedure to be

applied are determined as follows:
- each chamber will be classified according to Article 3, paragraph 1.1

and Article 9, paragraph 1. This establishes the technical requirements
for each chamber.
- the conformity assessment procedure to be applied to the whole vessel

is based on the highest category of the chambers.
The technical requirements to be applied to the common boundary are

those of the highest category of the two chambers.
Hazard analysis of individual chambers must take account of the effect of

any perceived hazard on the vessel as a whole.
The marking shall include the limits of the two chambers even if the limits
of one chamber do not exceed the limits of Article 3 paragraph 1.1.
Reason: If a vessel is composed of a number of chambers each individual chamber

must be first classified. The classification and the technical requirements
of each individual chamber are based to Article 3, paragraph 1.1 and
Article 9, paragraph 1. The conformity assessment procedure to be applied
to the whole vessel is determined by the highest category.
Examples: - A refrigerant heat exchanger that has water in tube or shell side,
- A valve body or a pipe with heating or cooling jacket that has a small
volume.
Note 1: Sound engineering practice can be applied as technical requirement for a

chamber that does not exceed relevant limit of Article 3, paragraph 1.1.
Note 2: Refer to guideline 1/13 for those cases where maximum allowable
pressure of a chamber does not exceed 0,5 bar.
Reservation from Denmark and Sweden.

Guideline related to: Article 9, paragraph 2.1, 4th indent
Question: What is meant by “flammable” in article 9 paragraph 2.1, 4th indent

of the PED?
Answer: Flammable means any fluid which is intended to be used at a maximum

allowable temperature TS above its flashpoint.
Reason: Although this is not fully in line with the definition of Directive
67/548/EEC, this answer was clearly the intention of the Council and
Parliament, as shown by the sentence between brackets in the text of the
PED.
Note 1: A fluid defined as flammable according to Directive 67/548/EEC does not

belong to group 1 in the case the maximum allowable temperature (TS) is
below its flashpoint.
Note 2: Heat transfer oils are not defined as ‘flammable’ according to the Directive
67/548/EEC (and its amendments) because their flashpoint is above 55 °C.
However, if the maximum allowable temperature (TS) is above flashpoint
the hazard of heat transfer oil corresponds with the definition of Article 9,
section 2.1, of flammable group 1 fluid.

Guideline related to: Annex I sections 2.2.1 and 2.3, Annex II Table 1 Annex II Table 6
Question: Tables 1 & 6 of annex II of PED include a reference to unstable gas

(this implies that we should classify the equipment in categories III or
IV). How does one define an unstable gas?
Answer: An unstable gas in this context is a gas or a vapour liable to transform

itself spontaneously, producing a sudden pressure increase.
Such transformation as an example can result from a relatively small

variation of an operating parameter (e.g. pressure, temperature) in a
confined volume.
These substances are generally put on the market in a stabilised form.

ADR:2001, chapter 2.2.2.2.1 contains the general criteria for the
classification of gases. An indication is given with the notion "stabilised"
in tables A and B in chapter 3.2 of ADR:2001.
Typical examples of unstable gases: acetylene (UN 1001), methyl

acetylene (UN 1060), vinylfluoride (UN 1860).
Note: Directive 67/548/EEC on classification, packaging and labelling of

dangerous substances does not deal with this point.

Guideline related to: Article 3 paragraph 1.2, Annex I section 5
Question: What does overheating mean in Article 3 paragraph 1.2?
Answer: Overheating in the sense of Article 3 paragraph 1.2 means exceeding the
design temperature, for instance in the case of a failure of a safety system,
or through operator error.
Overheating is a hazard which cannot be eliminated through a safety

system, but the risk can be minimized.
However if the design temperature is chosen to take into consideration the

highest temperature in all foreseeable conditions, the hazard of
overheating does not exist.
Note: Design temperature will have to take account of the highest temperature of
the material, and not only of the fluid content.

Guideline related to: Article 3 paragraph 1 and 3, Annex II
Question: How should a solar panel be classified?
Answer: This pressure equipment shall be considered as a heat exchanger

containing super-heated or hot water (with or without additives)
Only when a solar panel in its entirety is designed to withstand the highest
possible temperatures (stagnation conditions are within the normal
operation range), a risk of overheating does not occur (see guideline 2/22).
As a consequence the classification shall be made using table 2, Annex II
(see guideline 2/13).
Note: A typical solar panel would be classified as Article 3, paragraph 3

equipment, due to the maximum allowable pressure and volume.
Accepted by WPG on: 2002-04-10, editorial change on 2005-11-28
Accepted by Working Group "pressure" on: 2002-05-23, accepted on 2006-03-31

Guideline related to: Article 1 paragraph 2.7, Article 9 paragraph 3
Question: Article 9, paragraph 3 states that where a chamber contains several

fluids, classification shall be on the basis of the fluid which requires
the highest category. Can some guidance be provided on how to
proceed with the fluid mixture classification?
Answer: When a mixture of fluids contains at least one fluid classified to

group 1, the mixture shall be classified to group 1 unless the safety
data sheet of the mixture allows its classification to group 2.
A “safety data sheet” is a document established according to Directive

91/155/EC, in application of Directives 67/548/EEC and 99/45/EC (*). It
gives all necessary safety information, in particular classification of the
hazard properties referred to in Article 9 paragraph 2.1 of PED.
Note: When an equipment is manufactured for a specific application defined by
the user, it is normally the user who specifies the fluid to be contained or
transported in the pressure equipment. Hence, the user should tell the
pressure equipment manufacturer the fluid classification or give necessary
details so that the pressure equipment manufacturer can classify the fluid.
(*) -
Council Directive 67/548/EEC of 27 June 1967 on the approximation of laws, regulations and administrative
provisions relating to the classification, packaging and labelling of dangerous substances.
- Directive 1999/45/EC of the European Parliament and of the Council of 31 May 1999 concerning the
approximation of the laws, regulations and administrative provisions of the Member States relating to the
classification, packaging and labelling of dangerous preparations.
- Commission Directive 91/155/EEC of 5 March 1991 defining and laying down the detailed arrangements for
the system of specific information relating to dangerous preparations in implementation of Article 10 of
Directive 88/379/EEC.

Guideline related to: Annex II

Question: Is it possible to classify pressure equipment in a Category higher than
the category resulting from the application of tables in Annex II ?
Answer: No
The classification of a pressure equipment is based on the following
factors:
- Type of equipment (vessel, piping, or pressure accessory),

- Type of fluid: gas or liquid,
- Group of fluid: group 1 or 2.
These factors determine the table of Annex II to be used. In the
appropriate table, the maximum allowable pressure and the volume for
vessels or the maximum allowable pressure and the nominal size DN for
piping determines the Category of the equipment.
For example a valve classified as DN 25 can only be Sound Engineering
Practice according to Article 3 paragraph 3 and must never be CE-marked
(see also guideline 2/17).
Note 1: The directive exceptionally requires use of a higher Category (for instance
vessels for unstable gas, or portable extinguishers), but even then there is
no choice of category for the manufacturer.
Note 2: The classification of safety accessories is not covered by the tables of
Annex II (see section 2 of Annex II)
Note 3: The PED gives flexibility for a manufacturer to apply a conformity
assessment procedure from a higher category, if available (see guideline
2/11). For Sound Engineering Practice equipment see guideline 2/18.
Swedish reservation on the example due to guideline 2/1.

Question: How to classify a vessel which contains a "non-suspended dangerous"

solid blanketed by a group 2 gas?
Answer: It will be classified according to table 2.
Reason: Article 1 paragraph 2.7 defines fluids as gases, liquids and vapours and
covers fluids containing a suspension of solids (see guideline 1/24).
Article 9 in connection with Article 3 only mentions gases, liquids and
vapours for classification purposes.
Note: The characteristics of the solid should be considered as part of the hazard
analysis and do not influence the classification of the vessel.

Guideline related to: Article 9 paragraph 2.1, 2.2 and 3
Question: How to classify pressure equipment containing one or more fluids

when a chemical or physical reaction takes place therein?
Answer: The classification shall be determined by the fluid which gives the highest
category taking into account the starting, intermediate and final fluids,
which could arise from all reasonably foreseeable conditions.

Guideline related to: Article 1 paragraph 2.1.2, Article 3 paragraph 1.3 and Annex II
Question: How shall a "piping" (as defined in Article 1 paragraph 2.1.2),

comprising pipes with different DNs, be classified?
Answer: For such a piping the maximum DN used shall be the basis for the
classification.
Note: The term a "piping" as used above means an item of pressure

equipment, and not an "assembly" as defined in Article 1 paragraph
2.1.5.

Guideline related to: Annex I, section 2.10
Question: A pressure vessel (PS > 0,5 bar) has a vacuum relief valve mounted to
protect against collapsing (external pressure) when drained.
Is this valve a safety accessory?
Answer: Yes, if a vacuum relief valve is designed to be fitted to pressure

equipment (PS > 0,5 bar) where collapse due to vacuum is possible under
reasonably foreseeable conditions. The valve is a safety accessory as
defined by Article 1, paragraph 2.1.3 and must be assessed as such.
Note 1: Only those valves with a direct safety function shall be classified as a
safety accessory.

Guideline related to: Article 1 paragraph 2.7, Article 9 paragraph 2.1, 2.2
Question: How should a fluid containing a suspension of a solid be classified?
Answer: This classification shall take account of the group of the fluid and of the
group of the solid and of the group of the mixture if available.
When the group of the mixture is known according to directive 99/45/EC

"Dangerous preparation directive", this group is used for the
classification.
If not, the classification is based on the higher group of the fluid and the
solid.
See also guidelines 1/24, 2/24, 2/26, 2/27.
Reason: Article 1.2.7 of the PED stipulates that a fluid may contain a suspension
of solids. The directive 67/548/EEC referenced in article 9 of the PED
addresses “substances”, defined as “chemical elements and their
compounds as they occur in the natural state or as produced by industry”
and “preparations”, defined as “mixtures or solutions composed of two or
more substances”, i.e. its scope is not limited to “pure fluids”. Article 3 of
the directive 67/548/EEC provides the classification to be performed
according to the greatest degree of hazard.
Note: When a solid is suspended in a fluid the risk of the release of solid
particles by a pressure accident is substantially higher than in case of a
solid block blanketed by a fluid (case of guideline 2/26). This supports the
different conclusions of this guideline and guideline 2/26.
When the solid particles are big enough that the release of solid particles
cannot be expected in case of a pressure accident, then guideline 2/26
applies.

Guideline related to: Article 1 paragraph 2.1.2, Article 1 paragraph 2.1.4
Question: How to consider, in application of the Pressure Equipment Directive

(PED), piping components connected together and connected also to
valves, and which are the provisions for the placing on the market?
Answer: The PED makes the distinction in article 1 paragraph 2 between pressure
equipment (vessel, piping, safety accessory and pressure accessory) and
assemblies.
Connecting together piping components (flanges, pipes, fittings, reducers

for example) constitutes an "item of piping" (see also guideline 1/9). The
valves are pressure accessories, and not components of piping.
An item of piping, of category I and above, shall be placed on the market

with the CE marking. The same applies to each valve individually.
To determine whether the joining of valves and piping constitutes an

assembly to be CE-marked or not, see guidelines 3/9, 3/10 and 3/17.
Note 1: An item of piping can integrate a valve along its route. However, the valve
is not considered as a piece of this item of piping. The same applies to any
pressure accessory joined with a piping, for example a filter or a meter.
Note 2: The joining of valves and piping could then be integrated, by an assembly
manufacturer or a user, with other items of pressure equipment to
constitute a PED assembly or an installation submitted to national
regulations (Guideline 3/2). In this case, it may be useful that a contractual
document specifies all the elements that the manufacturer of that joining
will communicate to his purchaser to allow him to check the compliance
to the essential safety requirements of the final assembly or installation.
Note 3: Some linguistic versions are unclear on the terminology used for the
components making up an item of piping.
Accepted by on: WPG: 2003-12-17

Guideline related to: Article 1 paragraph 2.1.3, Annex I section 2.3
Question: A quick opening closure on a pressure vessel is “fitted with a device to

prevent it being opened whenever the pressure or temperature of the
fluid presents a hazard” in accordance with annex I section 2.3.
Is such a preventive device to be considered as a safety accessory

according to the Pressure Equipment Directive (PED)?
Answer: No, according to the definition in Article 1 paragraph 2.1.3, a safety

accessory is designed to protect pressure equipment against exceeding the
allowable limits.
Note 1: However, there are important safety implications for these devices which
are covered by the essential safety requirement 2.3 of the PED. The
manufacturer shall address this as part of the hazard analysis.
Note 2: This control equipment could be of a simple self-acting type or of a more
complicated type, e.g. with a pressure transmitter and an actuator.

Guideline related to: Article 1 paragraph 2.1.3, Annex II
Question: When a safety accessory consists of a safety chain which itself includes
“items of pressure equipment” (for example a valve or a cylinder), in
which category shall this “equipment” be classified?
Answer: When items of pressure equipment are integrated in a safety chain, they
are considered as parts of the safety chain and therefore fall under the
hazard analysis of the safety chain, which include the pressure
containment aspect of this item. When the hazard analysis of the safety
chain shows that the failure of an individual item of pressure equipment
within the chain would have no detrimental effect on the safety function to
be ensured (i.e. fail-safe), the requirements of a category lower than
category IV for the said "item of pressure equipment" can satisfy the
requirement resulting from the hazard analysis of the safety chain.
Its integration in the safety chain is achieved by using the category IV or

the category of the equipment for which the chain is specifically designed.
Note 1: This does not preclude the use of standard CE-marked items of pressure
equipment as parts of a safety chain.
Note 2: A safety accessory, even when it is a safety chain, cannot be classified as

an assembly.

Guideline related to: Article 1 paragraph 2.1.1, Article 1 paragraph 2.5, Article 9
paragraph 3
Question: How to determine the category of a hermetically sealed refrigeration

compressor?
Answer: Hermetically sealed refrigeration compressors are pressure vessels.
Usually, a compressor is composed of two chambers: the low pressure

side PS1, the volume of which is V1, and the high pressure side PS2, the
volume of which is V2. The equalizing pressure during standstill is PS3
(always higher than PS1).
The category is the higher of the low pressure side (based on PS3 and V1)
and of the high pressure side (based on PS2 and V2).
See guideline 1/12.
Note 1: The highest pressure cannot occur simultaneously on both sides; during
standstill there is no direct communication between the 2 chambers, due
to the presence of the valves; if a valve fails, the movement of the piston
cannot create pressure.
Note 2: When a compressor has more than 2 chambers (i.e. several chambers
constitute the low pressure side and several chambers constitute the high
pressure side) the above volumes V1 and V2 are the sums of the low
pressure and the high pressure chambers respectively.

Question: Some piping is provided with a double envelope. How do these double
envelopes have to be considered?
Answer: These double envelopes are to be considered as part of piping if the

function of these double envelopes cannot be disassociated from the
internal piping intended for the transport of the fluids.
Reason: The technical rules for the design and the manufacture of these double
envelopes are usually the same as those for piping.
Note 1: The double envelopes of piping covered by this guideline are of two
types:
- those intended to insulate products transported by the internal piping by

circulation of a fluid (vapor, coolant, glycol water, etc);
- or those intended to ensure the containment of the product transported in

the event of loss of tightness of the internal piping (double envelope for
the transport of very toxic fluids for example).
Note 2: This guideline does not address heat exchangers (see guideline 2/4), or
reactor loops.

Question: Are hot blast stoves, which heat incoming cold air to a blast furnace
by a regenerative process, covered by the exclusion in Article 1
paragraph 3.11?
Answer: Yes, they are excluded.
Reason: While recuperators and hot blast stoves operate in different ways, the first
heating incoming cold air by heat exchange with another hot gas and the
second by the firing of an alternative heat source, they can be considered
similar for the purposes of exclusion under this article. Those hot blast
stoves should be included under Article 1 paragraph 3.11.

Guideline related to: Article 1, paragraph 2.1.2 and 2.1.4
Question: How to consider, for the application of PED, a condensate trap

installed on piping?
Answer: A condensate trap is intended to play an operational role which is the

collection of condensates. Therefore it is generally considered as a
pressure accessory, placed on the market with CE marking where
appropriate.
However, a condensate trap specifically designed and manufactured as a

part of a given item of piping may be assessed as part of the whole piping
and, in that case, is not subject to individual CE marking.

Question: What kind of silencers is covered by the exclusion of Article 1

paragraph 3.16?
Answer: This exclusion concerns only exhaust and inlet silencers that are subjected
to a back-pressure lower or equal to 0,5 bar.
Generally these devices are directly in contact with atmosphere.
Silencers subjected to a back-pressure higher than 0,5 bar (for example

outlet silencer of a booster) are submitted to the directive as pressure
accessories.

Guideline related to: Article 9, paragraphs 2.1 and 2.2
Question: Article 9 classifies fluids with reference to Article 2 (2) of Directive

67/548/EEC. This directive will be repealed by the Regulation No
1272/2008 (“CLP Regulation”). In this regulation the classification of
some substances has changed. Which document shall be used for the
determination of the fluid group and then the applicable category of
pressure equipment?
Answer: The classification according to Directive 67/548/EEC shall be used

provided the PED is not amended or revised on this issue but not after 1
June 2015 when the Directive 67/548/EEC is repealed.
Reason: The Classification in the PED refers to a restricted range of risks related to
substances to categorize items of pressure equipment for their pressure
hazard.
The impact of the CLP Regulation on the classification of items of

pressure equipment will be assessed, and an appropriate update of
Directive 97/23/EC will be proposed before 1 June 2015.

Guideline related to: Article 1 paragraph 2.1.3, 2.1.4 and 2.1.5
Question: How to apply the Pressure Equipment Directive (PED) to a pressure

accessory equipped with a safety accessory?
Answer: The pressure accessory does not become a safety accessory by putting
both accessories together. The combination does not expand the different
functions of the individual items.
Both accessories shall be subjected to appropriate conformity assessment

and marking.
Note 1: A pressure accessory equipped with a safety accessory is not an assembly

because it does not constitute a functional whole as per Article 1
paragraph 2.1.5. See also Guideline 3/8.
Note 2: The global conformity assessment is conducted on the assembly, the

functional whole, placed on the market.

3. ASSEMBLIES
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

3.1. Guideline 3/1
Guideline related to: Articles 10.2 and 3.2.1
Question: Must the global conformity assessment procedure be applied to

assemblies covered by article 3.2.1, e.g. to boilers, even if the
assembling is done under the responsibility of the user?
Answer: No.
Reasons: PED Article 1.2.1.5 states that “assembly” in the sense of the directive
must be assembled by a manufacturer, otherwise it is not in the scope of
the directive. This is further supported by recital 5 last sentence. An
installation performed by or under the responsibility of the user would
normally not be under the scope of the Directive. It would be under the
applicable national legislation. See guideline 3/2.

3.2. Guideline 3/2
Guideline related to: Article 1.2 and 3.2
Question: Are joining operations on site covered by the PED?
Answer: For the joining on site of components or equipment, two cases have to be
considered:
1) Joining of component parts: joining of component parts to

comprise an item of pressure equipment is subject to the requirements of
the Directive. The manufacturer –even if he is the user- has the
responsibility that the resulting item of pressure equipment is in
compliance with the Directive.
2) Joining of items of pressure equipment.
The joining is not covered by the PED if it is carried out to constitute an

installation (1) under the responsibility of the user but remains covered by
national rules.
If the joining is carried out under the responsibility of a manufacturer to

constitute an assembly covered by the definition given in Article 1.2.1.5,
this assembly must fulfil the requirements of the Directive.
Reason: The fifth recital of the Directive says: « This Directive does not cover the
assembly of pressure equipment on the site and under the responsibility of
the user, as in the case of industrial installations ».
Notes: (1) The definition of assembly in Article 1.2.1.5 is limited to those

assemblies assembled by a manufacturer. When items of pressure
equipment or assemblies are being put together by a user, to avoid
confusion, the term “installation” is used.
(2) See also guideline 3/8
Accepted by Working Group « pressure » on: 2000-11-08

3.3. Guideline 3/3
Question: The effect of the derogation in Article 3.2.3 from the introductory
paragraph in Article 3.2 is not clear. In the circumstances, how should
Article 3.2.3 be applied?
Answer: The assemblies set out in Article 3.2.3 must comply with the essential
requirements referred to in 2.10, 2.11, 3.4, 5(a) and 5(d) of Annex I of the
Directive, even if all the items of pressure equipment comprising the
assembly fall under Article 3.3.
Reason: This was the intention of the Member States which proposed the text and
the intention of the Council when approving the text.

3.4. Guideline 3/4
Guideline related to: Article 3 section 2.1 and Annex I section 5
Question: What shall be the minimum extent of the assembly "boiler" which
shall be subjected to a global conformity assessment procedure in
accordance with article 3 section 2.1?
Answer: The assembly shall comprise, as a minimum, the boiler including all the
pressure parts from the feedwater inlet (including the inlet valve) up to
and including the steam and/or hot water outlet (including the outlet valve
or, if there is no valve, the first circumferential weld or flange downstream
of the outlet header). This includes all economisers, superheaters and
inter-connecting tubing which may be exposed to a risk of overheating
and are not capable of isolation from the main system by interposing shut-
off-valves. Additionally included are the associated safety accessories and
the tubing connected to the boiler involved in services such as draining,
venting desuperheating, etc., up to and including the first isolating valve in
the tubing line downstream of the boiler.
Note 1: This definition is based on draft standard prEN 12952-1:1997 and is in

conformity with annex 1 section 5 of the directive.
Note 2: This is a MINIMUM definition of the assembly.
Note 3: The ISOLATABLE superheaters, reheaters, economisers and related

interconnecting tubing are not part of this minimum assembly. They can
bear a CE marking separately or be integrated in the assembly if the
manufacturer wishes so;
Note 4: The means of providing the boiler with feedwater and the means of
preparing and feeding the fuel to the boiler are not part of this minimum
assembly. They can bear a CE marking separately or be integrated in the
assembly if the manufacturer wishes so.
Accepted by Working Group "pressure" on: 1999-11-08 (editorial change by WPG

on 2001-02-20)

3.5. Guideline 3/5
Guideline related to: Article 3 paragraph 2.3, Article 15 paragraph 2, Annex II table 4
Question: Shall the assemblies defined in the Article 3 paragraph 2.3 carry the
CE-marking?
Answer: Yes, in accordance with Article 15 paragraph 2, but the identification

mark of the notified body is left out if the manufacturer has selected the
use of module B1.
Reasons: The applied conformity assessment procedure is defined in table 4 of the

Annex II, where the modules B1 and H are given as alternatives. In the
case of module B1 there is no notified body involved at the production
control phase, and according to article 15 paragraph 1 no identification
mark is accompanied.
Note: Article 3 paragraph 2.3 assemblies to be CE-marked shall comprise, as a

minimum, the boiler with its protection devices.

3.6. Guideline 3/6
Guideline related to: Annex I, sections 3.2.2 and 7.4
Question: Must a hydrostatic pressure test be carried out on an assembly and

should the value laid down in section 7.4 then be followed?
Answer: Using the global conformity assessment of Article 10.2, each item of
pressure equipment and the integration of the items of pressure equipment
(Annex I, section 2.8) should be assessed.
Annex I, first preliminary observation determines that the requirements of

Annex I also apply to assemblies, if corresponding hazard exists.
Each item of pressure equipment making up the assembly and referred to

in Article 3.1 shall meet Annex I, section 3.2.2, and the pressure
containment aspects for the connections/joinings should be assessed by
appropriate methods, for example pressure test, NDT.

3.7. Guideline 3/7
Guideline related to: Article 10.2 (a)
Question: Which conditions shall be used in the assessment of an item of

pressure equipment referred to in Article 3.1 without a separate CE-
marking in an assembly being subject to the global conformity
assessment procedure?
Answer: The conditions to be used to determine the category of this item shall be:
- the volume or nominal size DN, as appropriate, of the item ;
- at least the conditions PS, TS or group of fluid, for which the assembly
is designed, which can be lower than the intrinsic conditions of the item.
For safety accessories, article 2 of Annex II applies.
Reasons: According to article 10.2. (a) the global conformity assessment procedure
shall comprise assessment of each item of pressure equipment making up
the assembly and referred to in Article 3 (1) which has not been
previously subjected to a conformity assessment procedure and to a
separate CE marking. The assessment procedure shall be determined by
the category of the item, which may be based on the conditions of the
assembly.

3.8. Guideline 3/8
Question: Can some guidance be provided on the terms used in the definition of
an assembly?
Answer: Items of pressure equipment form an assembly if :
1. they are integrated, i.e. they are connected and designed to be

compatible with each other and
2. they are functional, i.e. together, they achieve specific, overall
objectives and could be put into operation, and
3. they form a whole, i.e. all the items which are necessary for the
assembly to function and be safe are present and
4. they are assembled by one manufacturer who intends the resulting
assembly to be placed on the market and who will subject the
assembly to a global conformity assessment procedure.
It is irrelevant whether completion of the assembly takes place at the

manufacturer workshop or by the manufacturer on site.
Other factors will need to be considered to determine whether the

Directive applies to a particular assembly. (See guideline 3/2).
Some possible examples of assemblies are pressure cookers, portable

extinguishers, breathing apparatus, skid mounted systems, autoclaves; air
conditioner, compressed air supply in a factory, refrigerating system, shell
boilers, water tube boilers, distillation, evaporation or filtering units in
process plants, oil heating furnaces.

3.9. Guideline 3/9
Guideline related to: Article 1, section 2.1.5, Article 10, section 2
Question: Does the Pressure Equipment Directive put formal upper limits to the
extent of an assembly?
Answer: The PED does not limit the extent of an assembly, which can range from
simple standard products up to large complex industrial plants.
An assembly can itself be composed of other assemblies and further items

of pressure equipment.
For such a final assembly, two cases are possible:
1) When a manufacturer places on the market a product as a final

assembly, consisting of assemblies and items of pressure equipment,
intended to be put into service as such, he has to perform the global
conformity assessment resulting in the CE-marking of the final
assembly. If some of the constituent assemblies are not CE-marked –
see guideline 3/10 - the individual items of pressure equipment shall be
included in the global conformity assessment.
2) When a user takes the responsibility for the final assembly, it

constitutes an installation as explained in guideline 3/2.
Note: The definition of an assembly is explained in guideline 3/8.
Acceptedby WPG on : 2001-08-31

Guideline related to: Article 3 paragraph 2.2, Article 14 paragraph 3, Article 15

paragraph 2
Question: Is it possible to put assemblies on the market which are not CE-
marked?
Answer: Yes, for assemblies referred to in Article 3, paragraph 2.2:
– If the intention of the manufacturer is to place on the market an

assembly not to be put into service as such but to become part of a bigger
assembly or installation (see guideline 3/2), the global conformity
assessment according to PED does not need to be applied to this assembly,
which in this case will not be CE-marked. In this case, conformity
assessment according to PED shall have been conducted for each item of
pressure equipment.
– However, if the intention of the manufacturer is to place on the

market an assembly to be put into service as such, the global conformity
assessment procedure described in the directive must be conducted,
resulting in the CE-marking of the assembly.
For boilers (Article 3 paragraph 2.1) refer to guidelines 3/1, 3/4 and 3/5.
Note 1: Assemblies the conformity of which has been assessed by a user

inspectorate shall not bear the CE-marking.
Note 2: Assemblies in accordance with Article 3 paragraph 3 shall not bear the
CE-marking (see guideline 2/18).
Note 3: This does not restrict the integration of CE-marked assemblies into bigger
assemblies.

Guideline related to: Article 20; Article 3, section 2, Article 10, section 2.a)
Question: If an item of pressure equipment complies with national pre-PED

Regulations and is placed on the market on, or before, 29 May 2002, is
it possible for it to be subsequently included in an assembly which is
placed on the market after 29 May 2002?
Answer: Only if it is shown that such pre-PED item of pressure equipment also
complies with the requirements of the directive.
If an assembly, as referred to in Article 3, section 2, is placed on the

market after 29 May 2002 then it must comply with the Directive. This
requirement can only be met if the individual items of pressure equipment
which form the assembly also comply with the Directive. This is achieved
by using the global conformity assessment procedure as per Article 10.2a,
where required (see also guideline 3/7).

Guideline related to: Article 10 paragraph 2; Annex I
Question: Do only the essential requirements given in Article 10 paragraph 2

apply to assessment of the integration of assemblies?
Answer: No, according to Annex I, first preliminary observation, the requirements

of Annex I also apply to assemblies, where the corresponding hazards
exist.
Examples of other ESRs which may be relevant to assemblies: 3.1.2

Permanent joining, 3.2.2 Proof test (see guideline 3/6), 3.4 Operating
instructions, 6 (a) and (d) Thermal expansion and vibration of piping, …

Guideline related to: Article 1 paragraph 2.1.5, Article 3 paragraph 2.2, Article 10
paragraph 2
Question: When several items of pressure equipment are assembled by a
manufacturer to constitute a functional whole, and when one or
several of those items are excluded from the PED, is the resulting
whole considered as an assembly covered by the PED ?
Answer: The definition 2.1.5 of Article 1 does not prohibit non PED pressure
equipment (pressurised equipment excluded by Article 1 paragraph 3) to
be included in an assembly covered by the PED.
In the case of a PED assembly, the global conformity assessment required
by Article 10 paragraph 2 does not include the assessment of non-PED
items of pressure equipment.
The assessment of
- the integration of the assembly
- the protection of the assembly against exceeding the permissible
operating limits shall be conducted in the light by the highest category of
PED items of pressure equipment included, but it shall also take account
of the characteristics of the non-PED equipment.
Note 1: A hydraulic system of an item of machinery can meet the definition of

Article 1 paragraph 2.1.5, but as it is not intended to be put into service as
such, it is not covered by Article 3 paragraph 2.2 (see guideline 3/10). On
the other hand, a refrigeration system is considered to be a PED assembly
even if some of the pieces under pressure are excluded from PED.
Note 2: In the sense of PED, an assembly is a pressurised system; a machine-tool,
an earthmoving machinery, an agricultural tractor, a mobile crane is not,
as a whole, a PED assembly.

Guideline related to: Article 1 paragraph 2.1.5, Article 3 paragraph 2.3, Annex II, table 4
Question: Article 3, paragraph 2.3 states that the manually fed assemblies must
comply with certain essential requirements. Furthermore article 1,
section 2.1.5 states that the assemblies shall be assembled by the
manufacturer.
Assuming that the manufacturer wants to use EC design-examination
(module B1) in accordance with annex II, table 4, is it then sufficient
that the manufacturer of the boiler gets an EC design-examination
certificate or shall it be the installer (plumber), who assembles the
protective devices to the boiler on site that must obtain the EC design-
examination certificate?
Answer: As stated in guideline 3/5, Article 3 paragraph 2.3 assemblies comprise, as

a minimum, the boiler with its protective devices.
However, it is sufficient that the manufacturer of the boiler gets an EC

design-examination certificate, provided that he clearly specifies in his
installation instructions which protective device can be used in the
assembly and how it shall be installed.
The installation instructions shall be part of the EC design-examination.
Note: The module B1 assessment shall comprise essential safety requirements

from Article 3 paragraph 2.3 as well as the operating instructions.

Guideline related to: Article 10 paragraph 2, Annex I section 3.1.2
Question: How are the categories of permanent joints in an assembly to be

determined?
Answer: The category of permanent joints between the items of pressure equipment
of an assembly shall be determined individually, taking into account the
effect of the joining on the integrity of each of the items to be joined.
For example, the connection of a pipe to a vessel through a nozzle

(already connected to the vessel) will, in general, be made according to the
category of the pipe, provided that it does not affect the integrity of the
vessel.
Note 1: For assemblies, the directive defines a global conformity assessment

procedure and determines the category to be followed for essential safety
requirements related to design (as stated in Article 10 paragraph 2b), and
for the assessment of the protection (as stated in Article 10 paragraph 2c).
For the other essential safety requirements applicable to the assembly (see
guideline 3/12), in the absence of specific information in the directive for
the category, it should be based on the categories of the items concerned.
Note 2: This is consistent with guideline 2/15, which makes a distinction between
the category used for the assessment of the design, and the determination
of the category regarding essential safety requirements.
See also guideline 3/16 for the category of the global conformity
assessment procedure.

Guideline related to: Article 10 paragraph 2b
Question: In Article 10.2.b what does the “highest category applicable to the
equipment concerned” mean?
Answer: The category of each item of equipment making up the assembly is based
on the conditions which can occur in the assembly, taking into account:
- the volume or nominal size DN, as appropriate, of the item ;

- at least the conditions PS, TS, type or group of fluid, for which the
assembly is designed, which can be lower than the intrinsic conditions
of the item.
The highest category determined from these conditions will then

determine the assessment of the integration of the items in the assembly.
Note: When determining the conformity assessment module(s) for an assembly,

it is possible to assign to an item of pressure equipment a lower category
than that to which it was originally assessed. As a consequence, an
assembly which is covered by Article 3 paragraph 3 can include a CE-
marked item of pressure equipment.

Guideline related to: Article 1 paragraph 2.1.5; Article 10 paragraph 2, Annex I sections
2.10, and 3.2.3
Question: Is it permissible to place on the market a CE marked assembly not

equipped with protective devices where there is a risk of exceeding the
allowable limits?
Answer: No, see guidelines 3/8, 3/9, 3/10 and 5/6.
Note 1: As required in Annex I section 3.2.3, the final assessment of the assembly
includes checking of the safety devices. In some cases, this can be done
only after assembly at the user's premises.
Note 2: The Declaration of Conformity shall not be drawn up for the assembly
until the checking of safety devices has been completed.

Guideline related to: Article 10 paragraph 2, Article 15 paragraph 3, Annex I section 3.3
Question: When items of pressure equipment making up an assembly have not

been previously subjected to an assessment and are therefore assessed
at the same time as the assembly in accordance with the point a) of
article 10 paragraph 2, shall they carry the in-formation required in
annex I section 3.3?
Answer: No.
In that case Annex I section 3.3 requires that an appropriate document

(operating instructions for the assembly) includes the information
specified in this section. It is reminded that the operating instructions shall
clearly identify all items of pressure equipment making up the assembly.
Reason: As the product put on the market is an assembly, the requirements only
apply to this assembly. This is confirmed by Article 15 paragraph 3.
Note 1: In conformity with Annex VII of PED, the declaration of conformity of

the assembly must also contain the description of the items of pressure
equipment constituting the assembly (See also guideline 10/8).
Note 2: This does not preclude the assembly manufacturer from marking
appropriate characteristics on items of equipment which can be necessary
for safe installation, operation or use and, where applicable, maintenance
and periodic inspection.

Question: If, during functional testing of an assembly at the user's premises by

the manufacturer before placing it on the market, modification of an
item of pressure equipment is necessary, shall this modification be
carried out in accordance with Directive 97/23/EC?
Answer: Yes.
It is necessary to assess any modification within the global conformity

assessment of the assembly even if the declaration of conformity for the
item was already issued. This implies checking the technical
documentation of this item by the manufacturer and the notified body to
verify whether the original design is impacted.
Note: See Guidelines 1/3 and 1/4 for modification of pressure equipment in use.

Guideline related to: Article 1 paragraph 3.19, Article 1 paragraph 2.1.5, Article 10
paragraph 2
Question: How to consider a transportable (TPED) pressure receptacle

incorporated in an assembly being placed on the market under PED?
Answer: Two different cases have to be considered:
1) The TPED pressure receptacle will remain transportable pressure

equipment which will be used as gas storage system and further on will
be transported under transport regulations and filled in filling stations.
It is not required to re-assess such TPED pressure receptacle against

PED.
2) The TPED pressure receptacle will permanently become part of a PED

assembly (which means it will only be filled on-site).
The change of status from transportable (TPED) to static (PED)

pressure equipment requires the formerly TPED pressure receptacle to
be categorized and re-assessed against PED.
However for either case the correct incorporation has to be assessed

against PED, see guideline 3/13.
Note: See also guideline 1/33.
Accepted by Working Group «pressure» on: 2014-03-20

4. EVALUATION ASSESSMENT PROCEDURES
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

4.1. Guideline 4/1
Guideline related to: Annex III, module G
Question: Is design approval by a notified body required under module G?
Answer: Module G does not explicitly require formal design approval by a notified
body but it does require the manufacturer to submit to a notified body,
technical documentation to enable the design, manufacture and operation
of the pressure equipment to be understood. It also requires the notified
body to examine the design and construction of the pressure equipment to
ensure its conformity with the requirements of the Directive which apply
to it. It is expected that the notified body will report the outcome of the
examination of the design to the manufacturer and this will effectively
constitute design approval.
Reason: As stated above, module G does not contain any explicit requirement for
approval of the design by the notified body. However, it is understood that
design approval is common practice for the types of pressure equipment to
which module G would be applied. Module G does require that a notified
body must examine the design of the pressure equipment and it is
considered reasonable to expect the notified body to inform the
manufacturer of the results of the examination.

4.2. Guideline 4/2
Guideline related to: Annex III
Question: Can a manufacturer’s existing QA certification which is in

accordance with the standards EN ISO 9000 be taken into account by
the notified bodies when approving QA systems for modules D, D1, E,
E1, H or H1 of the PED?
Answer: A notified body when approving QA systems according to the modules D,

D1, E, E1, H or H1 should take into account that the manufacturer already
has ISO 9000 certification particularly if it has been certified by an
accredited certifying organisation. However, the notified body has overall
responsibility for ensuring that the QA systems satisfy the pressure
equipment directive in particular on aspects in pressure equipment
technology.
Reason: Q.A. systems under the modules D, D1, E, E1, H or H1 must cover the
technical aspects in relation to the pressure equipment.

4.3. Guideline 4/3
Question: How to apply conformity assessment modules when some parts of an

item of pressure equipment or some operations are sub-contracted?
Answer: There is only one manufacturer taking responsibility for each item of
pressure equipment, who chooses one module (or combination of
modules).
The conformity assessment is related to an item of pressure equipment and

not to the parts considered alone.
It is the responsibility of the pressure equipment manufacturer to obtain

from his sub-contractor the information and documentation required for
the application of the module chosen. Depending on the module, the
notified body could be required to visit the sub-contractor site, and it is the
responsibility of the pressure equipment manufacturer to ensure access. If
relevant work has been performed by different notified bodies at the sub-
contractor site, it should be taken into account.
See also the Blue Guide (Guide to the implementation of directives based
on New approach and Global approach) 3.1.1

4.4. Guideline 4/4
Question: If a manufacturer chooses to apply module B or B1 for the design

phase, in combination with another module for the production phase,
does the manufacturer have to choose the same notified body for the
design and production modules?
Answer: No.
As requested by modules B and B1 (Annex III, points 5 and 6 of the

corresponding modules), the examination certificate shall annex a list of
the relevant parts of the technical documentation and any other relevant
information, which allow the requirements of the production modules to
be applied.
The number to be affixed to the pressure equipment is the number of the

body involved at the production control phase (Article 15).

4.5. Guideline 4/5
Guideline related to: Annex III, module B1
Question: Clauses 3 and 4 of module B1 in Annex III deal with information

concerning qualifications or approvals of permanent joining that may
not be available at the design stage. What are the minimum
requirements in clause 3, last indent, and clause 4.1, 2nd and 3rd
indents?
Answer: Approval of operating procedures for permanent joining shall be made at

the design stage, if not previously approved.
For the personnel performing permanent joining and non-destructive tests,

the requirement at the design stage may be limited to the verification of
the criteria for qualifications or approvals.
The need to perform the personnel approval verification at a later

date before start of production should be pointed out in the design
examination certificate.

4.6. Guideline 4/6
Guideline related to: Article 10.2, Annex III
Question: Can an assembly be composed of pressure equipment dealt with using

different conformity assessment modules?
Answer: Yes, by application of Article 10.2a).
For example, the valves can have a module different from that applied to
the vessel or the piping on which they are placed.

4.7. Guideline 4/7
Guideline related to: Annex I, sections 1.2, 3.2.1 and 3.4, Annex III
Question: Shall the manufacturer of pressure equipment submit operating

instructions as part of the conformity assessment by a Notified Body,
and shall the Notified Body verify the content?
Answer: Yes.
PED requires the manufacturer to prepare operating instructions (see

guideline 8/3) and supply them together with the equipment.
Appropriate operating instructions are an essential safety

requirement (ESR) and shall therefore be part of the conformity
assessment procedure.
When the Notified Body's duty includes performing or monitoring

final assessment, it shall verify the existence of operating
instructions and check their compliance with the Directive.
When the Notified Body's duty includes design examination, it shall

verify that the intended use and residual hazards are described, and
are intended to be included in operating instructions.
For modules based on quality systems, the existence of proper

procedures to establish the various elements of the operating
instructions shall be verified as part of the assessment of the quality
system.

4.8. Guideline 4/8
Guideline related to: Annex III, module B1, sections 4.2 and 4.3
Question: Are tests by the notified body required for module B1?
Answer: No.
In contrast to module B, module B1 consists solely of the examination of

drawings, calculations and relevant information concerning
manufacturing. The experimental design method may not be used in this
module. There are no examinations or tests to be performed on a
representative example of the production envisaged.
Note: There is inconsistency in some language versions.

4.9. Guideline 4/9
Guideline related to: Annexes I and III
Question: Is a manufacturer of component required to include a design

examination, proof test and final inspection by a Notified Body if the
component is intended for later use in PED equipment?
Answer: No. Components are not items of pressure equipment, and therefore are
not subject to individual conformity assessment procedures.
For requirements on components to be used in pressure equipment, see

guidelines 1/22 and 7/19.
Note 1: The final inspection including the proof test applies to the complete item
of pressure equipment and not to the component itself.
Note 2: If the component is not designed according to a harmonised standard,

design information may also be requested by the equipment manufacturer.
Note 3: There is no legal basis in PED for a Notified Body to issue a certificate of
conformity for components.


Guideline related to:Article 10, Annex I preliminary observation 3, Annex III
Question: There are many organisations that design pressure equipment that is
subsequently fabricated by another organisation. Is it permissible for
the company responsible for the design to obtain an EC design
examination certificate (B1) and the fabricator obtain an appropriate
certificate for the manufacturing phase, e.g. Product Verification (F).
Answer: No.
Even if different organisations can be involved, the directive clearly

indicates that there can be only one "manufacturer" who is responsible for
design, manufacture and conformity assessment of the pressure
equipment.
The "manufacturer" may subcontract tasks in relation to design and/or

manufacture but must retain overall control and have the necessary
competence to take the responsibility for the product.
See also the Guide to the Implementation of Directives based on New

Approach and Global Approach.
Accepted by WPG on 2003-03-25

Guideline related to: Article 1 Paragraph 2.1.3, Article 3 Paragraph 1.4 and Article 15
Question: Should the holder and the bursting disc which combine to produce a
bursting disc safety device for use above 0,5 bar carry separate CE
marking?
Answer: No, only the complete safety device can be conformity assessed, and only
one CE marking shall be affixed. The CE marking shall be on the holder
which is less likely to be replaced.
The declaration of conformity and instructions for use shall describe in an

appropriate manner the components of the bursting disc safety device, and
instructions for use shall identify which safety discs can be used on a
specific holder.
Reason: Bursting disc safety devices are usually supplied as a set containing one
holder and several spare discs. While both are components of a safety
device and therefore should not be CE marked until assembled, for
practical purposes the holder carries CE marking.

Guideline related to: Annex III Module D, Module D1, Module E, Module E1, Module H
and Module H1
Question: What information shall be included in the quality system approval

notification document issued by the notified body concerning the
scope of products?
Answer: The document for all quality system modules shall contain sufficient
information to clearly define the scope of products covered by the
approval and where applicable, any limitations or restrictions.
The following list of examples is not exhaustive:
- Product description (e.g. pressure vessels, shell boilers, shut-off

valves, safety valves, piping, assembly)
- Product design code(s) applied (e.g. EN 13445, EN 12952, EN 12953,
EN ISO 4126, EN 13480)
- Materials (e.g. ferritic steels, austenitic steels, non-ferrous, metals,
plastics)
- Limitations/Restrictions, if applicable (e.g. dimensions, weight,
performance)
In the case of modules D and E the initial quality system approval

document shall include a listing of the relevant EC-type examination or
EC Design Examination certificates as relevant.
In the case of module H1, it is not required that the results of the EC
design examinations are listed in the initial quality system approval
document.
For module H1, in addition to the requirements of module H, the notified

body must examine the application and, where the design meets the
provisions of the Directive which apply to it, issue an EC design-
examination certificate to the applicant.
The certificate must contain the conclusions of the examination, the

conditions for its validity, the necessary data for identification of the
approved design and, if relevant, a description of the functioning of the
pressure equipment or accessories. So the initial stage of H1 is an
approval of the management system.
In all cases the system must require the assessment of whether new or
modified products will necessitate changes to the quality system, and that
these are submitted to the notified body. The Notified Body shall inform
the manufacturer if a reassessment of the quality system is required or if
the new or modified products are within the scope of the existing system.
In cases where no changes are required, a new quality system approval
document does not need to be issued.
Any re-issue of the document shall update the list of type approval
certificates.
WPG: only written consultation

Guideline related to: Annex I sections 3.2.1 and 3.2.2, Annex III Module F section 4.1
and Module G section 4.
Question: Is it permissible for the Notified Body to delegate the witnessing of the
final inspection and proof test under module F or the proof test under
module G to the manufacturer?
Answer: No.
In modules F and G, means and resources for carrying out the final
inspection and/or proof test can be provided by the manufacturer to the
Notified Body inspector, but the Notified Body shall be present during the
final inspection and proof test.

4.14. Guideline 4/14 (pending)

Guideline related to: Article 15 paragraph 1, Annex III Modules D/D1, E/E1, H/H1
Question: A manufacturer has equipment in stock manufactured under a QA

module (D/D1, E/E1 or H/H1). After expiry of the QA system
certification the manufacturer switches from Notified Body “X” to
Notified Body “Y” for the new certification.
Can the manufacturer deliver equipment with Notified Body number

"X" to his customers after the expiry date of the certificate?
Answer: Yes,
Provided that the final assessment has been performed under the QA
system certified (and surveyed) by Notified Body "X" before the expiry
date of the system certificate.
The manufacturer must keep records of which notified body approval his
equipment was manufactured under. One solution is to include a date on
the declaration of conformity.

5. INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON DESIGN
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5.1. Guideline 5/1
Guideline related to: Annex I Paragraph 2.2.2; Annex I Point 2.2.4
Question: How should the condition related to the experimental design method
without calculation in Annex I, Section 2.2.2 be interpreted stipulating
that:
Experimental design may be carried out without any calculation in

accordance with Section 2.2.4 if the product of the maximum
permissible pressure PS and the volume V is less than 6000 bar.litre
or the product PS.DN is less than 3000 bar?
Answer: It shall be understood that:
- the condition PS.V < 6000 bar.L is applicable to equipment for which
the classification criterion in annex II is the volume (vessels, boilers
and when applicable, accessories, etc.);
- the condition PS.DN < 3000 bar is applicable to equipment for which
the classification criterion in annex II is the nominal size (piping and
when applicable, accessories, etc.).
Note: Module B1 is not applicable to equipment validated by experimental

design.

5.2. Guideline 5/2
Guideline related to: Annex I, sections 2.11.2, 2.12
Question: In respect of pressure limiting devices, does the PED require that the
permitted short duration pressure surge of 1,1 PS be maintained
when the equipment is exposed to external fire conditions ?
Answer: The 1,1 PS restriction does not apply to fire.
Reasons: The requirement in Annex I section 2.12 for external fire refers to damage
limitation, and does not serve the purpose of pressure limiting device in
normal operation.

5.3. Guideline 5/3
Guideline related to: Annex I point 3 of preliminary observations, sections 1.1, 2.1, 2.3
and 2.8
Question: Is leakage of pressure equipment covered by PED?
Answer: Yes, whenever internal or external leakage (i.e. leakage to

atmosphere/environment) is a hazard due to pressure, it is covered by the
essential safety requirements of PED.
All hazards arising from pressure shall be assessed for the intended use
and the intended contained fluid(s), not only the requirement for sufficient
strength but also internal/external leakage and all functional requirements
related to pressure hazards (see also guideline 1/15).
For pressure equipment where the detailed specific use is not known by
the equipment manufacturer, the above consideration shall be addressed
by the assembly manufacturer as per Annex I section 2.8.
Remark: The version of 26 June 2001 is revised to make clear that this guideline
does not only apply to valves.

5.4. Guideline 5/4
Guideline related to: Article 10 paragraph 2(c) and Annex I, sections 1.3, 2.8, 2.9,
2.10, 2.11, 2.12 and 3.2.3
Question: Shall portable extinguishers be equipped with protective devices

against over-pressure?
Answer: The prevention of danger due to overpressurization of fire

extinguishers shall be achieved for all foreseeable circumstances
either by eliminating the hazard by the design, or by providing a
protective device.
The risk of external fire shall be adequately considered according to

the type of fire extinguisher.
Due to the fact that portable extinguishers are very wide-spread and
are also consumer products, their possible misuse (over-filling, use
of incorrect cartridge …) must be carefully assessed. Written
instructions alone cannot be regarded as sufficient.
Examples: In general the risk of over-filling is significant for cartridge type fire
extinguishers, which are manually (re-)filled.
External fire will cause high risks for CO2 fire extinguishers
(cylinders).
In such cases protective devices or similar methods shall be taken to

meet damage limitation requirements.

5.5. Guideline 5/5
Guideline related to: Annex I section 2.1 and section 2.2.4
Question: Is it possible that the sample to be tested for the experimental design
method be produced without its thicknesses reduced by the corrosion
allowance?
Answer: Yes, but the corrosion allowance as well as other characteristics are to be
used as corrective factors to determine the minimum value for the test
pressure, as stated in 2.2.4 a) second paragraph.

5.6. Guideline 5/6
Guideline related to: Article I paragraph 2.1.3, Annex I section 2.10, Annex I section
2.11
Question: Does the essential safety requirement 2.10, which deals with protective
devices, give the choice of the use of a safety accessory or of the use of
a monitoring device?
Answer: No.
When, under reasonably foreseeable conditions, the allowable limits could

be exceeded, a protective device in the form of a safety accessory must be
provided, with the addition, where appropriate, of a monitoring device.
Note: Annex I section 2.11 sets out the essential safety requirements for the
safety accessories that do not apply to monitoring devices. In particular,
safety accessories shall comply with the essential safety requirements by
appropriate design principles. This is in order to obtain suitable and
reliable protection that does not rely on instructions for regular
supervision during use.

5.7. Guideline 5/7
Guideline related to: Annex I section 2.2.2
Question: Are the limits in Annex I section 2.2.2 applicable to components of

pressure equipment (like manhole covers, special flanges, etc)?
Answer: No. The limits specified in Annex I section 2.2.2 second indent concern
the item of pressure equipment, not its components.
The results of the experimental method applied to components are taken

into account in the design of the item of pressure equipment.

5.8. Guideline 5/8
Guideline related to: Annex I Section 2.11.1
Question: In the 3rd paragraph of the essential safety requirement 2.11.1, there
is the sentence “These principles include, in particular, fail-safe
modes, redundancy, diversity and self-diagnosis.”, therefore do all
safety accessories require to be for example “self-diagnosis”?
Answer: No.
The sentence lists a number of separate possible design principles that
could be used to obtain suitable and reliable protection; it is not an
exhaustive list. “Self-diagnosis” is for example part of the list of separate
possible design principles, not an additional requirement. The design
principle to be used for any particular application should be based on the
hazard analysis and could indicate that other methods are just as suitable
or that more than one design principle should be used.

5.9. Guideline 5/9
Question: Is there a value defined for the acceptable limit of the short duration
referred to in Annex I section 2.11.2?
Answer: No
The duration corresponds to the time needed to reduce the pressure below
PS. It depends on the dynamics of transient pressure surges that can be
highly variable from one equipment to another.
The pressure limiting device shall have appropriate characteristics (flow

capacity, set pressure in relation to PS, etc) to relieve the pressure safely.
Accepted by WPG on 2013-04-25

MANUFACTURING
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6.1. Guideline 6/1
Guideline related to: Annex I, section 3.1.2
Question: According to section 3.1.2 (permanent joining) of Annex I, the third

party must perform examinations and tests in order to carry out the
approvals of operating procedures and personnel. Must the
representative of the third party witness the whole permanent joining
and testing process?
Answer: No, in accordance with and under the responsibility of the notified body or
of a third party organisation recognised by a Member State, some practical
tasks concerning the approval of joining operating procedures and
personnel may be accomplished by a competent person of a manufacturer
according to a quality system.
Note 1: The Notified Body or Recognised Third Party Organisation must attend
part of the different steps in the process for each procedure and for each
person.
Note 2: See also section 6.5 of the “Blue Guide”

6.2. Guideline 6/2
Question: Which documents have to be available for the final inspection

specified in Annex I, section 3.2.1?
Answer: In general the following documents should be available as appropriate:
− evidence of qualification of NDT personnel relevant to the equipment

category;
− evidence of qualification of permanent joining personnel relevant to the
equipment category;
− data dealing with heat treatment (e.g. diagram of temperatures);
− inspection documents for base materials and consumables;
− procedures for assuring material traceability;
− NDT test reports, including radiographic films;
− test reports of destructive tests (e.g. test coupons);
− reports on defects or deviations arising during manufacture;
− data related to the preparation of component parts (e.g. forming
chamfering);
− evidence of qualification of permanent joining procedures;
These documents shall be available for final inspection whether that

inspection is carried out by the manufacturer, the user inspectorate or the
notified body.
Outcome of WGP discussions on 28/1/1999: To indicate that the need for documents for
final inspection can vary depending on the case, the first sentence of the answer has been
changed to start with “in general”. An editorial amendment has been inserted in the last
dash of the answer.
WGP agreed to the proposal. However, WPG was asked to include a requirement on the
submission of some drawings.

6.3. Guideline 6/3
Guideline related to: Annex I, points 3.1.1 and 3.1.2
Question: How to interpret point 3.1.1 of Annex I as far as the forming

procedures are concerned?
Does it impose for the manufacturer a qualification procedure for

forming operations which will be validated by the Notified Body?
Answer: The Directive does not require for qualification of forming procedures in
point 3.1.1 of Annex I, although it includes such a qualification for
permanent joints in point 3.1.2 of Annex I.
But there is an essential requirement about the preparation of the

component parts (cf Annex I, point 3.1.1) and the manufacturer shall
demonstrate in the technical documentation of the equipment that this
requirement has been satisfied.
Depending on the modules, the Notified Body may examine this technical
documentation.

6.4. Guideline 6/4
Guideline related to: Annex I, point 3.1.2
Question: Must a Notified Body take into account a procedure of permanent

joints qualified by another Notified Body or a recognised third-party
organisation?
Answer: Yes, a Notified Body is not allowed to reject an approval of procedure of

permanent joints made on the basis of a precise reference and applying
competence in accordance with the PED.
Nevertheless, it is its responsibility to verify, if needed, that the joining

process and the reference to the manufactured product are adequate.

6.5. Guideline 6/5
Guideline related to: Annex I, points 3.1.2 and 3.1.3
Question: Do the requirements related to permanent joints given in Annex I,

sections 3.1.2 and 3.1.3 apply also to permanent joints other than
welded joints?
Answer: Yes.
Reason: The definition in Article 1 paragraph 2.8 also covers other permanent
joints such as e.g. those produced by brazing, braze welding, expansion,
gluing, frettage and riveting.
For that reason, the requirements of 3.1.2 and 3.1.3 apply also for these
types of joints.
Note: Removable expansion devices (e.g. expansion plug for sealing exchanger
tubes) do not require destructive methods to be disconnected and therefore
are not permanent joints.

6.6. Guideline 6/6
Guideline related to: Article 1 paragraph 2.8, Annex I section 3.1.2
Question: In the absence of harmonized standards, what approach is to be

followed for the approval of personnel carrying out permanent
joining?
Answer: In the absence of harmonized standards, the manufacturer shall refer to an

existing document (draft standard candidate for harmonization,
professional document, guide, recognised third party/notified body
document, company document, etc.) or shall establish a specific
document.
Such a document shall define at least:
− equipment to be used by the personnel;

− degree of automatization of the process and the operations to be carried
out by the personnel;
− conditions to apply when making the test piece to be used for the test
approval and results to be achieved;
− range of validity and conditions for the duration of the validity.
For welding, see Guideline 6/12.

6.7. Guideline 6/7
Question: Does the concept of non-destructive testing as mentioned in Annex I

section 3.1.3 also cover visual examination?
Answer: No.
Consequently, section 3.1.3 in Annex I is not applicable to personnel

undertaking "visual testing" as dealt with in EN 473:2000.

6.8. Guideline 6/8
Question: What are ”the appropriate harmonized standards” in Annex I,

section 3.1.2, last paragraph, which set out the examinations and tests
for the approval of permanent joining procedures and personnel ?
Answer: The appropriate harmonized standards are
− the specific harmonized supporting standards, subject to verification of

their suitability for the equipment being built.
or
− the relevant harmonized product standards.
In both cases the relevant requirements of PED Annex I section 3.1.2 are
to be covered by the standard and these provisions are to be referenced in
Annex ZA.

6.9. Guideline 6/9
Guideline related to: Annex I sections 3.1.1, 3.1.2, 3.1.3 and 7.2
Question: Does the Pressure Equipment Directive require accreditation for the
manufacturer’s testing laboratory that carries out non-destructive
tests (NDT) or destructive tests (DT) of pressure equipment or of
parts intended as pressure bearing parts of pressure equipment?
Answer: No.
According to Annex I section 3.1.3 the PED requires qualification for

NDT personnel that carry out NDT of permanent joints. No accreditation
is required for the manufacturer’s NDT or DT laboratory or for the testing
laboratory that the manufacturer may subcontract for NDT or DT.

Question: If a manufacturer has a procedure for permanent joining approved

by a notified body or other recognized third-party organization at one
site (location), may that manufacturer use the same procedure at
other sites for similar applications?
Answer: Yes, provided the other sites are under the same technical and quality
management.
Note: Standard EN 719 on welding co-ordination and standard EN 729-1 on

quality requirements for welding define manufacturing organization as
welding workshops or sites under the same technical and quality
management. Standard EN 288-3 on welding procedure tests states that
an approval of a welding procedure specification (WPS) obtained by a
manufacturer is valid for welding in workshops or sites under the same
technical and quality control of that manufacturer.

Guideline related to: Article 1 paragraph 2.8, Annex I section 3.1.2
Question: In the absence of harmonized standards, what approach is to be

followed for the approval of permanent joining procedures?
Answer: In the absence of harmonized standards, the manufacturer shall refer to an

existing document (draft standard candidate for harmonization,
professional document, guide, recognised third party/notified body
document, company document) or shall establish a specific document.
Such a document shall define at least:

− essential variables for the procedure that may affect the properties of
the permanent joining;
− inspection and testing to be carried out for the qualification of the
procedure;
− acceptance criteria ;
− range of validity.
Note: The directive states that “the properties of permanent joints must meet the
minimum properties specified for the materials to be joined unless other
relevant property values are specifically taken into account in the design
calculations”.
For welding, see Guideline 6/12.

Question: In the context of approval of welding procedures and personnel, what

is meant by “the third party must perform examinations and tests as
set out in the appropriate harmonized standards or equivalent
examinations and tests”?
Answer: Where the directive refers to equivalent examinations and tests it is

required that suitable and sufficient tests are conducted to determine the
same range of technological properties as those in the harmonized welding
standards. Where similar tests have already been conducted that establish
a particular property but the precise testing conditions vary from those in
the above standard, there is no requirement to repeat the test. However,
those technological properties which are not the subject of these similar
tests shall be added to the testing schedule. If for example the impact
property in the weld has already been tested but not the heat affected zone
(HAZ), this latter remains to be tested.
Note 1: The tests which are intended to determine the same range of technological
properties are the non destructive and destructive tests required by the
relevant harmonized welding standards.
Note 2: The additional tests shall be performed under the responsibility of a

competent third party (see also Guideline 6/1).
Note 3: The current version of ASME Boiler & Pressure Vessel code Section IX is
an example of where properties are not sufficiently dealt with for some
applications in order to comply by itself with the PED (for example:
impact property in the HAZ; hardness test etc.). Furthermore, it does not
require that the tests and examinations shall be performed under the
responsibility of a third party (see also Guidelines 6/1 and 6/4).

Guideline related to: Annex I section 3.1.3.
Question: For pressure equipment in categories III and IV, can Non-Destructive
Testing personnel holding qualifications other than those satisfying
criteria of the harmonised standards (e.g. EN 473:2000 General
principles for qualification and certification of NDT personnel) be
approved by Recognised Third Party Organisations (RTPO) notified
by a member state under Article 13 paragraph 1?
Answer: Yes.
NDT personnel certified under standards, other than the harmonised

standards, may be approved by a RTPO provided it is satisfied that
certification criteria equivalent to the harmonised standards have been
met, and that the scope of certification is relevant to the testing of
permanent joints in pressure equipment.
A RTPO may sub-contract part of its work, within the provisions of the
New Approach guide, but shall keep the full responsibility and issue the
approval. The approval of the personnel shall be done by a RTPO on an
individual basis.
Note: Approval of an individual solely on the basis of a certificate issued by

another body where no contractual arrangement exists with the RTPO
does not fulfil the requirement of the Pressure Equipment Directive.

Guideline related to: Annex I sections 3.1.1 and 3.1.2
Question: Does any welding operation on a pressure bearing component have to

require a qualification of the welding procedures and of the
welders/welding operators?
Answer: Yes, when the weldment can create a pressure hazard on the pressure
bearing component.
Examples of welding operation for which qualification is required

according to Annex I section 3.1.2 include:
1) Welding of a lifting lug on a pressure bearing chamber;

2) Welding of an attachment to a valve body;
3) Welding of reinforcing pads for nozzles;
4) Repair by welding on a chamber before placing on the market;
5) Major welding on a casting during production.
Examples of welding operations for which qualification is required

according to Annex I section 3.1.2, unless the hazard analysis
demonstrates that there is no pressure hazard, include:
1) Minor welding on a casting during production;

2) Buttering of a tubesheet;
3) Overlay welding on a pressure chamber (anticorrosive, wear
coating…).

Question: Where approval of operating procedures for permanent joining is

required by the PED and the approval is granted on the basis of a
document other than a harmonized standard, should this approval
explicitly mention the PED?
Answer: Yes.
The approval certificate should also indicate the tests performed in

addition to those in the document used for approval.
If certificates do not include a reference to the PED, the application of the

last paragraph of Annex I section 3.1.2 shall be checked through the
detailed examination of the WPQR (Welding Procedure Qualification
Record).
Remark: Reservation by Sweden

Guideline related to: Annex I Section 3.1.2 and 3.2.2
Question: Do the essential safety requirements apply to temporary components

used by the equipment manufacturer either during the manufacturing
or for the proof test of a pressure equipment?
Answer: No, unless the joining of this temporary component, for example by
welding, is likely to affect the safety of the equipment during its future
operation.
However, the manufacturer is responsible for the application of these

components, which must have an adequate level of safety and meet the
national labour regulation. Examples of temporary components: temporary
closure for proof testing, lifting lugs welded on an additional thickness to
be removed later.

Question: Is the manufacturer allowed to replace non permanent joining

components (bolts, studs, nuts, washers, gaskets) at the end of the
proof test without carrying out a new proof test?
Answer: Yes
Note: The manufacturer should ensure that the replacement components are
equivalent to those specified in the technical documentation.

Pending

Question: The Essential Safety Requirements define in Annex I chapter 3.1.2

that the properties of welded joints shall meet the minimum
properties specified for the materials to be joined unless other
relevant property values are specifically taken into account by the
design process.
Do these requirements apply also for impact property values?
Answer: Yes, in general also the impact property values shall meet the specified
minimum properties of the materials joined.
Lower values are acceptable if specified by the product standard or

justified by the design.
Annex I, 4.1(a) refers to 7.5 regarding specific requirements of materials.

To reach sufficient ductility for steel the impact value shall be at least 27 J
at lowest operating temperature.

7. INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON MATERIALS
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MANUFACTURING
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7.1. Guideline 7/1
Guideline related to: Annex I, section 4.2 b)
Question: What is to be understood by harmonised standard as referred to in

Annex I, section 4.2 b)?
Answer: A harmonized standard in this context can be a harmonized product

standard for an item of pressure equipment or an assembly which may be
CE marked.
It could also be a harmonized supporting standard for materials, that

contains technical data clearly indicating the field of application.
In the case of a harmonised supporting standard for materials,

presumption of conformity to the ESRs is limited to technical data of
materials in the standard and does not presume adequacy of the material
to a specific item of equipment. Consequently the technical data stated in
the material standard shall be assessed against the design requirements of
this specific item of equipment to verify that the ESRs of the PED are
satisfied.
Note: Subsequent manufacturing processes affecting properties of the base

material shall be taken into account when assessing the conformity of the
pressure equipment to the material requirements of the directive.

7.2. Guideline 7/2
Guideline related to: Annex I, section 4.3, third paragraph
Question: What is a ‘competent body’ for the certification of the quality

(assurance) systems of material manufacturers?
Answer: A ‘competent body’ for certification of the quality systems of material

manufacturers can be any third party body established as a legal entity
within the Community which has recognized competence in the
assessment of quality (assurance) systems for the manufacture of
materials and in the technology of the materials concerned. Competence
can be demonstrated, for example, by accreditation.
Note 1: A body not established as a legal entity within the Community, even if it
has a recognition agreement through the International Accreditation
Forum, does not comply with the requirements of Annex I section 4.3.
Note 2: A notified body may perform this task only if it has a recognized
competence in the field of quality assurance, materials and related process
technology. For this certification, the possible use of the notification
number for PED is irrelevant.
Note 3: The certificate of quality system shall make reference to the legal entity
established in the Community and its address.

7.3. Guideline 7/3
Guideline related to: Article 11.2
Question: A notified body is in the process of giving a European approval for

materials. In Article 11.2 an information process with delays is given.
Having sent out the information the notified body must wait for
comments. How long must the body wait?
Answer: The approval can be given three months after the mailing date of the
information, with one exception: if a Member State or the Commission
refers the matter to the Standing Committee set up by Article 5 of
Directive 98/34/EC (ex 83/189/EEC), it must inform the notified body
which must wait for a letter from the Commission giving the conclusions
of the Committee.

7.4. Guideline 7/4
Question: What are the ’suitable means’ for traceability referred to in annex I,
section 3.1.5?
Answer: The objective of traceability is to avoid any doubt about the material
specification used for a type of equipment. The suitable means shall be
determined according to the type of equipment and its manufacturing
conditions: for instance, complexity of the product, unitary or serial
products, risk of mixing of material grades, etc.
These means range from physical marking of individual items by

stamping or colour coding to procedural methods. It is not always
necessary for the identification of material to be linked to a specific
delivery.
The traceability system should be proportionate to the risk of mixing

material grades during the manufacturing process. When there is no such a
risk, the system may be limited to administrative means.
Note 1: The traceability system of the manufacturer shall allow him to provide to
a market surveillance authority, upon request, the technical documentation
related to a specific item of pressure equipment and the material
certificate.
Note 2: When a national authority applies the safeguard clause for a particular
product due to the material, the decision will relate to all products made
from the same material grade specification, if the traceability system does
not allow the identification to relate to (a) specific delivery(ies). The same
will apply if a manufacturer withdraws non-compliant or defective
products from the market.
Accepted by WPG on: 2002-04-09, proposed amendment on 2006-10-18
Accepted by Working Group “pressure” on: 2002-05-23, amended on 2006-11-21

7.5. Guideline 7/5
Question: Annex I, section 4.3 of the PED requires that the equipment
manufacturer must take appropriate measures to ensure that the
material used conforms with the required specification. In particular,
documentation prepared by the material manufacturer affirming
compliance with a specification must be obtained for all materials.
How may these requirements be applied in terms of required

inspection documents?
Answer: 1. According to the 1st paragraph of Annex I, section 4.3, the material
manufacturer shall certify, that the delivery complies with the requirement
of the specification and the order he has received. This affirmation of
compliance shall be stated on or appended to the certificate, whichever
type is issued.
2. According to the 2nd paragraph of Annex I, section 4.3 a certificate of

specific product control is required for the main pressure-bearing parts of
pressure equipment in categories II, III and IV. Account shall be taken of
the requirements in 4.1 and 4.2 (a) of Annex I.
3. According to the 3rd paragraph of Annex I, section 4.3 a distinction is

made for the material manufacturer's fabrication system: where he has an
appropriate quality (assurance) system certified by a competent body
established within the Community, and having undergone a specific
assessment for materials, an inspection document from the manufacturer
is appropriate (see also guidelines 7/7 and 7/16).
4. The general requirements for all other cases are given in the first 2
paragraphs of Annex I, section 4.3.
5. A scheme of the relevant inspection documents when following EN

10204:1991 or EN 10204:2004 is given in the following diagram:

Pressure equipment materials
Main pressure-bearing Main pressure-bearing parts

parts of equipment in of equipment in category I, Other parts
category II, III and IV pressure parts other than
main pressure-bearing
specific product control of equipment in categories I to IV,
attachments to equipment
of category II, III, IV
Quality system Direct inspection
route **) route
Inspection report Certificate of compliance

EN 10204:1991 type 3.2 Test report with the order
Inspection certificate
Inspection certificate EN 10204:1991 type 2.2 EN 10204:1991 type 2.1
EN 10204:1991 type 3.1.B *)
EN 10204:1991 type 3.1.C *) EN 10204:2004 type 2.2
EN 10204:2004 type 3.1 Declaration of compliance
Inspection certificate
with the order
EN 10204:2004 type 3.2
EN 10204:2004 type 2.1
*) see also item 1) of the answer

**) see also item 3 of the answer
Notes: 1) An inspection document of a higher level is always acceptable.
2) Material from stockists shall be accompanied by inspection documents

from the material manufacturer.
3) For traceability and transfer of marking, see also guideline 7/4.
4) For main pressure bearing parts, see also guideline 7/6, and for
attachments see definition 2.1 of Article 1 of the Directive.
5) For components, see guideline 7/19.
6) As regards joining materials, see guideline 7/10
7) Previously, the affirmation of compliance was not included in the

definition of certificate 3.1.B or 3.1.C according to EN 10204:1991, but is
now included in the definition of certificate 3.1 of EN 10204:2004.

with integration of guideline 7/20

7.6. Guideline 7/6
Question: The 2nd paragraph of section 4.3 of Annex I gives requirements for
the main pressure-bearing parts. How are they defined?
Answer: The main pressure-bearing parts are the parts, which constitute the
envelope under pressure, and the parts which are essential for the integrity
of the equipment.
Examples of main pressure-bearing parts are shells, ends, main body

flanges, tube sheet of exchangers, tube bundles.
The materials for these main pressure-bearing parts of equipment of

categories II to IV shall have a certificate of specific product control (see
Guideline 7/5).
See also guideline 7/8 for bolting parts (fasteners).

7.7. Guideline 7/7
Guideline related to: Annex 1, paragraph 4.3
Question: To what apply the terms “having undergone a specific assessment for
materials” of third § of 4.3 of annex I?
Answer: It is the quality (assurance) system of the material manufacturer which

shall have undergone a specific assessment for materials (and not the
competent body).

7.8. Guideline 7/8
Guideline related to: Annex 1, section 4
Question: What are the certificates required for bolting parts?
Answer: The bolting parts (screw, nut, stud, etc) are joining components.
When these components contribute to the pressure resistance, their

materials shall fulfil the relevant requirements of annex I, section 4.
Regarding section 4.3 of Annex I, a bolt is not considered to be a main

pressure bearing part unless its failure would result in a sudden discharge
of pressure energy.
When bolts are used as
− main pressure bearing parts a certificate of specific product control is

required (unless the item of pressure equipment itself is in Category I)
− pressure bearing parts a test report is sufficient,
− non pressure bearing part a certificate of compliance is sufficient.
(refer to guideline 7/5).
Accepted by WPG: 2000-10-02

7.9. Guideline 7/9
Guideline related to: Annex I, section 4
Question: Can a material manufactured according to a standard or another

publicly available specification for which a European Approval of
Materials (EAM) is available, but for which the inspection document
only refers to the standard or the specification on which the EAM has
been based, be used for pressure equipment manufactured under the
PED ?
Answer: Yes, if the EAM does not have any additional technical specification
compared to the standard or the specification. The inspection document
must satisfy the requirements of section 4.3 of Annex I (see also guidance
7/5).

Guideline related to: Annex I, sections 3.1.2; 3.1.5; 4.1; 4.2(a) and 4.3 1st paragraph
Question: What are the requirements for the documentation and traceability of
welding consumables:
- Inspection documents
- Suitable procedures for traceability?
Answer: Manufacturers of welding consumables shall provide inspection
documents affirming compliance with the specification.
Based on section 4 of Annex I and guideline 7/5 manufacturers of welding

consumables shall provide test report “2.2” as an inspection document in
accordance with the standard EN 10204.
The traceability requirement of Annex I section 3.1.5 applies also for
welding consumables. It can be maintained by procedural methods that
cover receipt, identification, storage, transfer to production, temporary
storage and use in production, availability of correct inspection documents
at the final inspection (see also guideline 7/4).
Note: Welding consumables are defined by trade name, designation and relevant
EN classification standard. Inspection documents of welding consumables
should give test results, for technical characteristics according to
designation and classification standard, such as:
− Chemical composition of welding filler metal or all-weld metal as

appropriate
− Tensile properties of all-weld metal: tensile and yield strength,
elongation
− Impact properties of all-weld metal at temperature according to
designation.
Test results are based on non-specific inspection and testing. They can be
given for example as typical values based on quality control tests.

Guideline related to: Annex I
Question: Do the essential safety requirements of annex I apply to pressure

equipment manufactured from plastic, GRP and other non metallic
materials?
Answer: Yes.

Guideline related to: Annex I section 4
Question: Shall welding consumables and other joining materials comply with
harmonised standards, European approvals of materials or particular
material appraisal?
Answer: No.
Reason: The PED does not require that these materials fulfil the requirement of
Annex I. 4.2b).
Note : The joining components referred to in Guideline 7/8 (bolting parts) are not
permanent joining materials.
Accepted by WPG on: 2000-02-17, editorial amendment (note) by WPG

2013-04-25, adopted by WGP 2014-03-20

Guideline related to: Annex I, Sections 4.1a and 7.5
Question: What is meant by Where appropriate, in the context of section 4.1a

when it refers to the quantitative values of section 7.5?
Answer: Where appropriate refers to steel, since this is the only material cited in
7.5.
For impact properties see also guideline 7/17.

Question: What does the exclusion of fine-grained steel in the first dash of
section 7.1.2 of Annex I of the directive mean?
Answer: Those fine grained steels are micro-alloyed steels for pressure purposes as,
for example, those given in EN 10028-3 or in EN 10222-4.
For these steels, the quantitative value of permissible membrane stress

stated in Annex I section 7.1.2 does not apply. However an equivalent
overall level of safety must be achieved (refer to guideline 8/6).

Guideline related to: Annex I, section 4.2.b)
Question: Annex I, section 4.2.b), first indent authorises the use of materials
which comply with harmonized standards.
Is this route still valid for a material for which the specification
includes complementary requirements or improved properties to
those of a grade in a harmonized EN material standard?
Answer: Yes.
Provided all the value limits stated for the particular grade in the
harmonized EN material standard are met.
Moreover the material manufacturer shall affirm compliance with both the
harmonized standard and the additional specification, as requested by
Annex I, section 4.3.
Accepted in principle by Working Group “pressure” on : 2001-04-03 – Wording reviewed by

WPG on 2001-04-24

Question: The Directive 97/23/CE considers the case of “a material

manufacturer who has an appropriate quality-assurance system,
certified by a competent body established within the Community and
having undergone a specific assessment for materials”. How should
this requirement be understood in practice?
Answer: In practice, this requirement is satisfied when the material manufacturer

has a quality assurance system of at least EN ISO 9001 type, certified by a
competent body (according to the definition given in guideline 7/2)
established as a legal entity within the European Community, and when
the field of validity of the certification specifies production of material
indicating the relevant material types.
The specific assessment of the quality system shall properly cover all the
relevant processes and material properties referred to in the material
specifications, and attested in the material certificates.
A single reference to section 4.3 of Annex I of PED is not sufficient to

validate the quality assurance system of the material manufacturer. The
reference document for quality assurance system which has been used
shall be identified. Reference to the PED in the quality assurance system
certification is not a mandatory requirement.
Note: See also guidelines 7/5, 7/7 and 9/5.
Accepted by WPG on : 2005-11-28 editorially amended by WPG on 2012-09-12 and

WGP on 2013-03-07

Guideline related to: Annex I section 4.1a and Annex I section 7.5
Question: What approach can be used to decide if a steel grade selected for a
pressurized part requires specific impact properties?
Answer: 1. The philosophy of the approach outlined below takes account of

the hazard analysis performed by the manufacturer in relation to the
toughness necessary for the identified failure modes (e.g. brittle fracture)
in the finished pressure equipment.
2. The exception concerns “ductile materials which are not subject

to a ductile/brittle transition at the foreseeable conditions the equipment
will be exposed to”.
Examples of such materials are: austenitic stainless steels.
Some design codes provide specific rules for the avoidance of brittle
fracture that takes account of the anticipated or actual operating conditions
prevailing, e.g. material, thickness, temperature, etc. Where the
application of these rules indicate that the material will not behave in a
brittle manner and all aspects of the chosen design code have been
followed, sufficient confidence is gained in the behaviour of the material
not to require specified impact properties. When these design codes are
applied also other items need to be taken into account (see item 3 below).
3. The justification for omission of the impact properties shall be

based on the most adverse possible combination of all elements of the
steel grade specification, such as:
− the full permissible range of the chemical analysis,
− the extreme mechanical properties,
as documented and permissible in the specification and not on the values

of the actual deliveries.
The consequence of the worst combination of chemistry must be

considered because the specified range of chemical analysis for some
materials could result in brittle behaviour,. Where appropriate, such
materials could be accepted if the chemical composition and mechanical
properties are restricted in the purchase order and in the particular material
appraisal to such levels that, from experience, do not give rise to brittle
fracture.
EXAMPLES include Manganese-Carbon ratio, Carbon, Sulphur,

Phosphorus content, Aluminium to Nitrogen ratio.
Other restrictions may include:

- avoiding inter-metallic phases,
- avoiding large grain sizes,
- placing limits on mechanical properties.

Manufacturers and Notified Bodies must demonstrate that they have taken
such factors into account in documenting the necessary PMAs.
4. Furthermore subsequent manufacturing processes affecting the

impact properties of the material shall be taken into account, when making
the above assessment.
Following all the rules in the design code should generally ensure that this
requirement is met; however additional requirements may also be
necessary to ensure that all relevant ESRs have been met.
EXAMPLES: forming, heat treatment, welding.
5. However, verification testing of specified impact property may

not be required in cases where there is no doubt about the fulfilment of the
essential safety requirement on sufficient toughness to avoid brittle
fracture.
EXAMPLES : Most Austenitic Stainless Steels.
Reason: Impact property values are the most common way to fulfil the essential
safety requirement of toughness specified in annex I Section 4.1a.
Although impact testing of materials is the commonly accepted route to

demonstrate materials have specified minimum toughness, it is not the
only route.
EXAMPLES: Restrictions on operating temperatures, Fracture

mechanics.
Note 1: Every harmonized European steel standard has specified impact

properties.
Note 2: A “history of safe use” alone cannot replace the need for the specification
of impact properties. This notion in inextricably linked to a particular
code, set of safety factors and safety philosophy and can therefore not
necessarily be transferred to a different safety philosophy/concept.
Following the requirements of an established design Code alone does not

provide a “presumption of conformity” and a simple claim by the
manufacturer that they “have followed the specified Code” is not in itself
justification. Established Codes may be used as the basis for meeting the
essential safety requirements however it is necessary to compare the
selected Code requirements to the essential safety requirements and
identify and address any deviations. This requires those using the Code to
have a good understanding of the principles involved, rather than
mechanistic following of rules.


Guideline related to: Annex I section 4.1 and Annex I section 7.5
Question: Do the essential safety requirements on materials specified in Annex I

section 4.1 and section 7.5 apply to the base material or to the
pressure equipment?
Answer: They apply to the pressure equipment in its entirety, i.e. also to the heat
affected zones of a weldment, but not to the non pressure-bearing parts.
Note: Subsequent manufacturing processes affecting properties of the base

material shall be taken into account when specifying the properties of the
base material, as per Annex I, sections 3.1.1, 3.1.2 and 3.1.4 of PED.

Guideline related to: Article 1, paragraph 2.1.2, Annex I, sections 3.1, 4.3 and 7.2
Question: Which requirements apply to components, such as dished ends, bolts,

flanges, welded fittings etc, which are placed on the market as such?
Answer: To be incorporated into an item of pressure equipment, components which

are manufactured from materials such as plates, coils and bars shall meet
all the relevant essential safety requirements related to the manufacturing
process used ; for instance in the manufacturing of welded dished ends,
sections 3.1 and 7.2 of Annex I are relevant in addition to section 4.
In order to prove the conformity to the PED of the pressure equipment

containing the component the equipment manufacturer will need relevant
documents from the component supplier:
- Material certificates (of the plates, coils, bars …),
and as relevant :
- Welding procedure approvals,

- Welder/welding operator approvals,
- Non Destructive Testing operator qualifications,
- Non Destructive Testing reports,
- Destructive Testing reports,
- Forming and heat treatment information,
etc.
This information may be in the form of a component certificate.
The requirement in Annex I section 4.3 is not however intended for a

component manufacturer, who is not a material manufacturer in the
context of PED, even if he modifies the mechanical properties of the
material.
Forgings (including forged flanges), castings and seamless tubes are

generally considered to be materials. Fittings made from these “materials”
without subsequent welding or other process which could alter the
material characteristics are also considered to be materials. As regard
welded tubes, see guideline 7/25.
Note: Current practice may require components to be delivered with certificates

based on standard EN 10204 Metallic products. Types of inspection
documents or corresponding requirement when they are placed on the
market as such. The PED does not preclude supplying such certificates
with components.
See also guidelines 1/9, 1/22, 4/3, 7/5, 7/6, 7/8, 7/18 and 7/25.


Guideline 7/20 has been withdrawn.

Guideline related to: Article 11, Annex I section 4.2b
Question: May a notified body perform a particular material appraisal at the

request of a material manufacturer?
Answer: No.
If the material manufacturer wants to have his material approved by a

notified body the proper way to proceed is to request European approval
for material in accordance with Article 11, if the material is not covered
by a European harmonised standard under the PED and cited in Official
Journal of the European Union (OJEU).
Note 1: See guideline 9/13 for further information regarding PMA.
Note 2: For further guidance about the process and the content of a PMA refer to
the Guiding principles in document PE-03-28 approved by the Working
Group Pressure (downloadable from the PED website).
Accepted by WPG on: 2010-09-21 (editorial amendment of version of 2007-04-18) + editorial

amendment by WPM on 2010-10-05

Guideline related to: Annex I sections 4.1 and 7.5
Question: What is meant by the following two terms: Other values, and other
criteria, in the context of section 7.5?
Answer: Other criteria refers to further criteria depending e.g. on the

type/dimension/product form and resistance level of steel or mode of
operation, which shall be taken into account to prove its toughness and
ductility.
Other values refers to those other criteria which can result in more
demanding values for elongation or bending rupture energy or specified
values for additional properties.
See also guideline 8/6 for the application of section 7.

Question: With which requirements of Annex I section 4 does the material used
for a gasket have to comply?
Answer: The main function of a gasket is to ensure tightness. Its material needs to
fulfil only the relevant requirements of 4.1, 4.2 (a) and the first paragraph
of 4.3.

Question: Annex I section 4.3 of the Pressure Equipment Directive (PED)

requires that the material manufacturer must prepare documentation
affirming compliance with the specification required by the
equipment manufacturer.
Does this requirement mean that material properties used in the

design of the pressure equipment must be based on those affirmed
(guaranteed) by the material manufacturer?
Answer: Yes, the material properties used in design of the equipment, e.g. yield
strength and impact properties, must be based on those of the specification
which are affirmed by the material manufacturer.
Note 1: This does not mean that the values of the specification need to be written
on the certificate. It is sufficient for the material manufacturer's certificate
to make reference to the specification where the appropriate values are
included. See also guideline 7/17 for the need of verification testing of
specified impact properties.
Note 2: See also guideline 7/18 for the relationship between the essential safety
requirements and the properties of the base material.

editorially amended by WPG on 2003-12-17, confirmed by WGP on 2004-03-17

Guideline related to: Annex I, sections 3.1.2, 3.1.3 and 4.3
Question: How shall welded tubes be considered for the application of the
Pressure Equipment Directive (PED)?
Answer: Continuously machine-welded tubes, i.e. tubes made from coils as starting
materials in an automatic process, which are usually heat treated after
welding shall be in the terms of certification procedures considered as
materials provided the essential safety requirements (ESRs) of Annex I
section 4 “Materials” as well as applicable ESRs of Annex I section 3
“Manufacturing” (in particular 3.1.2 and 3.1.3) are fulfilled.
Further the manufacturer of such tubes shall affirm compliance of the

welded tube to the specification.
In general, the inspection document shall take the form of a certificate of

specific product control, where shall be found the references to the
competent third party approval of welding procedures and personnel and
to the recognised third party approval of non destructive personnel (for
categories III and IV).
When the use of the welded tube is limited to pressure equipment of

category I, a statement in the test report confirming that personnel and
welding procedures are qualified according to suitable internal operating
procedures is sufficient.
In application of guideline 7/16, where the welded tube manufacturer has

a certified quality system, this system shall properly cover not only the
relevant material properties referred to in the tube specifications, but also
the manufacturing process of the welded tubes (in particular welding and
NDT).
Note: This implies that e.g. tubes made from plates are to be considered
components, see guideline 7/19.


Guideline related to: Article 1 paragraph 2.9 and Article 11
Question: What type of material may follow the European Approval for
Materials (EAM) route?
Answer: An EAM may be issued for a special or novel material grade not included
in a European material standard harmonized under the Pressure Equipment
Directive (PED). Such a material grade shall have a specification
associated with particular chemistry and/or conferring specific mechanical
properties or characteristics such as corrosion resistance. These
mechanical properties or characteristics shall be supplementary to those in
similar harmonised standards. See also PED Guideline 7/15.
An EAM is a route to facilitate the use of safe materials in absence of

harmonized standards and to encourage material technology development
and innovation.
An EAM shall not be issued for:
1. a grade of material listed in a current or former national material

standard that has a specification covered by a harmonised European
material standard.
2. a grade of material which was previously included in a European
national material standard but which was not included in the
harmonised European material standard which has replaced the
European national material standard.
In those cases a PMA is to be drawn up, see PED guidelines 7/21 and
9/13.
Note 1: A “grade of material” may be designated by use of a material number in

accordance with EN 10027-2 in the case of metallic materials.
Note 2: The Pressure Equipment Directive (PED) states that European Approval
for Materials (EAMs) shall be withdrawn by the notified body if the type
of material is covered by a harmonized standard.
Accepted by WPM on: 2010-10-05

Guideline related to: Annex I section 4.3
Question: When an equipment manufacturer receives a certificate type 3.1

according to EN 10204:2004 by the material manufacturer, in
pursuance of the third paragraph of section 4.3 of Annex I, what
evidence of compliance with these requirements shall be recorded in
the technical documentation?
Answer: The equipment manufacturer shall be able to confirm that the material
manufacturer's quality system certificate meets the requirements of the
third paragraph of section 4.3 of Annex I (field of validity of the
certification, range of validity of certification, establishment of the
competent body as a legal entity within the European Community,
accreditation).
The equipment manufacturer should keep track of such information which

may be requested by the market surveillance authority. To fulfil this
requirement the equipment manufacturer should keep in its technical
documentation the appropriate quality system certificate of the material
manufacturer or other equally objective evidence.
See also Guideline 7/2 and Guideline 7/16.
Accepted by Working Group “Pressure” on: 2013-03-07

Guideline related to: Annex I section 7.5
Question: How to apply Annex I, section 7.5 on the bending rupture energy
measured on an ISO V test piece for base materials whose, due to its
thickness, the collection of a test piece of section 10 mm x 10 mm is
not possible?
Answer: The value of 27 Joules required on Annex 1, section 7.5, means the use of
test piece of section 10 mm x 10 mm and an impact test KV according EN
ISO 148-1:2010, Metallic materials – Charpy pendulum impact test – Part
1: Test method.
When a standard size test piece of 10mm x 10mm cannot be obtained, it is

recommended to use a sub-sized specimen with a cross section of 7,5mm
(7,5mm x 10mm) or 5mm (5mm x 10mm) and to adjust the value of
impact test (see EN 13445-2 and EN 13480-2).
When a sub-sized specimen (5mm x 10mm) cannot be obtained due to the

dimensions of the material, the verification of the specified 27 Joules is
not relevant but the properties of the material are still to be guaranteed by
the material manufacturer.
See also Guidelines 7/17 and 7/13.

7.29. Guideline 7/29 (pending)

Guideline related to: Annex I; section 4.3
Question: A manufacturer produces material only to a chemical analysis

without mechanical testing and without affirmation of compliance to
a material specification and/or grade.
An entity intends to purchase the material and affirm compliance to a

material specification by performing the mechanical tests as required
by that material specification. There will be no further processing,
other than cutting to size. Is this procedure acceptable and may this
material be used in pressure equipment under the PED?
Answer: No, even if the mechanical tests are recorded in an EN 10204 inspection
certificate which describes the testing entity as the manufacturer of the
material.
Reason: Paragraph 4.3 Annex I of the PED requires the material manufacturer to
affirm the compliance with a specification. Any entity who is not involved
in the material manufacturing process cannot be considered as a material
manufacturer.

8. INTERPRETATION OF OTHER ESSENTIAL SAFETY REQUIREMENTS
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

8.1. Guideline 8/1
Guideline related to: Symbol for litre
Question: In the linguistic versions of the directive the symbol for the unit for
volume (litre) is not consistent (big L, small l). Which symbol should
be used?
Answer: The big “L” should be used. This should be taken into account by the
Member States when transposing the directive.
Reason: In the field of pressure equipment the symbol for litre is mainly used in
connection with numbers. The letter “l” and the figure “1” look often
identically so that misunderstandings between figures and the symbol can
occur. Often the marking on nameplates is stamped so it is important that
the symbol is easy readable.

8.2. Guideline 8/2
Question: Final assessment (Annex I, section 3.2.2) of pressure equipment must

include a test for pressure containment at a pressure at least equal,
where appropriate, to the value laid down in section 7.4. This section
only refers to pressure vessels. Does this mean that 7.4 does not apply
to piping, and pressure and safety accessories?
Answer: In accordance with Annex I, 3.2.2 in the course of the final assessment
pressure equipment must be subjected to a test for the pressure
containment aspect. As a rule, this test for the pressure containment aspect
is supposed to be carried out in the form of a hydrostatic pressure test.
Where this is not possible or disadvantageous other procedures are
permissible.
The pressure value chosen for carrying out a hydrostatic pressure test must
be such as to assure testing the pressure containment aspect of the pressure
equipment with due consideration of the determined safety factors without
causing a damage to the pressure equipment. Annex I, 7.4 provides
additional formulas which may be applied only in due consideration of the
above described general criteria (3.2.2). The formulas in Annex I, section
7.4 should be considered for all items of pressure equipment, not only
pressure vessels.

8.3. Guideline 8/3
Guideline related to: Annex I points 3.3 and 3.4.
Question: What safety information must be given to the user in relation to

Annex I points 3.3 and 3.4 ?
Answer: When pressure equipment is placed on the market, the manufacturer is

required by the PED to ensure that it is accompanied by instructions for
the user containing certain safety information; such information is
mandatory. Additional information may be requested by the user or
recommended by the manufacturer, and agreed as part of the order or
contract; this information is not a PED requirement and therefore is
optional. Both types of information are elaborated below.
The following are required by the PED:

− Details accompanying the CE mark, per clause 3.3a, 3.3b and 3.3c
− Operating instructions for mounting, putting into service, use and
maintenance, per clause 3.4a, which include as far as relevant to the
equipment:
o safe operating limits and design basis (includes anticipated
operating and assumed design conditions, intended life, design
code used, joint coefficients and corrosion allowances)
o features of the design relevant to the life of the equipment per
clause 2.2.3b last indent
o residual hazards not prevented by design or protective
measures, that might arise from foreseeable misuse, per clause
1.3, 3.3c, and 3.4c
o technical documents, drawings and diagrams necessary for a
full understanding of these instructions, as per clause 3.4b
o information about replaceable parts, for example per clause 2.7
Note 1: Where an assembly of pressure equipment includes a number of different

PS, it is acceptable not to provide these different PS on the assembly
marking but they must be provided by other suitable means for example
on an assembly layout diagram accompanying the operating instructions.
Note 2: Without prejudice of clause 3.4a, other information, not required by the
PED, may be included by contractual agreement, such as: hazard analysis,
material test certificates, detailed design calculations, “as built” drawings,
heat treatment records, welding records, NDT results, results of
dimensional check, full records of proof test, details and results of special
checks, details of any corrective repair or modifications, full
documentation of any concessions made.

8.4. Guideline 8/4
Guideline related to: Annex I, 2nd and 3rd preliminary observations
Question: What shall be the extent of the hazard analysis specified in the third
preliminary observation of Annex I?
How shall it be documented?
Answer: The hazard analysis shall enable the manufacturer to identify and to
determine the potential modes of failure due to loading of pressure
equipment which could occur when this equipment is installed and used in
reasonably foreseeable operating conditions.
After the manufacturer has fixed the limits of the equipment, he must
complete a hazard analysis which will enable him to identify the essential
requirements which are applicable to the equipment.
The results of this analysis (applicable essential requirements in relation

to the foreseeable operating conditions) shall be included in the technical
documentation, but the inclusion of full details of the analysis in the
documentation is not required by PED.

8.5. Guideline 8/5
Question: Does the strength of the foundations (concrete plates, tightened

gravel, piling etc), where the pressure equipment is erected, belong to
the details to be considered under PED?
Answer: The strength of the foundations does not belong to the details to be
checked by notified bodies in modules B1, G etc. But the manufacturer,
obliged by section 3.4 of Annex I of PED, must give relevant information
(support forces etc) so that the body responsible for installation of the
pressure equipment can design the grounding (see Annex I, section 2.2.1).
Note: This information should also be made available to the user with 'as built'
drawings, see guideline 8/3.

8.6. Guideline 8/6
Question: The first paragraph Annex I section 7 explicitly provides for

exceptions to the general rules specified subsequently. How should the
achievement of “an equivalent overall level of safety” in such a case be
demonstrated?
Answer: The specific quantitative requirements given in section 7 of Annex I are

related to particular failure modes. If different values are used, the
corresponding failure modes and their combination shall be identified and
the measures taken to maintain an equivalent level of safety shall be
provided in the technical documentation, with appropriate justifications.
The achievement of “an equivalent overall level of safety” may be

assumed if the measures taken provide adequate safety margins against all
relevant failure modes in a consistent manner. Safety margins are
adequate, and deviation from a particular value is justified:
a) by a reduced risk in the respective failure mode, or
b) by additional means to ensure no increase of the risk.
When using a harmonised standard for pressure equipment which has been
published in the Official Journal of the European Communities, no further
justification is needed for the quantitative values which have been used as
regards Annex I section 7 (refer also to guideline 7/1).
The requirement to demonstrate an equivalent overall level of safety

applies to the product itself, and to the measures taken to meet the
essential safety requirements. The use of a "recognised" code is not, in
itself, sufficient to demonstrate an equivalent overall level of safety (see
also guideline 9/5).

8.7. Guideline 8/7
Guideline related to: Article 1 paragraph 2.2, Article 1 paragraph 2.3, Annex I section
1.1, Annex I section 1.3, Annex I section 2.2.1
Question: What conditions should be considered to determine the maximum

allowable pressure PS of an equipment?
Answer: All the reasonably foreseeable conditions shall be taken into account,
which occur during operation (starting, operation, stop) and standby
(storage, transport, maintenance, emptying, blanketing or inerting).
Note 1: The operating instructions shall identify the reasonably foreseeable

hazards arising from misuse which were not possible to eliminate during
the design (see Annex I section 1.3).
Note 2: The maximum allowable pressure is used to determine the test pressure,
not vice versa.
Note 3: "Pressure related to atmospheric pressure", as defined in Article 1

paragraph 2.2, is the pressure inside the envelope. It shall not be
interpreted as "differential pressure between atmospheric pressure and
absolute pressure prevailing inside the equipment" for the purposes of
classification.
Example: Blanketing (inerting) at more than 0,5 bar of an equipment which operates
at less than 0,5 bar will have the consequence of including the equipment
in the scope of the directive, if not otherwise excluded.
Accepted by WPG on: 2000-11-29, editorially amended on 2004-06-15
Accepted by Working Group “pressure” on: 2001-10-19, confirmed by WGP on 2004-09-07

8.8. Guideline 8/8
Guideline related to: Article 9 paragraphs 1 and 2, Annex I, section 3.3 b, last indent
Question: What does “product group” mean?
Answer: “Product group” is not defined in the directive but in the context of Article
9 paragraphs 1 and 2 it shall be taken to mean the “fluid group” which is
used for the purposes of classification.
Note: Moreover, for equipment designed for a specific fluid, the manufacturer
shall indicate, where necessary, in order to draw the attention of user, the
name of the fluid on the equipment and in the operating instructions
(annex I section 3.3 b and annex I section 3.4 respectively).

8.9. Guideline 8/9
Guideline related to: Annex I, section 3.3 a)
Question: Must an individual serial number always be provided, even if the

items of pressure equipment are manufactured in batches or series?
Answer: No.
For items of pressure equipment manufactured in batches or series (such

as portable extinguishers or valves) the identification may be limited to the
batch or series number. It is not always necessary to provide an individual
serial number on each item of pressure equipment.
Notes: 1. When a national authority applies the safeguard clause the decision will
relate to all products belonging to the same batch or series. Similarly, if a
manufacturer withdraws non-compliant or defective products from the
market this will relate to all products belonging to the same batch or
series.
2. It should be noted that some linguistic versions are unclear on this

point.
3. Sufficient identification shall be possible according to the nature of the

equipment.

Guideline related to:Article 3 paragraph 1.2; Annex I section 3.3
Question: Does the directive require a specific format for marking the year of
manufacture of pressure cookers?
Answer: No.
The year of manufacture could be for example given as a 4-digit (year of
manufacture: yyyy) or limited to 2 digits, associated with the serial
number (xxxx/yy).

Guideline related to: Annex I, preliminary observation 3
Question: For products built according to a harmonized standard, is the

manufacturer still obliged to perform the hazard analysis required by
Annex I preliminary observation 3 of the PED?
Answer: Yes.
The manufacturer has
- first to identify the hazards;
- second to determine those essential safety requirements (ESRs)
which apply to his product.
Then, a comparison with Annex ZA of an existing harmonized standard

will allow him to decide whether this standard fully covers the relevant
ESRs for his product.

Question: Which are the essential maximum/minimum allowable limits to be

marked according to Annex I section 3.3 a) of Pressure Equipment
Directive (PED)?
Answer: All pressure equipment shall be marked with the maximum allowable
pressure PS, unless this might be misleading for safe use (see for instance
guideline 8/18 for bottles for breathing apparatus).
Depending on the type of pressure equipment, its operating conditions and

the results of hazard analysis there may be other essential
maximum/minimum allowable limits or combinations thereof, such as
- maximum or minimum allowable temperature;
- maximum or minimum fluid level
Note: Further information may be required (see PED Annex I sections 3.3.b and
c).

Guideline related to: Annex I, section 3.3, Annex VI
Question: Which provisions are to be followed for the CE marking of small

pressure accessories and safety accessories, the dimensions of which
do not allow fulfilment of the requirements of:
– annex I, section 3.3.a) about the minimum information required,
– annex VI about the minimum size of the CE marking of 5 mm.
Answer: Where these requirements are a physical impossibility, the marking may
be given on a label attached to the accessory.
For example if a safety accessory has an external diameter of 8 mm and an

internal diameter of 3,7 mm, the whole marking is given on a label.
Reason: Even though the 2nd indent of the last paragraph of section 3.3 of Annex I
refers only to the information under 3.3.b) to be given on a label, in case
of technical impossibility it is allowed to give all the information on a
label as provided for in the Guide for the New Approach Directives.

editorially amended on 2005-06-28


Questiqon: Is it possible to undertake statistical proof testing of series-produced
safety valves?
Answer: Yes, when the body of the safety valve classified according to Annex II
section 3 does not exceed category I and subject it is supported by the
hazard analysis.
Reason: The proof test is intended to verify the pressure containment aspect of the
item of pressure equipment. The proof test does not address the safety
function which is covered by Annex I section 2.11.1.
Note 1: The safety function of such safety valves needs to be assessed according
to category IV (except for safety valves manufactured for specific
equipment of category lower than IV).
Note 2: The same reasoning is not applicable to the other items of pressure
equipment which are classified by the PED in a higher category than the
category derived from their intrinsic characteristics.

Guideline related to: Annex I sections 1.1, 1.2, 1.3, 2.9, 2.10, 2.11, 3.4, 5
Question: How should the ESRs (essential safety requirements) of Annex I be

interpreted in regard of boilers for generating steam or superheated
water intended for operation without continuous supervision?
Answer: All the ESRs from Annex I apply if the corresponding hazards exist. The
following observations, which are not necessarily exhaustive, explain
how some of the ESRs can be understood in the context of operation
without continuous supervision.
ESRs Explanation
1.1 The boiler shall be able to operate automatically, and include a control mode “operation
without continuous supervision”.
1.3, The heating system shall be able to operate only if all the boiler safety systems are
operational.
5a
2.10 Protection against exceeding allowable limits on pressure, temperature and water level shall
be ensured by safety accessories (see also guideline 1/43).
2.10 When specific aspects of water quality are subject to rapid variation giving rise to
dangerous situations within the period of unattended operation, protection against
exceeding such limit shall be ensured by safety accessories.
2.10 Adequate monitoring devices, which enable adequate action to be taken automatically to
keep the boiler within the allowable limits, shall be provided.
2.10 Warning devices, such as indicators or alarms, which enable the origin of anomalies to be
displayed, shall be provided.
2.10 In the case of failure of the power supply to electrical boilers a safe shutdown or continuous
operation of the control circuit of the boiler shall be ensured.
2.11 Safety accessories shall be designed to cause a safe shutdown of all or part of the boiler, in
case of failure of their power supply.
2.11.1 If for certain operations, the boiler shall be able to operate with some safety accessories
neutralised, this shall simultaneously disable the control mode “operation without
continuous supervision”.
3.4, The instructions for use shall explicitly state that the boiler is designed and equipped to be
operated without continuous supervision. It shall inform of residual hazards and special
1.2 measures to be taken during operation to eliminate them. It shall state:
- how to test the safety accessories (logic diagram for instance) and what are the
recommended intervals for such inspections;
- the requirements for boiler feedwater;

- the instructions to restart the boiler, for every stop origin.
5a After a boiler shutdown caused by anomaly, the boiler shall not be able to restart
automatically.
5d After shutdown, residual heat shall be safely removed without human intervention.
5e After a heating system has been locked in the stop position due to failure in its supply, a
manual reset shall be necessary to unlock it.
The following examples are frequently used requirements to check the function of the
safety system periodically as stated in guideline 9/20. The requirements are related to
ESRs section 5 and section 2.11.1 of Annex I:
24 hours operation without continuous supervision is permitted if functional tests of the

limiting devices are carried out periodically at adequate intervals.
A functional test carried out by the boiler attendant includes the shut down of the burner-
valves, or, when the boiler is fed by solid fuels, the stopping of the conveyor system. This
functional test also includes checking of the quality of water. Member states may have
specific requirements to allow duration greater than 24 hours, e.g. provision of a device
for automatic monitoring of water quality.

Guideline related to: Annex I sections 3.2.2 and 7.4
Question: If the hydrostatic pressure test required by Annex I section 3.2.2 is

replaced by a pneumatic pressure test because filling with water is
harmful or impractical, what value has to be used for the pressure
test?
Answer: Either the values given in Annex I section 7.4 are to be used for the
pneumatic pressure test or the manufacturer has to achieve an equivalent
level of safety using other appropriate means.
See guideline 8/2.
Note 1: Whether the test is pneumatic or hydrostatic, when the value of the
pressure deviates from the value of Annex 1 section 7.4, additional
measures must be applied to verify the pressure containment aspect
including tightness (see guideline 5/3).
Note 2: Attention is drawn to the fact that pneumatic testing can be highly
dangerous. Reference should be made to the appropriate national
authorities for regulation or guidance on the procedures to be followed.

Guideline related to: Article 15 paragraph 2, Annex I section 3.3
Question: Is it possible to provide the marking and labelling required by Annex

I section 3.3 on a sticker?
Answer: Yes, provided the sticker is non-removable, indelible, legible and firmly
attached to the pressure equipment, for the intended lifetime and
foreseeable conditions of use.
Note: When using stickers, account has to be taken of limited durability in

practice. For most types of pressure equipment, industrial practice is to
use rigid data plates.

Question: What shall be the information about pressure and temperature to be

marked on bottles for breathing apparatus according to PED?
Answer: Bottles for breathing apparatus shall be marked with the working pressure
(PW) as defined in RID/ADR, chapter 1.2.
Minimum and maximum allowable temperatures TS shall also be marked
Instead of the test pressure PT referred to in PED (3rd indent of 3.3.b in

Annex I) the test pressure (PH) as defined in RID/ADR, chapter 1.2 shall
be marked.
Note: 1. Further information may be required (see PED Annex I sections 3.3.b
and c).
2. The manufacturer shall explain the marking of pressure and temperature

parameters in the instructions for filling and periodic inspection.
3. According to RID/ADR , PW is the settled pressure, expressed in bar,

of a compressed gas at a reference temperature of +15 °C in a full pressure
receptacle, and PH is the required pressure, also expressed in bar, applied
during a pressure test for initial or periodic inspection. PW and PH being
the abbreviations for working pressure and test pressure as per RID/ADR,
6.2.2.7.3.
4. The answer is given on the basis that the standards referenced in ADR
are normally used for the design of bottles for breathing apparatus and that
appropriate impact properties are specified to demonstrate an overall level
of safety equivalent to that of the PED.

Guideline related to: Article 15 paragraph 2, Annex I section 3.3 and 3.4
Question: What is the marking information to be put on the constituent parts of

pressure equipment intended for domestic use?
Answer: Only the complete pressure equipment can be conformity assessed, and
only one CE marking shall be affixed, preferably on the constituent part
that is not supposed to be replaced.
The constituent parts of such pressure equipment, which can be sold

separately, as spare parts for instance, should have a marking allowing
them to be identified unambiguously. They shall not carry a CE marking
additional to the marking of the complete equipment.
The declaration of conformity and instructions for use shall describe in an

appropriate manner the components making up this equipment. The
operating instructions for use shall give the list of spare parts (where
appropriate); how to identify them, in particular their marking
information.
See also Guideline 1/22, 1/47, 4/11
Note: An example would be a pressure cooker constituting a body and lid.

9. MISCELLANEOUS
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

9.1. Guideline 9/1
Guideline related to: Article 3, paragraph 3
Question: What is to be understood by "sound engineering practice"?
Answer: Sound engineering practice” means, without prejudice to article 4,

paragraph 1.2, that such pressure equipment is designed taking into
account all relevant factors influencing its safety. Furthermore, such
equipment is manufactured, verified and delivered with instructions for
use in order to ensure its safety during its intended life, when used in
foreseeable or reasonably foreseeable conditions. The manufacturer is
responsible for the application of sound engineering practice.

9.2. Guideline 9/2
Guideline related to: Article 11, Paragraph 1
Question: What does “material recognised as being safe to use before 29

November 1999” in Article 11, first paragraph mean ?
Answer: Recognised as being safe to use means a material
- with well-known characteristics, and

- with a well-established history of safe use in the pressure equipment
field.
To be approved under Article 11, such a material must fulfil the relevant
essential safety requirements of Annex I.

9.3. Guideline 9/3
Question: Is the approval of a material manufacturer part of the European

Approval of Material procedure for “a material recognised as being
safe to use before 29 November 1999”?
Answer: No, the purpose of such a European Approval of Material is to certify the
conformity of types of materials with the corresponding requirements of
the Directive, not to approve a material manufacturer.

9.4. Guideline 9/4
Question: May a European Approval of Material for a “material recognised as

being safe to use before 29 November 1999”, be restricted to one or
more material manufacturers?
Answer: No, see guideline 9/3.
Note: If a material which is covered by a European Approval of Material is

patented, or has a patent pending, this information shall be included in the
European Approval of Material.

9.5. Guideline 9/5
Question: In which conditions is it possible to use a document other than a

harmonised standard (national standard, professional code or private
technical document) for the design and manufacture of pressure
equipment for the application of PED?
Answer: 1) The use of the harmonised standard is not mandatory.
2) However, the directive did not include provisions to give presumption

of conformity to documents other than harmonised standards.
A manufacturer using another document shall describe in his technical

documentation the solutions adopted to meet the essential requirements of
the directive.
The notified body (or the user inspectorate) shall validate, if required by
the module chosen, these solutions.
3) The technical requirements of the Directive are given in Annex I. When

using a national standard, a professional code or a private technical
document for fulfilling Annex I, only the technical content of this
document is relevant. Further provisions of this document (e.g. about
bodies or certification procedures) are not relevant for the application of
PED.

9.6. Guideline 9/6
Question: Is it possible to use partially one or more harmonised standards, codes

or specifications to design and manufacture a pressure equipment
conform to the Pressure Equipment Directive?
Answer: The different parts (design, manufacture, inspection, …) of an harmonised

standard, a code or a specification for pressure equipment form a
consistent set of documents which should be followed.
Nevertheless, the partial use of an harmonised standard, a code or a

specification is not forbidden.
In these conditions, the essential requirements covered by the part(s) of

harmonised standards, codes or specifications used shall be identified.
The essential requirements not covered by the part(s) of harmonised

standards, codes or specifications shall be subject to an analysis to judge
the validity of the adopted solutions.
Then, if several different parts of harmonised standards, codes or

specifications are used, it shall be verified that there are no incompatibility
or inconsistency between these parts, particularly for the application data
(permissible stress, safety coefficient, extent of the inspection, …).

9.7. Guideline 9/7
Guideline related to: Article 1 paragraph 2.1.3, Article 3 paragraphs 1.4 and 3
Question: Under what circumstances shall safety accessories placed on the

market not bear the CE marking according to the PED?
Answer: Safety accessories exclusively manufactured and put on the market for
specific pressure equipment or assemblies covered by Article 3 paragraph
3 of the PED shall not bear the CE marking under the PED (but see Note
2).
Furthermore, safety accessories exclusively intended for equipment not

covered by the PED are also not covered by the PED.
Also safety accessories covered by the PED and assessed by a user

inspectorate shall not bear the CE marking.
Note 1: The specific use shall be clearly mentioned by the manufacturer of the
safety accessory in the instructions.
Note 2: This does not forbid the use of a CE-marked safety accessory on an
Article 3 paragraph 3 equipment.

9.8. Guideline 9/8
Question: Conformity with the PED is required for some piping per Article
3.1.3, which are part of an industrial installation. May all such piping
for a given installation be covered by a single CE marking?
Answer: Yes, providing the CE marking is prominently displayed and the

accompanying documentation supplied by the manufacturer to the user
clearly defines the boundary of the installation.

9.9. Guideline 9/9
Question: If an item of pressure equipment is covered by Article 3.3, and there

exists an EN product standard for this type of pressure equipment,
does this mean that the EN standard explains the meaning of the
sound engineering practice?
Answer: Not necessarily.
The manufacturer is always responsible for the application of all relevant

procedures and techniques, whether they are given in the standard or not,
in order to fulfil the requirement of Article 3.3. Standards and other
professional codes are useful frame of reference in this context. See also
guideline 9/1.

Guideline related to: Annex I, section 4.2 b, 3rd indent, Annex III module B, 4.1 2nd
indent and module B1, 4.1 1st indent
Question: When performing an EC type examination or an EC design-

examination by using particular appraisals for materials, are these
appraisals applicable to all items of pressure equipment covered by
this examination?
Answer: Yes.

Guideline related to: Annex I, 4.2.b third indent
Question: When performing a particular appraisal for materials recognized as

being safe to use before 29.11.1999, shall the existing data for these
materials be taken into account when assessing the suitability of this
material?
Answer: Yes, and if this data as referred to in Guideline 9/2 is sufficient for the
proof of conformity, in principle no additional testing should be
performed.
The manufacturer (and the Notified Body) shall take into account the
material properties of the actual deliveries when claiming the history of
safe use for a particular material, if its specification has significantly
wider limits.
Reasons: 1. Even though the PED does not specify the content of a particular
material appraisal, the concept of safe history applies similarly as for
EAMs.
2. It would be incorrect to assume that every batch supplied to the wider

specification has equally good properties.
For example, in many steel specifications, sulphur may be permitted up to

0,030%, but modern steelmaking techniques produce lower sulphur levels
consistently less than 0,010%. The good impact toughness associated
with the low sulphur content will not be obtained if another batch of steel
is supplied at or near 0,030% sulphur.
Note: Where such commonly used materials are not covered by harmonised
standards or EAM, particular material appraisal is the only other route that
remains.

Guideline related to: Article 3.3, Annex I.4
Question: Do the requirements of Annex I.4 regarding materials also apply to

pressure equipment described in Article 3.3 (Sound engineering
practice)?
Answer: No.
Any pressure equipment covered in Article 3.3 does not have to meet the
Essential Safety Requirements of Annex I and consequently does not fall
under the regime of the material requirements contained therein.

Guideline related to: Annex I section 4.2b 3rd indent, and Annex I section 4.2c
Question: What are the formal requirements of a particular material appraisal

(PMA)?
Answer: The PMA shall describe the material properties in a manner that is
concise, complete and correct for the foreseen application (see also PED
Guideline 7/18). It shall comprise qualitative and quantitative data
providing evidence that the relevant Essential Safety Requirements (ESR)
of PED Annex I are met.
The responsibility for drawing up the PMA lays with the pressure
equipment manufacturer.
The PMA shall be part of the technical documentation.
The PED only requires a particular appraisal of a PMA by a notified body

for pressure equipment in category III and IV.
Note 1: The PED uses the word "appraisal" in two contexts which are unclear in
some linguistic versions: (i) the PMA (which is the material datasheet)
and (ii) the appraisal of the PMA.
Note 2: For further guidance about the process and the content of a PMA refer to
the Guiding principles in document PE-03-28 approved by the Working
Group Pressure (current version downloadable from the PED website).
Note 3: When European harmonised material standards are available for materials
similar to a material grade covered by the PMA, the material
characteristics (e.g. rupture energy, elongation after fracture, corrosion
resistance,...) included in this European harmonised material standard are
to be considered in the PMA. See also PED Guideline 7/1.

Guideline related to: Article 14 section 1, Annex I section 4.2
Question : May the particular material appraisal (referred in the third indent of
4.2 b) of Annex I) be carried out by a user inspectorate as part of the
conformity assessment of pressure equipments based on modules A1,
C1, F or G?
Answer: Yes for module G.
Indeed, article 14 indicates that, by way of derogation from the provisions

relating to the tasks carried out by the notified bodies, the conformity of
pressure equipment can be assessed by a user inspectorate. And so the
particular appraisal referred in annex I 4.2 c) can be carried out by a user
inspectorate if, in accordance with article 14, it has been appointed for
module G.
Note 1: For module A1, the particular appraisal is carried out by the manufacturer.
For module C1 and F, the particular appraisal was carried out previously
as part of modules for design.
Note 2: The PED uses the word "appraisal" in two contexts which are unclear in
some linguistic versions: (i) the PMA (which is the material datasheet)
and (ii) the appraisal of the PMA.
Accepted by WPG on: 2000-10-03, with editorial

amendment by WPG on 2001-01-10 and 2013-04-25

Question: A user places an order for Pressure Equipment on a manufacturer in

Member State 'A', where the Member State has chosen not to
implement Article 14; but the Pressure Equipment is intended to be
put into service as part of an industrial installation in Member State
'B', where Article 14 is implemented. May Member State 'A' refuse to
allow the user's inspectorate, which has been authorized according to
Art. 14 in another Member State, to operate on its territory, thus
preventing the User Inspectorate from undertaking conformity
assessment of the Pressure Equipment?
Answer: No, provided the transfer takes place directly from the manufacturer to the
user, and it takes place in Member State 'B' the User Inspectorate may
legally undertake the conformity assessment activities in Member State
'A'.
Reason: Article 14, Paragraph 1 says: “.... Member States may authorize in their
territory the placing on the market, and the putting into service by users,
of Pressure Equipment .... which .... has been assessed by a User
Inspectorate designated in accordance with the criteria ....”
It is clear that the putting into service will take place in Member State 'B'
and therefore can be authorized in conformity with the Directive.

Guideline related to: Article 4 paragraph 1.1; Article 5 paragraph 1; Annex VII
Question: Must a CE-marked item of pressure equipment, or an assembly, be

supplied with an EC declaration of conformity, when it is placed on
the market?
Answer: The manufacturer of CE-marked pressure equipment or assembly should

be aware that the declaration of conformity must be made available for
national authorities immediately upon request. Otherwise the presumption
of conformity as provided for in Article 5, paragraph 1, is in doubt. For
this purpose the manufacturer or his authorised representative established
within the Community must draw up a written declaration of conformity
and keep a copy of it for a period of ten years after the last pressure
equipment has been manufactured.
However , Article 4, paragraph 1.1 requires that Member States provide

free movement for pressure equipment and assemblies which comply with
the PED and bear a CE mark, but there is no provision in the PED that an
EC declaration of conformity must be mandatorily supplied with the
pressure equipment or assembly in order to comply with the PED.
In addition, the manufacturer should be aware that the declaration of

conformity is a helpful document to the distributor or user because it is a
summary of design, manufacture and conformity assessment.
The manufacturer should also be aware that some Member States require
that the declaration of conformity is available at the user premises at the
time of putting into service and for subsequent in-service inspections of
the pressure equipment.
The manufacturer should also be aware that the EC declaration of

conformity is an essential document for the manufacturer of an assembly
into which a CE-marked item of pressure equipment is to be integrated.
It is therefore highly recommended to provide the EC declaration of

conformity for all products which are intended to be put into service as
such, with the product.
Note: The EC declaration of conformity does not need to be a separate

document; it may be included in the instructions for use.
Accepted in principle by Working Group “pressure” on: 2001-06-27

Question: How shall a manufacturer established outside the European

Economic Area (EEA) fulfil the requirement of the sound engineering
practice (SEP) of a Member State?
Answer: A manufacturer outside of EEA may choose the SEP of one of the
Member States.
SEP from countries outside EEA does not automatically fulfil the
requirement of Article 3, paragraph 3.
However, as a general rule, it can be assumed that the SEP of a Member

State is met if:
- the product has been legally marketed in one Member State of EEA for
many years, or
- the product fulfils technical specifications recognised by one Member

State of EEA.
Refer also to guidelines 9/1 and 9/9.
Reason: Article 3 paragraph 3 of PED stipulates mutual recognition of SEP of

Member States in order to avoid barriers of trade. The level of safety is
assumed to be sufficient in all Member States. So the equipment must in
be fact safe.

Question: Article 4.1 of PED provides for free placing on the market or putting
into service of CE-marked pressure equipment. Under what
circumstances can the application of national regulations (e.g. by
public authorities or private authorised bodies) on periodic testing
constitute a barrier to trade?
Answer: Differentiation between in-service inspection periods for similar CE-

marked items of pressure equipment for the same purpose should be based
on technical reasoning and the conditions of use of the equipment.
Specification of formal requirements for:
- the involvement of a specific notified body or bodies,

- the compliance with a specific (e.g. national) design code to the
exclusion of other technically justifiable/equivalent solutions would
constitute a barrier to trade.

Guideline related to: Article 3, paragraph 3; Article 4, paragraph 1.2
Question: What information should be supplied with an item of pressure

equipment, or an assembly, which falls under article 3, paragraph 3
(sound engineering practice, SEP) when it is placed on the market, to
indicate that it complies with the provisions of article 3, paragraph 3?
Answer: There are no specific provisions in the directive on how the manufacturer
must indicate that such equipment complies with the PED.
Nevertheless, the manufacturer must supply adequate instructions for use,

and provide markings to permit identification of the manufacturer or its
authorized representative established within the Community.
However, manufacturers should be aware that it is likely to be helpful if

they include with the product a reference to the PED indicating that the
requirement of sound engineering practice of a Member State (see
guideline 9/1) has been met. This can for example be achieved by a
statement included with the instructions of use, by a separate document
attached to the equipment, or by an addition to the marking.
Note: The manufacturer must not draw up, an EC declaration of conformity, nor
affix the CE-mark for such equipment in the context of PED.

Guideline related to: Article 2 paragraph 2, Article 4 paragraph 1.1, Annex I sections 2.3,
2.10b and 2.11.1
Question: Are national requirements additional to the Pressure Equipment

Directive (PED) for the design, conformity assessment and installation
of safety systems of CE-marked boilers for generating steam or
superheated water intended for operation without continuous
supervision permissible?
Answer: No.
When
- the boiler is intended for operation without continuous supervision
- the specific hazards due to this situation are taken into account in the
hazard analysis and design of the assembly and its safety systems
- this assembly meets all relevant provisions of the PED (including a

description of the intended operation mode and of the associated safety
systems in the instructions for use)
any additional design requirements would constitute a restriction on or

impediment to the placing of this product on the market.
National requirements may oblige the user to check the function of the
safety system periodically. The requirements shall be based on technical
criteria of the design of the safety system in order to guarantee that for
similar safety systems the same operational requirements apply.
See also guidelines 3/4, 8/3 and 9/18.
Note: Guideline 8/15 identifies significant ESRs applicable to boilers intended

for operation without continuous supervision.
Acceptedby Working Group "pressure" on: 2003-11-03, updated on 2004-03-18

Guideline related to: Article 4, paragraph 2, Annex I sections 3.1, 3.3 and 3.4
Question: Article 4 of the Pressure Equipment Directive allows Member States

to require the information for pressure equipment described in
Annex 1 sections 3.3 and 3.4 to be provided in the language of the
country in which the equipment or assembly reaches the final user. If
so required, does this impose the task of translating on the
manufacturer?
Answer: The PED allows Member States to require translation and consequently to
take restrictive measures if this requirement is not fulfilled.
Manufacturers, distributors and importers should be aware of this
requirement.
If the national legislation requires the translation, it has to be fulfilled.

When the equipment is not placed on the market in the Member State of
the final user, the person introducing the equipment in the linguistic area
(e.g. the importer, the distributor, the manufacturer of an assembly
including such equipment) must ensure the requirement is fulfilled.
For pressure equipment specifically manufactured for a defined end user

which is subject to contract between the supplier and user, they can also
contractually agree who shall do the translation(s) taking into account the
national law.

Guideline related to: Article 10 paragraph 4, Annex VII
Question: In which language must the EC declaration of conformity be written?
Answer: The EC declaration of conformity shall be drawn up in one of the official

languages of the European Union, as chosen by the manufacturer or
agreed by contract with the client.
See the guide to the implementation of directives based on New approach

and Global approach § 5.4.
Note: In the process of the market surveillance, a national authority may request
a translation of the EC declaration of conformity into its official language
(see the guide to the implementation of directives based on New approach
and Global approach § 8.2).
Reservation from Belgium

Guideline related to: Article 4 paragraph 1, article 5 paragraph 1
Question: What aspects must not be assessed during inspections under national
legislation before putting into service products falling in the scope of
the Pressure Equipment Directive (PED)?
Answer: Pressure equipment and assemblies bearing the CE mark and the EC
declaration of conformity are presumed to conform with the requirements
of the PED. Therefore, during inspections under national legislation of
such products, performed before putting into service, it is not permissible
that:
- the fulfilment of essential requirements of the PED, e.g. integrity

of welds or the sustainability of the design, is assessed again.
- product-related documentation (other than operating instructions
and the EC declaration of conformity) is required to be provided by the
user or manufacturer.
Note 1: The said inspections may e.g. verify whether the pressure equipment or
assemblies have suffered from transport damage, whether their integration
in the surrounding environment and/or their joining to the rest of the
installation has been performed correctly according to national legislation
or whether the operators have sufficient expertise.
Note 2: Any re-assessment of essential safety requirements already covered by the

conformity assessment of the PED would be illicit double testing and
constitute an impediment of the putting into service of equipment
complying with the PED.
Note 3: This guideline does not address market surveillance activities, under the
responsibility of public authorities, by application of Article 2.
Note 4: See also guidelines 1/3 and 8/3.

Guideline related to: Article 1, article 2 paragraph 2, article 3, article 4 paragraph 1,

article 5 paragraph 1
Question: What additional requirements for the design, manufacture and

assessment of pressure equipment and assemblies covered by the
Pressure Equipment Directive (PED) containing explosive/
inflammable fluids are allowed in national regulations in addition to
the requirements of the PED?
Answer: (1) All technical (design, manufacturing, conformity assessment)

requirements addressing hazards related to pressure are covered by the
PED. Any additional national requirements related to pressure would
constitute an impediment of the free movement of products falling into the
scope of the PED and are not permissible. The following are examples of
non-permissible additional requirements:
• Specific requirements for protection against the release of the

fluid
• Specific requirements for materials due to the nature of the fluid
• Specific requirements to avoid explosions/fires triggered by
pressure (e.g. local heating due to pressure energy converted into thermal
energy)
These aspects shall have been taken into account by the manufacturer as
part of the hazard analysis.
(2) The PED does not consider the prevention of and protection against
explosions/inflammations, which are not triggered by pressure (e.g.
electrostatic ignition of an explosive fluid, etc.). These hazards may be
addressed by national legislation, unless it is covered by other European
legislation (e.g. ATEX Directive).
Note 1: This question is of particular relevance for national legislation on LPG,

natural gas and hydrogen installations.
Note 2: The PED provisions on risk analysis and categories for conformity
assessment take into account the explosive/inflammable nature of the
fluid.
Note 3: However, national requirements can address installation conditions of the

pressure equipment or assembly, e.g. in order to protect operators,
environment or the pressure equipment / assembly itself.

10. GENERAL-HORIZONTAL QUESTIONS
3 ASSEMBLIES

MANUFACTURING
9 MISCELLANEOUS

Guideline related to: Horizontal guidelines
Question: Must the pressure equipment directive be applied to used pressure

equipment imported from outside the European Economic Area?
Answer: Yes.
Reason: Blue guide, point 2.1 "Products submitted to directives";
Blue guide, point 7.2 "Products to be CE-marked"
Accepted by WPG on:

Guideline related to: Horizontal guidelines
Question: Must the pressure equipment directive be applied to used pressure

equipment imported from another country of the European Economic
Area (EEA), if it was not manufactured under the regime to PED?
Answer: No, but national legislation of the receiving country will apply.
Reason: Guide to the Implementation of Directives Based on New Approach and

Global Approach, point 2 "Scope of New Approach directives" (footnote
20 to be noted) and point 9.1 "The agreement on the European Economic
Area".
Accepted by Working Group “pressure” on: 1999-01-28, editorially amended on 2005-03-16 by

WPG, confirmed on 2005-06-28 by WGP.

Guideline related to: Article 20, section 3
Question: Article 20, section 3 states that the transition period extends up to and
includes 29 May 2002. If a manufacturer intends to place pressure
equipment or assemblies on the market according to pre-PED
national Regulations during the transition period, what conditions
must be met?
Answer: 1. A necessary condition is that all manufacturing and conformity

assessment operations required by the pre-PED national Regulations have
been completed on or before 29 May 2002.
2. In addition, given that one of the purposes of including a transition

period in the Directive is to provide time for manufacturers to reduce
stocks, items of pre-PED pressure equipment must be physically
transferred to the customer or distribution chain on or before 29 May
2002, unless the transfer of ownership has occurred before this date.
Supplementary points: Provided the conditions in 1 and 2 have been met, there are no
restrictions on the subsequent sale of pre-PED pressure equipment
(through a distribution chain for example) or when such equipment is
eventually put into service within the respective Member state.
If a manufacturer retains some stocks of pre-PED pressure equipment or

assemblies after 29 May 2002, then they can only be subsequently placed
on the market if they are shown to be in compliance with the PED (This is
not necessary if the items are intended for export to a country outside the
Community). For subsequent use of such an item of pressure equipment in
an assembly, refer to guideline 3/11.

Guideline related to: Article 1 paragraph 2.1.5, Article 3 paragraph.2.2
Question: When an assembly is built by a subsidiary or affiliated company of

the final user, is such an assembly covered by the PED?
Answer: Yes.
As the subsidiary or affiliate company is a separate legal entity – even if it

is part of the same industrial group – the assembly is transferred between
the two companies and hence is placed on the market. The subsidiary or
affiliate company is to be considered the manufacturer.
Note: If the subsidiary or affiliate company acts under the overall responsibility
of the user (as an installer or sub-contractor), the PED does not apply to
this "installation" (see guideline 3/2).

Guideline related to: Article 5 and recitals 16 & 17
Question: Harmonized standards frequently use normative references to other

EN and non-EN standards. Do these referenced standards also confer
presumption of conformity to the ESRs?
Answer: It depends on the type of reference:
1. When a reference (which is contained in a part of a standard which

provides presumption of conformity) to a particular, limited section of
another standard, is used as a particular description in the harmonized
standard, then the presumption of conformity extends to this reference.
In exceptional cases, an entire standard can be used as a particular

description in the harmonized standard (test standards for instance).
In both cases, the referenced standards shall be dated. If it is not dated, the
version valid at the time of publication of the standard containing the
reference shall be used.
It should be noted, that the presumption of conformity is not valid for the
referenced parts or standards independently, but only when applied in the
context of the harmonized standard containing the references.
2. Other references, such as:
- references contained in an informative part,

- references with no direct relevance to harmonized normative parts,
- references to informative parts/documents,
- reference to pre-standards (ENV), technical specifications (TS); or other
deliverables such as Technical reports (TR) or CEN workshop
agreements (CWA),
- references to non EN standards, non ISO/IEC standards which do not
comply with the applicable CEN/CENELEC rules (see note 1), do not
confer this presumption of conformity.
It should also be noted that the entire reference list, which typically is
given as clause 2 of EN standards, does not in itself confer presumption of
conformity.
Note 1: Applicable CEN/CENELEC rules require the following:
- ensure that no suitable CEN, CENELEC, ETSI, ISO or IEC documents

are available and confirm that there is a necessity to refer to a document
other than those developed by CEN, CENELEC, ETSI, ISO and IEC;
- confirm that it is impractical to include the relevant text in full;
- justify the need for making reference to a document other than those
developed by CEN, CENELEC, ETSI, ISO and IEC;
- ensure and confirm that the referenced document shall:
- have wide acceptance;

- not be in contradiction with the European legislation, nor create
regulatory problems when the EN is implemented by
CEN/CENELEC members;
- have been prepared in accordance with the principles set in the
ISO/IEC Guide 59 - Code of Practice for Standardization - (with
the definitions of EN 45020) and in the ISO/IEC Directives;
- have clearance in respect of possible IPR (Intellectual Property
Rights) issues as prescribed in CEN/CENELEC Memorandum 8;
- not be a draft, but shall be an adopted document with an identified
and dated issue;
- be publicly available in official CEN/CENELEC languages, at
least in English.
Note 2: For a harmonized standard whose reference is published in the OJEC, the
annex ZA gives the relation between the ESR’s covered by the standard
and the corresponding clauses of this standard.

Guideline related to: Annex VII
Question: What is the information to be given in the Declaration of Conformity

in order to comply with indents 8 and 9 of Annex VII?
Answer: The harmonised standard or specification referred to is the governing

document(s) embracing all aspects of materials, design, manufacture and
testing of the item of pressure equipment or assembly.
If the governing document is an internal specification or a published

technical code, this information shall also be given.
However, as regards conditions related to the use of such documents, see

also guidelines 9/5 and 9/6 particularly.
Reason: According to paragraph 5.4 of the “Guide to implementation of directives

based on New Approach and Global Approach”, the standards or other
documents (such as published technical codes and internal specifications)
used should be described in a precise, complete and clearly defined way;
It is not requested to give the complete list of the standards used in
combination with the governing document.

Guideline related to: Annex III, modules D, D1, E, E1, H and H1
Question: In Annex III, for modules D, D1, E, E1, H and H1, specific
documentation is required to be retained for a period of 10 years after
the last date of manufacture.
The text specifically requires that ‘documentation concerning the

quality system’ be retained. Does this also include quality records
such as material certificates, test reports etc?
Answer: Yes.
The provisions concerning the retention of records shall be described in

the manufacturer's quality system documentation. The description of
technical documentation, in section 3 of module A, should act as the
guiding principle for the other modules. This includes results of
examinations, test reports, material certificates, etc. and has to be kept by
the manufacturer, or his authorised representative, for 10 years after the
last of the pressure equipment has been manufactured.
See also the Guide to the Implementation of Directives based on New

Approach and Global Approach, sub-clause 5.3.

Guideline related to: Annex VII
Question: What is the information to be given in the Declaration of Conformity

of assemblies in order to comply with the 4th indent of Annex VII?
Answer: The declaration of conformity of assemblies must contain a description of

all items of pressure equipment constituting the assembly together with,
for each PED item, the conformity assessment procedure followed.
Note: This description includes the identification of the items of pressure

equipment falling under category I to IV.
The other items taken into account in the assessment of the integration of
the PED assembly (including Art 3 paragraph 3 equipment or pressure
equipment excluded from the PED) shall also be described as part of this
assembly. This latter description may be by reference to appropriate
information in the instructions for use (e.g. component lists, drawings).
See also paragraph 5.4 of the “Guide to implementation of directives

based on New Approach and Global Approach”.
[end of document]

PED Guidelines EN v1.6

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What is the purpose of the Pressure Equipment Directive guidelines?

What is the purpose of the Pressure Equipment Directive guidelines?

What are the different subjects covered by the guidelines?

What are the different subjects covered by the guidelines?

Guidelines related to the Pressure Equipment Directive

Status of the guidelines

PED_Guidelines_EN_v1.6.doc Page 1 of 263

1 SCOPE AND EXCLUSIONS OF THE DIRECTIVE

2 CLASSIFICATION AND CATEGORIES

4 EVALUATION ASSESSMENT PROCEDURES

5 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON DESIGN

6 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON

7 INTERPRETATION OF THE ESSENTIAL SAFETY REQUIREMENTS ON MATERIALS

8 INTERPRETATION OF OTHER ESSENTIAL SAFETY REQUIREMENTS

PED_Guidelines_EN_v1.6.doc Page 2 of 263

Question: Are portable extinguishers within the scope of the Pressure

Answer: They are covered by the Pressure Equipment Directive.

Reason: Portable extinguishers are specifically mentioned in Article 3 paragraph

Furthermore, fire extinguishers are specifically mentioned in special

Thus, these extinguishers are not covered by the exclusion in Article 1

Accepted by WPG on: 2010-09-21

Accepted by Working Group "pressure" on: 2010-11-24

PED_Guidelines_EN_v1.6.doc Page 3 of 263

Guideline related to: Article 1 paragraph 2.1

Answer: Yes. If the PS of the tank is more than 0,5 bar.

Reason: Such tanks are not excluded by Article 1 paragraph 3.19.

Note: Refer also to guidelines 1/14, 1/34 and 8/7.

Accepted by WPG on: 2009-10-01

Accepted by Working Group "pressure" on: 2009-10-26

PED_Guidelines_EN_v1.6.doc Page 4 of 263

Guideline related to: Article 1, Annex I section 3.4

Question: Are replacements, repairs or modifications of pressure equipment in

Answer: 1) Entire change: the complete replacement of an item of pressure

3) Pressure equipment which has been subject to important modifications

See “blue guide” chapter 2.1

Accepted by WPG on: 2004-02-24

Accepted by Working Group "pressure" on: 2004-03-17

PED_Guidelines_EN_v1.6.doc Page 5 of 263

Guideline related to: Article 1 paragraph 2.1.2

Question: When is a modification of a piping system not covered by the PED?

Reason: See Guideline 1/3

Accepted by WPG on: 1998-10-13

Accepted by Working Group "pressure" on: 1999-01-29

PED_Guidelines_EN_v1.6.doc Page 6 of 263

Guideline related to: Article 3; Annex II

Question: Which conformity assessment category applies to vessel with a volume

Vessels referred to in Table in Category

1.1(a) first indent 1 If PS ≤ 200 bar, then Article 3.3 applies

otherwise see point 3 below

1.1(a) second indent 2 If PS ≤ 1000 bar, then Article 3.3 applies

otherwise see point 3 below

1.1(b) first indent 3 If PS ≤ 500 bar, then Article 3.3 applies

otherwise see point 3 below

1.1(b) second indent 4 If PS ≤ 1000 bar, then Article 3.3 applies

otherwise see point 3 below

3. In the absence of specific information in the Tables of Annex II for the

Accepted by WPG on: 1999-04-21, editorially corrected on 2002-06-18

Accepted by Working Group “pressure” on: 1999-11-08, confirmed by WGP on 2002-10-03

PED_Guidelines_EN_v1.6.doc Page 7 of 263