New Machinery Regulation will also affect lifts under the Lifts Directive

The last issue of the LIFTjournal reported extensively on the new contents of the Machinery Regulation, which replaces the Machinery Directive. In the meantime, an official letter of the European Commission and an Information Note of the ELA regarding this matter have become available.

BY EBERHARD VOGLER

The newly added or amended "Essential health and safety requirements" (EHSR) important for lift manufacturers of the new Machinery Regulation will apply from 20.01.2027. This means that all lifts marketed from this date will have to meet these new requirements.

The safety components incorporated in them under the Lift Directive, Annex III, will also have to meet the new requirements. Since there is no transitional period, only lifts according to the currently applicable regulations and not according to the new Machinery Regulation, can be marketed up to and including 19.01.2027.

The European Commission has provided an accompanying document especially for lifts on its homepage. This also has a link to an in-depth document of the ELA.

What does the LD have to do with the Machinery Directive (MD)? A reference can be found under point 1.1 of the EHSR of the LD that includes observance of the EHSR of the MD or in future of the new MR.

Why do the EHSR have to be observed, haven’t we got standards? The EHSR must in general be observed. Where it can be assumed that the technical requirements in the standards are suitable to fulfil the EHSR, these are cited in the Official Journal of the European Union. Hence, if a cited standard is observed, the presumption of conformity can be invoked and the assumption made that the EHSR have also been observed.

The differentiation between the presumption of conformity and conformity procedures is important for the following statements. All of the conformity procedures undergone for lifts and as well as most of those for safety components have to be updated to ensure the new EHSR are in addition covered. Normally, this requires the involvement of a Notified Body. In what follows, I shall only address presumption of conformity.

The EN ISO 8100-1:2026 standard has been available at CEN since 2026-06-17. National standardisation organisations, such as British Standards, have already published it. Citation can be expected in late autumn 2026. Whoever then observes the cited standard can invoke its presumption of conformity for systems and safety components. However, practical application will differ for most manufacturers and installers since most of the technical conversions and certifications will not have been concluded by 2027-01-20.

Photo: Grafik © Eberhard Vogler/TK Elevato

1. EHSR LD, Annex I
2. Part of the EHSR MD, which are relevant for Lifts falling under the LD
3. Requirements of EN 81-20/-50 fulfilling the relevant EHSR of LD and MD
4. 2x Requirements of EN 81-20/-50 going beyond to those in (3)
5. Requirements of ISO 8100-1/-2 fulfilling the relevant EHSR of LD and MD
6. 6.1, 6.2
   Requirements of ISO 8100-1/-2 going beyond to those in (5)
7. EHSR LD, Annex III, identical to (1)
8. Part of the EHSR MR which is relevant for Lifts falling under the LD.
9. Part of the EHSR MR,
   - which is relevant for lifts falling under the LD and
    come
   - in addition compared to the relevant EHSR of the MD (2)
10. Part of the EHSR MR, which
    - is relevant for Lifts falling under the LD, and
    - come in addition compared to the relevant EHSR of the MD (2), and
    - are covered by requirements of EN 81-20/-50 and ISO 8100-1/-2.
11. Part of the EHSR MR, which
    - is relevant for Lifts falling under the LD, and
    - come in addition compared to the relevant EHSR of the MD (2), and
    - are not covered by requirements of EN 81-20/-50 (GAP 1)
12. Part of the EHSR MR, which
    - is relevant for Lifts falling under the LD, and
    - come in addition compared to the relevant EHSR of the MD (2), and
    - are not covered by requirements of neither EN 81-20/-50 nor ISO 8100-1/-2 (GAP 2).

What now? For this reason, an option has been created that "as an exception" permits observance of the previous standards and authorisation in excerpts of particular paragraphs of EN ISO 8100-1:2026 only for the newly added EHSR. Normally, such mixing of standards is not permitted.

The figure above and the accompanying index show the connections between the legally prescribed EHSR and the technical standard requirements. The left block shows the LD and the section of the "old" MD that have to be observed. The right block shows the LD (no changes) and the new MR. There are two blocks with standards between these.

First, the good news: many of the new or amended EHSR are already met by EN 81-20:2020, since EN 81-20 ‘over fulfils’ the old EHSR. But it is also evident that there are two gaps: gap 1 only affects the standard EN 81-20:2020. Gap 2 in addition also affects the new standard EN ISO 8100-1:2026. I shall not address gap 2 (artificial intelligence).

Photo: © TK Elevator

The question now arises how gap 1 can be closed. The following equation indicates the road to success: EN 81-20:2020 + EN ISO 8100-1:2026¹) + ISO 8102-20:2022²) = presumption of conformity from 2027-01-20.

Finally, it should be noted that the information and recommendations provided here are based on the current state of knowledge and assessments made at the time of going to press (July 2026).

The author is the head of the German mirror committee for lifts and chief engineer codes & standards at TK Elevator.

¹) only the paragraphs 4.10.1.1.5, 4.10.1.1.6, 4.12.4, 6.2.2 g), 6.2.4 k) 7), 6.2.4 v) and 6.2.4 w) as well as Table 25

²) ISO 8102-20:2022 is not cited in the European Official Journal. However, once EN ISO 8100-1:2026 has been cited in the Official Journal, the presumption of conformity can from this point in time be invoked for chapters 5 and 6 of ISO 8102-20:2022 since reference is made to these in EN ISO 8100-1:2026.

HOW ARE EXISTING SAFETY COMPONENTS FOR LIFTS TO BE HANDLED? A decision must be reached for every existing safety component regarding whether it is affected by the new or amended EHSR. The manufacturer should check this in its own interests in order to initiate measures if required in good time for an additional certificate that covers the new or amended EHSR. In parallel, the notified bodies should check the validity of existing certificates and contact the manufacturers if necessary.

CAN ADDITIONAL OR NEW CERTIFICATES ALREADY BE ISSUED AND SIGNED BEFORE 20.01.2027? The certificates and declarations of conformity issued normally cover the legislation valid at the time of signature. To realise a smooth transition to the new MR it would make sense on pragmatic grounds to already issue the certificates before 2027-01-20, noting clearly that they will only be valid from 2027-01-20.