The EU legal framework in plain language

EU rules on sawmill safety come from several directions. The most useful way to hold them in your head is to ask who owes what: the employer who runs the mill, or the manufacturer who builds the machine.

The employer's side

• Framework Directive 89/391/EEC (12 June 1989) is the parent text. EU-OSHA summarises employer duties as: evaluate all risks (including equipment, chemicals and layout), combat risks at source, ensure adequate training, consult workers on new technologies and impose no costs on workers.
• Work Equipment Directive 2009/104/EC sets minimum requirements for using work equipment. Employers must make equipment safe for the workplace, reduce residual risks, keep it compliant through maintenance, allow modifications only by expert personnel, have competent persons inspect it (initial, periodic and special inspections) and keep the results, and give workers training and clear written instructions.
• Personal Protective Equipment Directive 89/656/EEC: PPE is used when risks cannot be avoided or sufficiently limited by technical means of collective protection. The employer provides appropriate equipment free of charge, organises training and demonstrates its use.
• Noise Directive 2003/10/EC, Carcinogens and Mutagens Directive 2004/37/EC (amended by Directive (EU) 2017/2398, which set the wood dust limit) and ATEX workplace Directive 1999/92/EC (explosive atmospheres) are covered in later lessons.

The manufacturer's side

Directive 2006/42/EC (adopted 17 May 2006) is the Machinery Directive. EU-OSHA's summary: the manufacturer or authorised representative must ensure that a risk assessment is carried out for the machinery and that the design reflects its results; the CE marking is the only marking guaranteeing conformity; and a technical construction file must be prepared.

Regulation (EU) 2023/1230 replaces the Directive. According to EU-OSHA, it applies from 20 January 2027; the requirements for notified bodies apply from 20 January 2024. It clarifies concepts such as incomplete machinery and substantial modification, and extends coverage to autonomous mobile machinery, connected equipment and AI-based safety functions.

The portal's reading (an interpretation): machinery placed on the market before that date is assessed under the Directive and machinery placed on the market from that date under the Regulation. The transitional provisions were not checked against the Regulation text, so confirm them before relying on this. A commercial consultancy article also reports a 2026 amendment concerning AI provisions with no change to the 20 January 2027 date; it is a secondary source, so check the Official Journal.

Directive or regulation: why the difference matters

A directive must be transposed into each country's national law, so details differ between member states and national wording matters. A regulation applies directly. That is why this course keeps saying: check your national transposition.

Worked example: a mill adds a new infeed to an old line

A mill owner bolts a new infeed conveyor onto an existing sorting line and removes a fixed guard to make room. Using what you have just read:

1. The DGUV sawmill page says CE conformity must be re-examined for linked plants and after conversions.
2. Removing a guard or adding an infeed can make the owner responsible for the conformity of the resulting line (the portal's interpretation).
3. Under Directive 2009/104/EC, modifications should be made only by expert personnel and the equipment should be inspected again by a competent person.
4. The risk assessment under the Framework Directive must be updated, because a new hazard point now exists.

Tampering is a design and management issue

DGUV stresses designing machines so that protective devices are not tempting to bypass. The Polish inspectorate pointed to weak supervision. Both lead to the same practical rule: if workers keep defeating a guard, ask why (is it blocking a necessary task?) instead of only reprimanding them.

Checklist: questions to put to a machine supplier

• Which regime (Directive 2006/42/EC or Regulation (EU) 2023/1230) applies to this machine?
• What does the declaration of conformity cover, and does it cover the linked line?
• Are the instructions in a language our operators read?
• Which tasks (cleaning, jam clearing, blade change) does the risk assessment assume, and what isolation does it expect?

Key points

• Employers: Framework Directive 89/391/EEC, work equipment Directive 2009/104/EC, PPE Directive 89/656/EEC.
• Manufacturers: Directive 2006/42/EC, replaced by Regulation (EU) 2023/1230, which applies from 20 January 2027.
• CE marking is the only marking guaranteeing conformity; linked plants and conversions need re-examination.
• Modifications only by expert personnel; equipment inspected by competent persons with results kept.
• Directives are transposed nationally: always check your own country's version.