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14 June 2023

The Ministry of Industry clarifies the requirements for power-operated pedestrian doors

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AEPA, Asociación Empresarial de Puertas Manuales y Automáticas, has echoed a note from the Ministry of Industry, Commerce and Tourism on the CE marking of power-operated pedestrian doors, which clarifies the Ministry's position on the CE marking of this type of doors, the requirement to assess the risks and test the doors when they are motorised.

AEPA indicates that, a priori, it seems that the Ministry will extend this obligation not only for when doors are power operated, but also to automated doors, for example, those with a simple spring that closes the door. "This would be the interpretation if we follow the literal meaning of the text of the note, where the installation of an 'operator' or motor for automation is mentioned as determining the requirements referred to. However, it is not specified what ‘operator’ means”. They added that “at AEPA we will be attentive to the foreseeable clarifications of this note in order to understand and disseminate its true scope".

The informative note from the Ministry of Industry, Commerce and Tourism indicates, among other issues, that for the specific case of automatic pedestrian doors  the CE mark is obligatory from the time at which the Machinery Directive enters into force (the current version in force is Directive 2006/42/CE on machinery). “The Directive is a document which establishes generic requirements and which provides for the use of harmonised standards as a means of obtaining 'presumption of conformity' with the applicable safety requirements. In the case of automated pedestrian doors, the standard which is harmonised with Directive 2006/42/CE for machinery is standard EN 16005:2012 Power Operated Pedestrian Doors. Safety in use. Test methods and requirements. This standard provides presumption of conformity for CE marking if the construction, modification or automation of existing pedestrian doors is carried out in accordance with the safety requirements laid down in this standard”.

Safety requirements

This harmonised standard established safety requirements for  power operated pedestrian doors as a whole: “It establishes requirements for the operator or motor, for the activation of the manoeuvre, for the type of manoeuvre itself, for the door leaf and the materials used, for the movement and possible impact of the door leaf, etc.".

It follows from the above that the CE marking of an automatic door implies compliance with safety requirements which apply to the door as a whole. “For this reason it is not enough, although it is necessary, that its devices and components (such as the operator or the motor installed) have their corresponding CE mark. While it is a requirement that the operator or motor and all other safety devices fitted to the automatic pedestrian door have a CE marking and the relevant EU Declaration of Conformity or CE Declaration of Incorporation, this is not sufficient for the CE marking of the door as a whole".