ATEX guide now available in its 6th edition

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In contrary to hand-operated pumps, it may be questionable if a battery-operated pump declared for domestic and non-commercial environment, would fall in scope of Directive 2014/34/EU. The pump does not fall in scope of the Directive 2014/34/EU due to the exemption in Article 1.2(c), but it shall fulfil provisions of General Product Safety Regulation (EU) 2023/988 (GPSR) and other applicable EU Harmonization Legislation.

In this case, the manufacturer must clearly describe intended use of product as required in the applicable legislation, in instructions for use, including precise indication of possible use of liquids. As the private users are not usually familiar with explosion hazards, it is necessary to describe all residual risks and necessary safety measures.

In any case, market surveillance authorities have the right to restrict such product from the market, if they conclude that the product may pose a risk to health and safety (such as risk of explosion during the use).

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The Directive does not specify the form of EU declaration of conformity and attestation of conformity.

If the EU DoC or attestation of conformity is provided in digital format, manufacturer should provide internet address or machine-readable code where the document can be accessed. Digital EU DoC or attestation of conformity should be made accessible online for the expected lifetime of the product and at least 10 years after the placing on the market or the putting into service.

Further details are provided in the Commission’s proposal 2025/0133 (COD) for Omnibus on digitalisation and common specifications.

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ATEX Directive does not specify the form of the instructions. When deciding the form of instructions for use, the manufacturers must take into account the intended use of the product as well as the probable environment of use and type and possibilities of end users. Instructions for use should be easily understandable, ensure precise, up to date and comprehensible information and take into account the technological development and changes of end-user behaviour.

Further details (such as requirements on accessibility, downloadability, printability, save ability on electronic device, paper format on request, and safety information on paper) are provided in the Commission’s proposal 2025/0133 (COD) for Omnibus on digitalisation and common specifications.
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(4) Different types of trace heating systems

a) Trace heating systems with a temperature class depending on the construction of the trace heater:
In the case of electrical trace heating systems with a temperature class depending on the construction of the trace heater (hereinafter referred to as type A), the temperature class is defined by the construction of the heating cable.
Typically, a type A trace heating system is understood to be a trace heating system with a self-limiting characteristic.
Therefore a trace heating system type A is an equipment according to Directive 2014/34/EU, even if the installation has not yet taken place.
The manufacturer needs an EU Type Examination Certificate issued by a Notified Body. The manufacturer of trace heating system type A is responsible for placing the product on the market together with an appropriate EU Declaration of Conformity, CE marking and instructions for use. Instructions for use shall serve as the information for appropriate commissioning, assembling and installation of the system in accordance with the manufacturer’s specifications. The specific temperature class is indicated on the marking of the trace heating system
The employer is responsible to install the trace heating system in accordance with Directive 1999/92/EC. The manufacturer's instructions for use must be taken into account during installation. In addition, also the requirements with respect to the skills of personnel during installation must be considered during installation.
If a trace heating system type A is to be operated with a more restrictive temperature class than the temperature class that results from the construction of the heating cable, see b).

b) Trace heating systems with a temperature class depending on the configuration

In the case of electrical trace heating systems with a temperature class depending on the configuration (described below as type B), important parameters relevant to explosion protection - in particular the temperature class - are mainly determined by the individual design, configuration of the heating circuit and the installation method.
In general, type B trace heating systems include fixed resistance heating cables.
Because of specific characteristics of trace heating systems type B, the placing on the market occurs only after the installation, as the temperature class only can be verified at that time by a final commissioning test. It means that the manufacturer affixes CE marking, the name plate including temperature class and issues the EU declaration of conformity only during or after installation.
The manufacturer is responsible for the installation of the trace heating system. However, the manufacturer can subcontract partial steps of the manufacturing process, in particular installation to a third party if there are corresponding contractual agreements with the manufacturer. The manufacturer obliges the subcontractor with these contractual agreements to respect the requirements of the manufacturer’s EU type examination certificate (e.g., for qualification of personnel). The manufacturer is responsible for all issued documents.
Engineering or installation companies act as a manufacturer, if they design trace heating systems Type B out of different components and install them on site. The reason why they are regarded as manufacturer is, that they place type B electrical trace heating systems on the market under their name or trademark. Therefore, such a company must get their own certificates of conformity and fulfil all obligations of the manufacturer, including EU Declaration of Conformity, the CE marking and instructions for use.