BS EN IEC 61439 or BS EN 60204-1: which applies to a panel?

If the panel is part of a machine's electrical equipment, start from BS EN 60204-1. If it is a stand-alone assembly that distributes power or feeds other equipment, such as a switchboard, a motor control centre or a board feeding a machine, start from the BS EN IEC 61439 series. It can be both, because one enclosure can hold both jobs and 61439 can support a 60204-1 design, but the two are not interchangeable in law: EN 60204-1:2018 is designated in Great Britain under both the machinery and the low-voltage regulations, while EN 61439-1 and -2 are designated under the low-voltage regulations only.¹² This is a legal and contractual judgement as much as a technical one, so confirm it with whoever signs the declaration, and take clause-level detail from the licensed standard.

Which standard, by the panel you are building

The "what flips it" column is an inference from the sources cited in the same row, unless it carries a note of its own.

What the GB designated lists give each standard

DKE, the German standards committee, reached the same conclusion from the EU lists: the 61439 parts are listed under the Low Voltage Directive only, so applying them alone gives no presumption that machinery requirements are met.³ BSI lists BS EN 60204-1:2018+A1:2025 as current, published 30 April 2025, and says the 2018 text will be withdrawn on 30 April 2028,¹² while the GB lists and the EU's machinery summary list name EN 60204-1:2018 without the amendment, and the EU row ends with the Directive on 20 January 2027.¹²¹³ BSI says the amendment changes, among other things, the method for short-circuit current ratings.¹² Read together, these sources suggest working to the current text and claiming the presumption only for what the listed text requires and the panel meets.

The machinery regulations also exclude "low-voltage switchgear and control gear" in so far as the Electrical Equipment (Safety) Regulations cover it.¹⁰ The Commission's guide adds two conditions: once incorporated, that equipment must let the machine meet the machinery requirements, and the exclusion does not reach electrical safety components.⁵

Where public sources disagree

Is 61439 needed at all on a machine panel? DKE says 60204-1 is sufficient to declare conformity for assemblies that are part of the electrical equipment of machines, with 61439 an additional aid for things like heat and short circuit.³ Siemens calls 60204-1 the starting point and 61439 something to consult where a risk analysis finds risks it does not cover.⁹ BEAMA's July 2026 guide says "all assemblies must conform to the appropriate part" of the 61439 series.⁷ BEAMA's guide runs from consumer units to switchboards and MCCs and does not mention machine panels, so the two may have different things in view, but read literally they conflict. A Safe Machine trade article sits between them: 60204-1 with specific clauses or subclauses of 61439 considered.¹⁴

Does a build-to-order panel need its own declaration? ZVEI, the German trade body, says no if the machine builder takes responsibility and the supplier does not market it in its own name.⁴ BEAMA says every assembly placed on the GB market must carry UKCA or CE marking.⁷ OPSS is mixed: products imported for further manufacture are not placed on the market and the finished product's manufacturer has sole and ultimate responsibility, but components can be products in their own right.¹⁰ That passage concerns imports, so applying it to a domestic subcontractor is an inference. No UK authority has ruled. A contract records who takes responsibility; it does not decide whether a placing on the market happened. If the panel could go on anything else, or the customer will not accept the role in writing, issue your own declaration. That is an inference, not a rule any of the three states. ZVEI's case 2 turns on the panel not being marketed in the supplier's own name and on the machine builder assuming responsibility, and ZVEI recommends, without requiring, a written agreement that names the machine builder as manufacturer.⁴ BEAMA's wording covers every assembly placed on the GB market.⁷ OPSS says components can be products in their own right.¹⁰

Does a safety function change the regime? The Commission's guide says a control unit or board delivering safety functions is a safety component if the rest of the definition is met.⁵ ZVEI applies that to cabinets and draws a further line: fit only bought-in safety components to their makers' instructions, and the cabinet stays under the low-voltage route.⁴

What to agree with the customer before the order

The disagreements above turn on the boundary, the roles and the edition. Wording for each, for the quotation or the order acknowledgement:

• The boundary: "The electrical equipment of machine [X] starts at the incoming terminals of the supply disconnecting device in panel [Y]. Everything upstream is installation, to BS 7671."
• The roles: "[Supplier] is the manufacturer of panel [Y] and will sign its declaration" or "[Purchaser] is the manufacturer and will include panel [Y] in its machine's declaration; [Supplier] does not market the panel under its own name."
• Standard and edition: "Designed and verified to BS EN 60204-1:[state whether A1:2025 is applied]. Sections [Z] also verified to BS EN IEC 61439-2:[edition] for temperature rise and short-circuit withstand."
• Safety functions: "Safety functions in panel [Y] are designed and validated by [party]."
• Ratings at the connection point: prospective short-circuit current, rated current, ambient and enclosure class. BEAMA's specifying guide asks the specifier for the prospective short-circuit current at the incoming terminals with the supplies' modes of operation, the design currents, any conditions harsher than the standard assumes, and the cables to be terminated; where design currents are not given, the manufacturer has to assume them.⁷ Checking short-circuit ratings against the site's fault level and temperature rise in a sealed panel both change with these.
• Markets and documents: which of Great Britain, Northern Ireland and the EU, and what the customer will receive. "Deviations from the verified design to be listed before order."

What evidence to keep under each route

The right-hand column is what the cited source lists for that route, which is also what a customer working from it will ask to see.

A 60204-1 panel still needs a short-circuit answer. Siemens' Edition 6 white paper says chapter 7.10 requires the short-circuit current rating of the electrical equipment to be determined by design rules, calculation or test,¹⁵ so the panel file needs that rating, how it was reached and the protection it relies on. A 61439 certificate alone does not answer the 60204-1 items, and a 60204-1 declaration alone gives the customer no tested temperature-rise or short-circuit evidence.

Notes

1. GOV.UK, Designated standards: machinery, consolidated list version 16, 8 August 2026. Checked for all 60204 and 61439 entries. ↩ ↩² ↩³ ↩⁴

2. GOV.UK, Designated standards: low voltage, consolidated list version 13, 5 September 2025. Latest on the page when read in November 2026. ↩ ↩² ↩³ ↩⁴ ↩⁵

3. DKE/K 225, Information on the application of DIN EN 60204-1, DIN EN 61439-1 and DIN EN 61439-2 for the installation of electrical equipment of machines. Undated; the file was created in 2015 and refers to the earlier Low Voltage Directive. German committee, EU lists, not a UK position. ↩ ↩² ↩³

4. ZVEI, Placing on the market and CE marking of switchgear cabinets for machines, position paper, 5 November 2018. Trade body view under the Machinery Directive, cases 1 to 3.2b. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷

5. European Commission, Guide to application of the Machinery Directive 2006/42/EC, edition 2.3, April 2024, §38, §42, §46, §68 and §417. Guidance on the EU Directive, not UK law, and written about control units and boards rather than whole cabinets. The Machinery Regulation replaces the Directive from 20 January 2027. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶

6. BEAMA, Guide to Verification: Low-voltage Power Switchgear and Controlgear Assemblies, July 2023. ↩ ↩² ↩³

7. BEAMA, Specifying a Low-Voltage and Controlgear Assembly, edition 1, July 2026, sections 1 to 9. ↩ ↩² ↩³ ↩⁴ ↩⁵ ↩⁶ ↩⁷ ↩⁸ ↩⁹

8. GOV.UK, RoHS compliance and guidance, updated 22 July 2025. ↩ ↩²

9. Siemens, Keep up with IEC control cabinet standards. Supplier page, automated translation of the English original. ↩ ↩² ↩³

10. Office for Product Safety and Standards, Supply of Machinery (Safety) Regulations 2008: Great Britain, updated 24 March 2025, sections 3 and 7 and Annex A. ↩ ↩² ↩³ ↩⁴ ↩⁵

11. HSE, Placing work equipment and machinery on the market after Brexit, updated 29 October 2024. Its dates for CE marking are out of date; the points used here are about roles and modifications. ↩ ↩² ↩³ ↩⁴

12. BSI Knowledge, BS EN 60204-1:2018+A1:2025. Publisher's product page; the standard was not read. ↩ ↩²

13. European Commission, Harmonised standards: machinery, summary list generated 28 October 2026. ↩

14. D. Coulson and P. Skyrme, Safe Machine, Should you use BS EN 61439 or BS EN 60204 for machine control panels?, Industrial Technology, 13 May 2024. Trade article. ↩

15. Siemens, White paper on the changes in IEC 60204-1 Edition 6. Supplier guide; check the clause in the licensed standard. ↩