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

A decision table for machine panels, MCCs, boards feeding machines, panels shipped loose and skids, where public sources disagree, and what to specify.

By Wataru Sasaki, Editor. Written with AI assistance under human editorial supervision.

Published 5 November 2026. Updated 5 November 2026. 10 min read.

Desk research. The figures here are calculated from published formulas or taken from public records, with sources in the notes. None of it was measured on a production line.

Safety: not yet checked by a qualified engineer. This work can injure or kill. Use it to prepare questions, and follow the equipment maker's instructions, your risk assessment and the licensed standard.

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.

StandardOn the machinery list?On the low-voltage list?What follows
EN 60204-1:2018Yes (version 16, 8 August 2026)1Yes (version 13, 5 September 2025)2Can support a declaration under either set of regulations
EN 61439-1:2011 and EN 61439-2:2011No entryYes2The list names the 2011 parts, which gives a presumption under the electrical regulations only. BEAMA warns that a withdrawn edition cannot automatically reflect the state of the art and says conformity can be shown using the latest, undesignated edition, so verify to the current edition.3 On our reading, cite the 2011 part on a declaration only if the panel also meets it, because the presumption belongs to the edition you actually applied.

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.4 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 2028,5 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 2027.126 BSI says the amendment changes, among other things, the method for short-circuit current ratings.5 Work to the current text, and on our reading claim 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.7 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.8

The decision table

The "what flips it" column is our reading unless a note is attached.

What you haveStart fromLegal route and who signsWhat flips it
Machine control panel built by the machine builder and shipped with the machineBS EN 60204-1, or the part for that machine type such as -32 for hoisting machines.1 61439 optional, for heat and fault design.4Machinery regulations, through the machine's own declaration. Not separately placed on the market, in ZVEI's view.9The panel also feeds other plant: see the last row
The same panel built by a subcontractor to the machine builder's order, not sold in the subcontractor's nameBS EN 60204-1, as the machine builder specifiesZVEI says no declaration or marking of its own, whatever the scale of the design work, so long as the machine builder takes responsibility.9 BEAMA and OPSS differ (see below).It is marketed under the subcontractor's name, or the machine builder will not accept the manufacturer's role
Panel shipped loose for a machine built by someone else, in the panel builder's nameBS EN 60204-1, which can also support a low-voltage declaration.2Panel builder is manufacturer: electrical safety, EMC and RoHS regulations, its own declaration and marking.9It implements safety functions of its own: a safety component.98 Sold as one product with its motor or actuator: part of partly completed machinery.8
Motor control centreBS EN IEC 61439-2103Electrical safety, EMC and RoHS regulations; assembly maker declares.311It is the control section of one packaged machine: 60204-1 then governs that machine's equipment
Distribution board feeding a machineBS EN IEC 61439-2; part 3 only for a board operated by ordinary persons3Electrical safety, EMC and RoHS regulations; BS 7671 for the installation.1110 Siemens says 60204-1 starts where the machine's equipment connects to the supply,12 so this board is upstream of it.The board sits after the machine's supply disconnecting device, or ships as part of the machine
Skid package with its own panel, such as a pump or compressor setBS EN 60204-1Machinery regulations, through the skid's declaration of conformity and marking. A skid that lacks only site connections or power is still machinery, even though it cannot run until installed.78 Use a declaration of incorporation only if it cannot perform its specific application until built into something else.13 A hazardous area or pressure parts bring further regimes.The panel ships separately to an integrator: third row
Replacement panel on an existing machineBS EN 60204-1From the original machine maker as a like-for-like spare: treated as a spare.7 Built by anyone else and sold in its own name: third row; if it delivers safety functions and is supplied independently, HSE treats it as a safety component.13 The owner then checks the Provision and Use of Work Equipment Regulations.In GB, if the change is effectively a new machine, affects safety devices or systems, or brings new hazards, the machine needs full conformity assessment and a new mark (HSE).13 In Northern Ireland and the EU from 20 January 2027, the narrower "substantial modification" in the marking guide
One enclosure with a distribution section and a machine control sectionBoth, each to its own section, with the boundary written downShipped as part of the machine, the machine's declaration; shipped alone, the panel builder's declaration under the electrical safety, EMC and RoHS regulationsWho signs. Agree one legal entity for the whole enclosure

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.4 Siemens calls 60204-1 the starting point and 61439 something to consult where a risk analysis finds risks it does not cover.12 BEAMA's July 2026 guide says "all assemblies must conform to the appropriate part" of the 61439 series.3 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.9 BEAMA says every assembly placed on the GB market must carry UKCA or CE marking.3 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.7 That passage concerns imports, so applying it to a domestic subcontractor is our 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.

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.8 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.9

What to write in the specification

Most of this argument disappears if the enquiry answers it first:

  • 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. Short-circuit ratings and temperature rise both change with these.
  • Markets and documents: which of Great Britain, Northern Ireland and the EU, and what you will receive. "Deviations from the verified design to be listed before order."

What evidence to ask for under each route

RouteAsk for
61439 assemblyDesign verification evidence for the system and each deviation from it, and whether the tested sample closely matches what you are buying.3 Routine verification record for this serial number.10 Declaration citing the regulations and dated standards.
60204-1 panel inside a machineThe machine's declaration and the panel documents Siemens lists: description, operating and maintenance information, parts list, installation notes, schematic and wiring diagrams, protective devices.12 You have no right to the machine maker's technical file, which HSE says stays confidential.13
Panel as a safety componentMachinery declaration, evidence of conformity assessment, safety performance data and instructions.8 Check the third-party rule in the marking guide.

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

  4. 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

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

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

  7. 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

  8. 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

  9. 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

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

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

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

  13. 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

  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. ↩