VGP · obligations
Is VGP mandatory or not? The equipment-by-equipment table
VGP is mandatory for all lifting appliances and accessories covered by the French ministerial order of 1 March 2004 (MEWPs, forklifts, cranes, overhead cranes, slings…) and for ride-on earth-moving equipment covered by the French ministerial order of 5 March 1993. A mini excavator is therefore covered. A pallet truck that only lifts the load just clear of the ground is not.
To find out whether a piece of equipment needs a VGP inspection, two questions are enough: does it lift a load or a person with a genuine change in height? Is it construction equipment with a ride-on operator? The table below answers case by case.
Where the obligation comes from
Article R4323-23 of the French Labour Code (Code du travail) provides that ministerial orders list the equipment subject to periodic thorough inspections (VGP) and set their frequency. For an equipment fleet, two orders matter:
- the French ministerial order of 1 March 2004 (arrêté du 1er mars 2004): load- or person-lifting appliances and lifting accessories, with a list of covered appliances and a list of excluded appliances in the annex;
- the French ministerial order of 5 March 1993 (arrêté du 5 mars 1993): certain machines, including “mobile machines for extraction, earth-moving, excavation or ground drilling with a ride-on operator”, inspected every 12 months.
Table of mandatory VGP inspections, case by case
| Equipment | VGP mandatory? | Why |
|---|---|---|
| MEWP (aerial work platform) | Yes, every 6 months | Work platform elevator listed in the annex of the 2004 order |
| Forklift, telehandler | Yes, every 6 months | “Self-propelled lifting trucks” listed in the 2004 annex |
| Stacker | Yes | Listed in the 2004 annex: 6 months if self-propelled, 12 months if manual |
| Standard electric or manual pallet truck | No | Excluded by the annex: it only lifts the load just clear of the ground |
| High-lift pallet truck, which raises the load in height | Yes, generally | The change in level becomes significant: it falls within the definition of a lifting appliance |
| Mini excavator, excavator, wheel loader, ride-on bulldozer | Yes, every 12 months | French ministerial order of 5 March 1993, Article 2 |
| Mini excavator or excavator used for lifting (hook, lifting eye) | Yes, additionally: 6 months for the lifting function | “Earth-moving equipment fitted for handling objects” (2004 annex) |
| Dumper, ride-on compactor | Yes, every 12 months | Listed among the earth-moving equipment covered (technical note No. 9, reproduced in INRS ED 6339) |
| Walk-behind equipment (plate compactor, pedestrian roller) | No, under the 1993 order | The “ride-on operator” concept excludes equipment walked alongside |
| Mobile crane, lorry-mounted loader crane | Yes, every 6 months | Listed in the annex and in Article 20-II of the 2004 order |
| Overhead crane, gantry crane, hoist, jib crane | Yes, every 12 months | Listed in the 2004 annex |
| Lifting table, tail lift | Yes | Listed in the 2004 annex: 6 months for the tail lift; 12 months for the table, 6 months if it lifts people |
| Tractor with front loader fitted for lifting | Yes | Listed in the 2004 annex |
| Slings, spreader beams, shackles, clamps | Yes, every 12 months | Lifting accessories, Article 24 of the 2004 order |
| Tipper truck, tilting flatbed equipment transporter | No | Excluded by the 2004 annex, unless the tipper body is fitted on a lifting mechanism |
| Concrete pump mast, conveyor | No, under the 2004 order | Excluded by the 2004 annex |
Mini excavator: mandatory or not?
Yes. A mini excavator with a seated operator is a mobile earth-moving machine with a ride-on operator: the French ministerial order of 5 March 1993 requires a VGP inspection at least every 12 months. The size or weight of the machine does not matter.
If the mini excavator is also used to lift loads, with a hook or lifting eye, it becomes “earth-moving equipment fitted for handling objects”. Its lifting function then requires a VGP inspection every 6 months under the French ministerial order of 1 March 2004. INRS brochures ED 6339 and ED 828 specify that both inspections apply together. For a particular configuration, ask your inspection body for advice.
Electric pallet truck: mandatory or not?
For a standard pallet truck, electric or manual, the answer is no: the annex of the French ministerial order of 1 March 2004 excludes “pallet trucks that raise the load only to the height needed to move it by lifting it clear of the ground”. It is not the type of power that matters, but the lift height.
As soon as the device raises the load to a height, for example a stacker or a high-lift pallet truck, it falls within the list and VGP applies. If in doubt, check the maximum lift height on the user manual.
Equipment not subject to VGP must still be maintained and kept in good condition (Article L4321-1 of the French Labour Code). INRS then advises the employer to set their own inspection frequency, based on the risks and the manufacturer’s manual.
Forklift: mandatory or not?
Yes. Self-propelled lifting trucks, whether ride-on or not, are listed in the annex of the 2004 order. For a self-propelled forklift, including telehandlers, VGP takes place every 6 months. If the forklift receives interchangeable attachments (platform cage, jib, bucket), it is inspected in each of its configurations according to INRS.
Rented equipment or rarely used appliances
- Rented equipment: the obligation does not disappear. The user company checks with the rental company that VGP inspections are up to date; copies of the reports travel with the equipment (2004 order, Article 15).
- Rarely used equipment: the VGP interval still applies. Equipment left idle for several months must be up to date before returning to service.
- Area with no exposed person: according to INRS, a lifting appliance operating in a genuinely inaccessible area, protected by technical means, may be exempted from VGP under the employer’s responsibility. This is rare on a construction site.
Once you have drawn up the list of equipment covered, Trackary keeps their VGP due dates up to date and alerts you before each one, but the inspection itself is still carried out by your inspector. Request a demo →