Who is responsible for CE marking of driverless transport systems?
The individual vehicle is CE marked by the vehicle manufacturer. For the driverless transport system as a whole, whoever assembles it at the site and puts it into service is responsible. That covers vehicles, fleet control, routes, charging stations and the interfaces to doors and lifts. Anyone adding vehicles later or changing routes intervenes in that system responsibility.
Where does the line between vehicle and system run?
| Level | Scope | Responsible party |
|---|---|---|
| Vehicle (driverless truck) | Vehicle with drive, personnel detection sensors, load handling | Vehicle manufacturer: CE marking and declaration of conformity |
| Fleet control | Order management, traffic control, assignment of routes | System supplier |
| Infrastructure | Routes, charging stations, transfer stations, doors and lifts | Integrator together with the operating company |
| The system as a whole | All levels interacting at the specific site | Whoever assembles it and puts it into service: integrator or operating company |
The CE marking of the vehicle does not cover the overall system. That is the most common false assumption in AGV projects.
What is the problem with plug-and-play extensions?
Driverless transport systems are deliberately marketed so that additional vehicles can seemingly be added without effort. Technically that is often true; in safety terms it is a modification of the system.
An additional vehicle changes the traffic density on the routes, the occupancy of narrow points and intersections, the behaviour at transfer stations and the load on charging places. Hazards that were under control with three vehicles may have to be reassessed with eight.
The same applies to changes to the routes: a new path through an area with pedestrian traffic is a different installation in safety terms, even if nothing has changed on the vehicles.
So assess every extension like a possible substantial modification, not like a procurement.
What do I have to check when extending a fleet?
Which standard applies to driverless industrial trucks?
The relevant standard is EN ISO 3691-4:2023-12 for driverless industrial trucks and their systems. It covers both the vehicle and requirements for the operating area.
Alongside it the usual basics apply: EN ISO 12100 for risk assessment, EN ISO 13849-1 for the control safety of the safety functions and EN 60204-1 for the electrical equipment.
The VDMA materials handling and intralogistics association has also published a free brochure on CE marking of driverless trucks and their systems. It is useful as a practical guide for separating the roles but does not replace your own assessment.
For container robots in cube-based storage systems, EN ISO 3691-4 does not apply; a different set of standards is relevant there.
Sources and standards
- EN ISO 3691-4:2023-12: industrial trucks, driverless industrial trucks and their systems
- VDMA materials handling and intralogistics association: brochure on CE marking of driverless trucks and systems
- Machinery Regulation (EU) 2023/1230, Art. 3(16)
- EN ISO 12100 · EN ISO 13849-1 · EN 60204-1
Editions of standards and their harmonised status change continuously. Check standard numbers and editions against the current list in the Official Journal of the EU before applying them. This article is a technical classification and does not replace legal advice.
Frequently asked questions
Is the CE marking of the individual vehicles enough?
No. It covers the vehicle, not the interaction of vehicles, fleet control, routes and building interfaces at the specific site. The overall system requires an assessment of its own.
Is adding a vehicle a substantial modification?
Not necessarily, but it has to be assessed. What matters is whether the additional vehicles create new hazards or increase existing risks so much that simple protective measures are no longer sufficient.
Who is responsible if the operating company orders vehicles itself?
Whoever carries out the extension and puts it into service is responsible for the modified system. If the operating company orders directly from the vehicle manufacturer and integrates the vehicles itself, system responsibility lies with them.
Does EN ISO 3691-4 also apply to autonomous mobile robots (AMR)?
The 2023-12 edition addresses driverless industrial trucks including autonomously navigating vehicles. Check the scope against the specific design and function of your vehicle in each case.
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This article was produced with AI assistance and reviewed for technical accuracy before publication. Editorial responsibility within the meaning of Art. 50(4) of the AI Act (EU) 2024/1689 lies with Heinrich Knutas.
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