Which CE documents do I have to hand over to the customer, and which stay internal?
Only two documents necessarily go to the customer: the instructions for use and the EU declaration of conformity, or for partly completed machinery the assembly instructions and the declaration of incorporation. Risk assessment, calculations, detailed circuit diagrams and test and validation records belong in the technical documentation and stay with the manufacturer. The customer has no legal claim to them; you only have to submit them to the market surveillance authority upon reasoned request.
How many documents are really mandatory?
When placing a machine on the market, the Machinery Regulation requires exactly two documents to be supplied with it: the instructions for use and the EU declaration of conformity. Added to that is the marking on the machine itself: the CE marking and the details on the rating plate.
Everything else that typically changes hands in projects is either a contractual service or does not belong in the scope of delivery at all: risk assessment, sets of circuit diagrams, test records, calculations, lists of standards. This distinction matters because it separates what you have to deliver from what you want to deliver. Whatever you hand over once without need will be expected as standard in the next project.
What has to be supplied with the machine?
For an assembly of machinery the customer receives one declaration of conformity for the whole installation. The declarations of the individual machines move into your technical file and should be required from suppliers by contract.
Which document goes where?
| Document | To the customer | In the technical file |
|---|---|---|
| Instructions for use | Mandatory | Yes, all language versions |
| EU declaration of conformity | Mandatory | Yes |
| Declaration of incorporation, assembly instructions | Mandatory for partly completed machinery | Yes |
| Risk assessment | No, not mandatory | Yes, in full |
| Test and measurement records | No | Yes |
| Validation of safety functions, performance level calculation | No | Yes |
| Design drawings, strength calculations | No | Yes |
| Circuit diagrams | As far as needed for operation and maintenance | Yes, in full |
| List of applied standards and legislation | An extract appears in the declaration of conformity | Yes, in full with editions |
| Declarations of conformity of bought-in components | No | Yes |
| Maintenance and spare parts information | Mandatory | Yes |
| Software source code, control program | No | Only as far as relevant to conformity assessment |
Rule of thumb: what the operating company needs in order to run the machine safely, maintain it and produce its own workplace risk assessment is supplied. What demonstrates how you arrived at conformity stays with you.
The customer demands the risk assessment, what now?
Why the technical file is not a customer document
The technical documentation serves a different purpose than the documentation supplied with the machine. It demonstrates to the market surveillance authority that conformity was derived methodically: which hazards were considered, which standards applied, which evidence produced. Its addressee is the authority, not the operating company.
It has to be submitted upon reasoned request by market surveillance, usually within a period set by the authority. It has to be kept for at least ten years from placing on the market, for series production from the last unit delivered.
Two things follow from that. First: a customer demanding the file is not invoking any right the Machinery Regulation gives them. Second: handing it over can harm you without helping the customer. A risk assessment contains your design decisions, your evaluation logic and your assumptions about operation: know-how that has value in competition and can be used against you in a dispute.
Where you do hand something over, a confidentiality and ownership note belongs on every page, and the scope belongs in the contract rather than in an email shortly before acceptance.
Practical rules for handover
- Name the documentation scope in the quotation, do not negotiate it at acceptance. One line in the quotation saves the discussion during the project.
- Prepare a residual risk list as the standard answer to customer demands; it covers what the operating company actually needs.
- For linked lines and complete installations, require the suppliers' documents by contract before their machines arrive on site.
- Record the handover: which document, which revision, which date, to whom. In a dispute that is your only evidence.
- Put the language versions of the instructions for use into the technical file, not just the original German version.
- Tie the revision status to the serial number so that years later it can still be reconstructed which version belongs to which machine.
Sources and standards
- Machinery Regulation (EU) 2023/1230: manufacturer obligations, technical documentation, instructions for use
- Machinery Regulation (EU) 2023/1230, Annex III: information and warnings, instructions for use
- Machinery Regulation (EU) 2023/1230, Annexes V and VII: EU declaration of conformity, declaration of incorporation
- German Ordinance on Industrial Safety and Health: the employer's workplace risk assessment
- EN ISO 20607: instruction handbook, general drafting principles
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
Does the customer have a right to the risk assessment?
No. The Machinery Regulation gives them no claim to it; it is part of the technical documentation and stays with the manufacturer. You only have to submit it to the market surveillance authority upon reasoned request. Handing it over can be agreed contractually; it is then a commercial service, not a legal duty.
What does the operating company really need for its workplace risk assessment?
The remaining risks, the protective measures foreseen, the qualification required of staff and the necessary protective equipment. All of that is in the instructions for use. Where the operating company needs more detail, a residual risk list is the right route, not the complete assessment document.
Do I have to supply complete circuit diagrams?
What has to be supplied is what is required for operation and maintenance, that is the documents a maintenance technician needs to find faults and put the machine safely back into operation. The complete design data set with all variants and production states belongs in the technical file.
What applies to partly completed machinery?
It receives neither CE marking nor a declaration of conformity. What is supplied are the assembly instructions and the declaration of incorporation. In the declaration of incorporation you undertake to transmit the relevant technical documentation to the authority on request; there is no such duty towards the customer.
Can I provide the instructions for use as a download only?
The Machinery Regulation permits digital provision. You then have to state how the instructions are accessed, keep them available over the expected lifetime of the machine and supply the safety information on paper free of charge on request. For non-professional users the safety information has to be enclosed on paper in any 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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