How does CE marking of machinery work?
In eight steps: classify the product, determine the applicable legislation and standards, carry out the risk assessment, implement protective measures, compile the technical documentation, write the instructions for use, go through the conformity assessment procedure, and finally issue the declaration of conformity and affix the CE marking.
Which steps does CE marking involve?
Which document do I need for which product type?
| Product type | Declaration | Instructions | CE marking |
|---|---|---|---|
| Machinery | EU declaration of conformity | Instructions for use | Yes |
| Partly completed machinery | Declaration of incorporation | Assembly instructions | No |
| Assembly of machinery | EU declaration of conformity for the whole installation | Instructions for use of the whole installation | Yes, for the whole installation |
| Safety component | EU declaration of conformity | Instructions with installation and safety data | Yes |
Partly completed machinery receives no CE marking under the Machinery Regulation. It may only be put into service once it has become part of a conform final machine.
What has to be on the rating plate?
- Business name and full address of the manufacturer, and where applicable of the authorised representative.
- Designation of the machine and its series or type designation.
- Serial number, where one exists.
- Year of construction, that is the year in which the manufacturing process was completed.
- CE marking in the prescribed form and minimum size.
- Where applicable the identification number of the notified body.
- Technical data required for safe operation, such as rated power, voltage, mass or load capacity.
How long does CE marking take?
The honest answer: it depends almost entirely on when you start.
If the risk assessment runs alongside the design work and the documentation is kept up to date, the formal conclusion is a matter of days, because the work is already done.
If everything is pushed to the end of the project, a typical special purpose machine quickly takes several weeks: catching up on the risk assessment, producing evidence for the safety functions, writing the instructions for use, sorting the documents. And design faults that step 1 of the three-step method could have avoided can then only be compensated expensively with safeguards.
Where a notified body comes into play, its schedule dominates the timeline. Plan generously here; towards the deadline of 20 January 2027 demand is likely to rise sharply.
Sources and standards
- Machinery Regulation (EU) 2023/1230: conformity assessment, marking, technical documentation
- EN ISO 12100: risk assessment and risk reduction
- EN ISO 20607: instruction handbook, general drafting principles
- EN 60204-1: electrical equipment of machines
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
Who may affix the CE marking?
Only the manufacturer or its authorised representative. By affixing it they declare that the machine meets all applicable legislation and that the prescribed conformity assessment procedure has been carried out.
Do I need a separate risk assessment for every machine?
For every machine type. For series machines the assessment covers the model range, provided the individual units are technically identical. Variants and customer-specific adaptations have to be assessed in addition.
What does CE marking cost?
There is no flat figure; the effort scales with complexity, the situation regarding standards and internal maturity. The biggest cost lever is the starting point: begun early, the documentation is a by-product of the design work; begun late, it is a project of its own.
Does an authority check my documents before placing on the market?
No. There is no prior approval. The market surveillance authority can however request the technical documentation afterwards upon reasoned request, which is why it has to remain available for ten years.
Has been guiding CE projects in machinery, plant and special purpose engineering for years. That work led to Kaidoc.app, a software for standards-based CE documentation. Through Knutec.de the same work is available as a personal service.
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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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