Who is responsible for CE marking of an automated small parts store or shuttle system?
Responsibility for CE marking of the whole installation lies with whoever connects the individual components into a functional unit, usually the system integrator or main contractor. The system supplier only declares its own scope of supply. Where there is no main contractor, the operating company itself becomes the manufacturer of the whole installation.
Who issues the declaration of conformity for the whole installation?
In CE terms an automated small parts store or shuttle system is almost never a single product. It consists of the storage structure with its container robots, the transfer stations, upstream and downstream conveyor technology, workstations, an overarching control system and usually a warehouse management system. These parts typically come from different suppliers.
Whoever combines these parts into a functional unit and places it on the market or puts it into service as a whole is the manufacturer of the installation. That party carries out the risk assessment for the whole installation, issues the EU declaration of conformity and affixes the CE marking.
In practice that is the system integrator or the main contractor. Where the installation is procured without a main contractor, for instance because the operating company buys storage technology, conveyors and controls separately and coordinates the trades itself, the role passes to the operating company. That often happens unintentionally.
Which role carries which duty?
| Role | Typical delivery | CE duty |
|---|---|---|
| System supplier | Storage structure, container robots, transfer stations, robot control | Declaration of conformity or of incorporation for its own scope, assembly instructions, interface description |
| Conveyor supplier | Continuous conveyors, transfer points | Declaration of conformity or of incorporation for its own scope |
| System integrator / main contractor | Assembly, overarching control, safety concept | Risk assessment of the whole installation, EU declaration of conformity for the whole installation, CE marking, overall instructions for use |
| Operating company | Operation of the installation | Workplace risk assessment. Becomes the manufacturer as soon as it links or modifies things itself |
The table shows the usual division. What is decisive is always the contractual arrangement and who actually connects the parts into a unit.
How do I determine who the manufacturer is in my project?
Which documents should I obtain from the supplier?
What is the most common mistake in such projects?
- The operating company collects individual declarations of conformity from the suppliers and considers the topic settled. No declaration and no risk assessment then exists for the installation as a whole.
- The interface between the storage system and the conveyor technology is not covered in safety terms by either supplier.
- Robots or additional ports added later are treated as spare parts, although they change the installation.
- The overarching safety concept across all trades is missing because each supplier only looked at its own area.
Sources and standards
- Interpretation paper on assemblies of machinery (BMAS, BAuA, DGUV, VDMA, 2011)
- Machinery Regulation (EU) 2023/1230, Art. 3(16) (substantial modification), Annex III
- EN ISO 12100: risk assessment and risk reduction
- EN ISO 13849-1: safety-related parts of control systems
- 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
Does the system supplier affix a CE marking itself?
The system supplier declares the conformity of its own scope of supply. A declaration for your whole installation including conveyors, workstations and the overarching control system is not covered by that. There is no publicly citable manufacturer documentation for this; do not rely on analogies but have the scope of supply delimited in writing.
Do I as the operating company really become the manufacturer if I coordinate things myself?
Yes. Whoever connects machines into a functional unit and puts it into service takes on the manufacturer duties for that unit. That applies regardless of whether you built the parts yourself or only bought them.
Is a shared emergency stop chain enough for one overall CE marking?
No. Under the German interpretation paper, a shared emergency stop alone is minor linking and does not create an assembly of machinery. All four criteria have to be met at the same time.
Does responsibility change with the Machinery Regulation from 2027?
The basic logic stays: the manufacturer is whoever places the product on the market. Machinery Regulation (EU) 2023/1230 does however tighten the requirements for documentation, substantial modification and cybersecurity. Installations put into service beyond 20 January 2027 should be aligned with it early.
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.
Write me a few lines about your project. You get a first assessment back, free of charge and without obligation.
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.
No credit card required. A complete project to try out.