Which standard applies to automated small parts stores, shuttle systems and container robots?
For cube-based storage systems with autonomous container robots there is no matching harmonised type-C standard. EN 528 covers rail-guided storage and retrieval machines, EN 619 continuous conveyors, EN 15095 power-operated circulation storage and EN ISO 3691-4 driverless industrial trucks; each covers only part of the ground. The storage and robot part therefore has to be safeguarded via EN ISO 12100, EN ISO 13849-1 and EN 60204-1.
- Which type-C standards come into question and where do they fit?
- Is there a type-C standard of its own for container robots in cube-based storage systems?
- How do I safeguard a system without a matching type-C standard?
- What if there is no matching type-C standard at all?
- How do I recognise a suitable analogous standard?
- A practical example: a welding line for roll-fed filter media
- Which hazards are overlooked most often on these systems?
Which type-C standards come into question and where do they fit?
| Standard | Edition | Scope | Fit for cube-based storage systems |
|---|---|---|---|
| EN 528 | 2023-02 | Rail-guided storage and retrieval machines with a lifting device along a mast | No, different kinematics |
| EN 619 | current | Continuous conveyors for unit loads | Partly, periphery only |
| EN 15095 | current | Power-operated circulation storage and storage lifts | No |
| EN ISO 3691-4 | 2023-12 | Driverless industrial trucks, AGV, AMR | Partly, floor-borne vehicles only |
Editions change continuously. Check the current status of harmonised standards in the Official Journal of the EU before applying them.
Is there a type-C standard of its own for container robots in cube-based storage systems?
For cube-based storage systems in which autonomous robots travel on a grid above stacked containers, no specific harmonised type-C standard currently exists. The design is younger than the available standards, and none of them reflects the kinematics: the robots travel horizontally on a grid and lift containers vertically out of the stack; there is neither a mast as on a storage and retrieval machine nor floor travel as on an industrial truck.
That is not a gap in the law but the normal case for new designs. Where a type-C standard is missing, safety is derived from the type-A and type-B standards.
This assessment is a technical conclusion from analysing the scopes of the standards named. For legally reliable communication with customers you should check it against the current status in the Official Journal.
How do I safeguard a system without a matching type-C standard?
What if there is no matching type-C standard at all?
For special purpose machinery this is the normal case, not the exception. A type-C standard is only applicable if its scope genuinely covers the machine. If none fits, safety is derived from the type-A and type-B standards: EN ISO 12100 for the method, EN ISO 13849-1 for control technology, EN 60204-1 for the electrical equipment. That is the duty and it is formally sufficient.
In practice, though, this leaves open which safety distances, speeds and operating modes are appropriate. You close that gap by applying the type-C standard of a technically similar machine by analogy. It supplies concrete figures and proven protection concepts that you would otherwise have to derive from scratch.
One point matters here: a type-C standard applied by analogy does not create a presumption of conformity. That only arises where the machine falls within the scope of the harmonised standard. What you gain is something else, but equally valuable: a defensible state of the art and a derivation that can be followed during an inspection.
So the decision belongs in the documentation. Record in the list of standards which standard you applied by analogy, for which aspects, and why it is technically comparable. Equally important is the other direction: which points of the analogous standard do not fit and how you safeguarded those instead.
How do I recognise a suitable analogous standard?
- Comparable kinematics: how does the workpiece or material move through the machine, continuously as a web, in cycles as unit loads, rotating?
- Comparable speeds and energies: web speed, mass, drive power and stored energy determine run-down distances and safety distances.
- The same type of hazard: drawing-in points, crushing and shearing points, cutting, thermal hazards. A standard that does not know your main hazard does not help.
- Comparable access situation: how often and for what purpose do people have to enter the hazard zone, during operation, setting or faults?
- Comparable operating modes: is there a setting mode with reduced speed and an enabling device?
- The industry sector is not decisive. Two machines from the same sector can be kinematically completely different, while two from different sectors can be almost identical.
Examine several candidates and note why you decided on one. That justification is later the most valuable part of the documentation.
A practical example: a welding line for roll-fed filter media
A line for producing filter elements: filter medium runs off the roll as a continuous web, is welded lengthways, cut to length and given cross seams. For exactly this machine no type-C standard exists.
The type-A and type-B standards were a given. For the concrete figures, though, guidance was missing, above all for the web path: unwinder, drawing-in points between rollers, web tension, behaviour on web break. Those are the most dangerous points of such a line, and the type-B standards say nothing machine-specific about them.
Two type-C standards for web-processing machinery came into the shortlist: the series for printing and paper converting machinery and the standard for textile machinery. Both deal with roll material, drawing-in points at roller pairs and protection concepts for running webs.
The decision fell on the textile machinery standard. What tipped it was technical similarity in the detail: comparable web speeds, a flexible sheet material rather than stiff paper webs, and unwinding and rewinding kinematics closer to textiles than to a web printing press. The paper standards are heavily tailored to printing units and their cylinder arrangement, which does not occur on this line.
After that the line could be laid out concretely: safety distances and covers at the drawing-in points, an access concept for roll changes, an operating mode for threading the web at reduced speed, an emergency stop concept across the drive groups. The aspect the textile standard does not cover, the thermal hazard from the welding station, was safeguarded separately via the risk assessment and the applicable type-B standards.
In the end the list of standards contained both: the type-C standard applied by analogy with a justification of comparability, and a list of the aspects solved differently. Precisely that pairing makes the derivation verifiable.
Which hazards are overlooked most often on these systems?
- Access to the grid surface during maintenance and fault clearance while neighbouring robots keep moving.
- Containers or goods falling from the stack during storage and retrieval.
- Crushing points at the ports, where operators and robotics meet.
- Run-down distances of the robots after a safeguard is triggered.
- Effects from the warehouse management system on the safe state, for instance on restart after a fault.
- Zone separation during partial operation: one area is maintained while the rest of the installation produces.
Sources and standards
- EN 528:2023-02: storage and retrieval machines, safety requirements
- EN 619: continuous handling equipment and systems, unit loads
- EN 15095: power-operated circulation storage and storage lifts
- EN ISO 3691-4:2023-12: industrial trucks, driverless industrial trucks
- EN 1010: printing and paper converting machinery, safety requirements
- EN ISO 11111: textile machinery, safety requirements
- 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
Does EN 528 apply to a cube-based storage system?
No. EN 528 (2023-02) applies to rail-guided storage and retrieval machines with a lifting device along a mast. A container robot does not have those kinematics. The standard is not applicable to that part.
What does it mean legally if no type-C standard fits?
It changes nothing about the essential health and safety requirements; those apply regardless of the standards situation. You merely lose the presumption of conformity of a harmonised type-C standard and have to derive and document compliance yourself via EN ISO 12100 and the type-B standards.
Do I then need a notified body?
Not automatically. What matters is whether the machine is listed in Annex I of the Machinery Regulation. For Annex I Part B, internal production control is only possible where harmonised standards are applied in full; if a matching type-C standard is missing, that can force the route via a notified body.
Does EN ISO 3691-4 apply to the container robots?
Only partly and only indirectly. The standard applies to driverless industrial trucks that move on the floor. For additional AGV or AMR in the same installation it is relevant; for the container robots in the storage grid it is not.
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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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