CE marking for a special-purpose machine — what to require from the builder

You order a special-purpose machine and hear the assurance: "of course, it will come with CE". The problem is that CE marking for a special-purpose machine is not a sticker applied at the end, but the outcome of a process that starts at the design stage: risk assessment, technical documentation, the manual, the declaration of conformity. If the builder treats the topic as a slogan, you will find out at acceptance at the earliest — and most painfully during an inspection or after an accident.

This article explains what really makes up the conformity of a new machine, how things stand when an existing machine is modernised, and what exactly to ask the builder before signing the contract. No legal paragraphs — at the level that is enough for a buyer and a maintenance manager to protect the company's interests.

The legal framework in brief: who is the manufacturer and what are they responsible for

Every new machine placed on the market or put into service in the EU must meet the essential safety requirements. Today the framework is set by the Machinery Directive, which in January 2027 will be replaced by the EU Machinery Regulation — the obligations remain essentially the same: the manufacturer designs a safe machine, documents it and declares conformity on their own responsibility.

The key word is manufacturer. For a special-purpose machine the manufacturer is its builder — they carry out the conformity assessment and affix the CE marking. For the vast majority of machines there is no mandatory involvement of a certification body; CE is the manufacturer's declaration, not a certificate issued by an authority. Two practical consequences follow from this. First, the credibility of the CE marking depends directly on the builder's diligence. Second, if you buy a machine without the complete documents, or substantially rebuild it yourself, the manufacturer's obligations can pass to you.

Watch out for assemblies of machinery: if several devices are linked by a common control system and a common safety system into one line, such an assembly is treated as a single machine — it needs its own conformity assessment and a declaration for the whole. Someone then has to take on the role of the integrator responsible for the conformity of the assembly, and it is worth settling this in the contract before devices from three different suppliers meet on your shop floor.

CE marking of a special-purpose machine — what conformity consists of

Five elements to require from every builder of a new machine:

• Risk assessment — a systematic analysis of hazards across the machine's whole life cycle: normal operation, changeover, cleaning, fault clearing, servicing. From it follow the guards, light curtains, interlocks and operating modes. Carried out in parallel with the design, not after it.
• Technical documentation — drawings, electrical and pneumatic diagrams, calculations, the selection of safety components, the results of the risk assessment. The manufacturer is obliged to compile it and keep it for years in case of an inspection.
• Operating manual in the language of the country of use — for a machine operated in Poland, in Polish — covering intended use, but also changeover, maintenance and foreseeable misuse. A manual only in English or German does not meet the requirements for a machine used in Poland.
• EC/EU declaration of conformity — the document in which the manufacturer identifies the machine, the regulations and standards it was built to, and takes responsibility for it with a signature.
• Nameplate with CE marking — the manufacturer's details, the machine designation, the year of construction and the CE mark permanently affixed to the machine.

In practice the manufacturer bases the design on harmonised standards — applying them gives a presumption of conformity with the essential requirements. The client does not need to know the standard numbers; it is enough that the builder can point out which ones they design the guards, the safety-related controls and the protective distances to.

If any of these elements is missing, a "machine with CE" is one in name only. All five points are worth writing into the contract as a condition of acceptance — just like the performance criteria we cover in the article on the specification for a special-purpose machine.

Table: the document, what it is for, when to require it

Modernising an existing machine: when it becomes a "new machine"

The second common scenario is not building but rebuilding: adding a robot to an old press, new controls, increasing line speed. The general rule is: as long as the change does not create a new hazard and does not increase existing risk beyond the level covered by the current protective measures, we are talking about repair or replacement — no new conformity assessment. But when the change is substantial — the machine gets new functions, higher parameters, a different way of operating or a modified safety system — the party carrying out the rebuild becomes the manufacturer of the modernised machine with all the obligations: risk assessment, documentation and a new declaration.

The borderline can be a judgement call, so the decision should be preceded by a documented analysis — ideally done together with the company carrying out the modernisation. Keep the document of this analysis together with the machine's documentation: during audits and inspections it saves long discussions about whether the change was substantial. It also has a practical dimension in automation projects: integrating a robot with an existing machine almost always requires rethinking the safety of the whole station, and often its formal assessment as well. Whether to modernise at all or build new is a separate decision, which the article special-purpose machine or off-the-shelf workstation helps to structure.

Questions to ask the builder before signing the contract

Instead of a general "will the machine have CE", ask questions that verify the process:

1. Who will formally be the manufacturer of the machine and issue the declaration of conformity?
2. When and how will the risk assessment be produced — and will the client get access to it?
3. Which harmonised standards does the builder take as the basis for the safety design?
4. What exactly is included in the documentation handed over: diagrams, programs, parts lists?
5. Will the manual be in Polish and cover service modes and fault clearing?
6. How does the builder handle integration with existing machines — who is responsible for the conformity of the whole assembly?
7. What happens when the client wants to modify the machine in the future — what support and what documentation make that possible?

These questions are worth asking already when comparing offers. If one quote is clearly lower than the rest, the reason often turns out to be exactly this: documentation and safety treated as an afterthought — an apparent saving that you pay for later during an inspection, when integrating further equipment, or when reselling the machine.

A builder who answers these questions concretely usually has the conformity process built into their engineering. At Nomatec we design special-purpose machines exactly in this mode: safety and the required documentation are created together with the design, not as a separate stage after commissioning.

Summary

The CE mark on a special-purpose machine is shorthand for a whole package: risk assessment, technical documentation, a manual in the user's language, the declaration of conformity and the nameplate. The manufacturer — the machine's builder — is responsible for it, and the client's role is to write the complete package into the contract and enforce it at acceptance. With modernisation, the key question is whether the change is substantial; if it is, the manufacturer's obligations return in full.

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