CERTIFICATION & COMPLIANCE GUIDE

When machinery CE marking is required: scope and exclusions

Assess function, supply status, intended use and EU market context before treating machinery CE as universally mandatory.

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01

Decide whether the machinery rules apply

For EU supply, examine the definition of machinery, intended application, moving assembly, drive source and any specific exclusions. Products such as lifting accessories and certain manually powered lifting machinery also fall within the Directive’s scope. Electric power alone is not the scope test.

Complete machinery within scope must satisfy the relevant requirements and assessment procedure before placement or first use. CE marking follows that conformity work; it is not a substitute for it. Check other applicable product legislation without assuming that one electrical report covers every requirement.

02

Distinguish partly completed supply and own use

A hypothetical manually powered hoist is built for the manufacturer’s own lifting operations. Direct human power and absence of a sale do not by themselves remove it from machinery obligations. Examine the lifting function and own-use manufacturer responsibilities before claiming exemption.

Partly completed machinery follows technical-documentation, assembly-instruction and incorporation-declaration obligations. Its status does not simply mean “nothing is required”, and those outputs are not the final machine’s conformity declaration. Check other applicable legislation separately.

03

Address exclusions and actual market requirements

For excluded products, identify the actual exclusion and the alternative relevant legal framework, rather than issuing a machinery certificate by default. A component and the assembled machine can have different scope decisions. This guide concerns EU rules; another destination needs its own assessment.

Kayra can support an agreed product-scope review using function, drawings, installation and destination details. The manufacturer remains responsible for the actual supply. Regulation 2023/1230 generally applies from 20 January 2027; its scope must be reviewed at the relevant placement date.

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For “When machinery CE marking is required: scope and exclusions”, share the machine function, current model and design revision, intended use, planned EU placement date and available risk or test records. Agreed product preparation work does not replace the manufacturer’s declaration or a legally required notified-body procedure.

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