CE Marking of Machinery: Requirements, Procedure and Who Affixes It

It comes last, after the technical documentation, the conformity assessment procedure and the EU declaration of conformity.

Regulation (EU) 2023/1230 applies from 20 January 2027 and replaces Directive 2006/42/EC, which applies until 19 January 2027 through national law. The CE marking rules move from Article 16 and Annex III of the Directive to Articles 23 and 24 of the EU Machinery Regulation.

The sections below explain what the marking means, the six steps before it, who affixes it, where and how large, when the notified body number follows it, the 2027 change, products without it, certificates, costs and formal non-compliance. The table gives ten core rules with their legal basis.

What the CE Marking on Machinery Means

Article 3(25) of Regulation (EU) 2023/1230 defines the CE marking as "a marking by which the manufacturer indicates that machinery or a related product is in conformity with the applicable requirements set out in Union harmonisation legislation providing for its affixing".

The definition in the consolidated text of Regulation (EU) 2023/1230 on EUR-Lex makes the marking the manufacturer's own statement for machinery and related products, such as safety components and lifting accessories.

The marking comes last. Article 10(2) of Regulation (EU) 2023/1230 requires the manufacturer to draw up the Annex IV, Part A technical documentation and to carry out the Article 25 procedure before placing on the market; where conformity is demonstrated, the manufacturer draws up the EU declaration of conformity under Article 21 and only then affixes the CE marking under Article 24. That procedure is the subject of conformity assessment under the Machinery Regulation.

Article 23 and Regulation (EC) No 765/2008

Article 23 of Regulation (EU) 2023/1230 makes the CE marking subject to the general principles of Article 30 of Regulation (EC) No 765/2008, in force since 2 September 2008. The first of those principles, in Article 30(1) of Regulation (EC) No 765/2008 on EUR-Lex, reserves the affixing to the manufacturer or its authorised representative.

Two more rules reach machinery through Article 23. Annex II, point 3 of Regulation (EC) No 765/2008 sets a minimum height of 5 mm where the specific legislation imposes no dimensions, and Regulation (EU) 2023/1230 imposes none.

Article 30(6) of Regulation (EC) No 765/2008 requires Member States to provide penalties for infringements, which may include criminal sanctions for serious infringements.

How to CE Mark a Machine under the Machinery Regulation

CE marking a machine under Regulation (EU) 2023/1230 follows the order of Article 10(2): design to Annex III, technical documentation, the Article 25 procedure, the EU declaration of conformity, and only then the CE marking. The six steps are listed below in that order.

1. Classify the product and its route under Article 25: outside Annex I, module A; Annex I, Part A (6 categories), B+C, H or G; Annex I, Part B (19 points), module A only where harmonised standards or common specifications specific to that category cover all relevant requirements, otherwise B+C, H or G (see the machinery conformity route finder).
2. Design and build to Annex III after the five-step risk assessment, (a) to (e), of Annex III, Part B, point 1 (the essential health and safety requirements).
3. Draw up the technical documentation of Annex IV, Part A (the machinery technical file).
4. Carry out the procedure, with a notified body for its part where the module requires one (Article 25(1)).
5. Draw up and sign the EU declaration of conformity under Article 21 and the 10 particulars of Annex V, Part A (the EU declaration of conformity for machinery).
6. Affix the CE marking under Article 24, with the notified body number after module H or G,, and keep the documentation and declaration for at least 10 years (Article 10(3)).

Who Affixes the CE Marking to Machinery?

Only the manufacturer or its authorised representative may affix the CE marking to machinery (Article 30(1) of Regulation (EC) No 765/2008), and the manufacturer is whoever makes the machine and markets it under its own name or puts it into service for its own use (Article 3(18) of Regulation (EU) 2023/1230).

An authorised representative is established in the Union and acts on a written mandate for specified tasks (Article 3(19)). Under module A it may fulfil the Annex VI, point 4 obligations, the CE marking included, if the mandate specifies them (Annex VI, point 5).

Three other persons take on the manufacturer's role. An importer or distributor who places machinery on the market under its own name or trademark, or modifies it so that compliance may be affected, is a manufacturer (Article 17); so is whoever carries out a substantial modification (Article 18), who then applies the Article 25 procedure.

Importers and distributors check the marking but do not affix it: the importer ensures it is there before placing on the market (Article 13(2)), and the distributor verifies it (Article 15(2)(a)). The roles are compared below.

Where and How the CE Marking Is Affixed

Article 24(1) of Regulation (EU) 2023/1230 requires the CE marking to be affixed visibly, legibly and indelibly to the machinery or related product, and only where that is not possible or not warranted to the packaging and the accompanying documents.

The product itself is the default carrier, and packaging and documents are the exception. Under module A, the manufacturer affixes the marking to each product individually (Annex VI, point 4.1).

Minimum Size of the CE Marking: 5 mm

The CE marking on machinery is at least 5 mm high, a minimum that comes from Annex II, point 3 of Regulation (EC) No 765/2008 through Article 23 of Regulation (EU) 2023/1230, because the Machinery Regulation sets no size of its own.

Annex III of Directive 2006/42/EC also required at least 5 mm, but allowed the minimum to be waived for small-scale machinery and required the marking in the immediate vicinity of the manufacturer's or authorised representative's name, using the same technique.

The Commission's Blue Guide 2022 on EUR-Lex (point 4.5.1.4) allows a waiver only where the legislation provides for it. Regulation (EU) 2023/1230 provides for no waiver.

When the Notified Body Number Follows the CE Marking

The notified body's identification number follows the CE marking when the machine went through full quality assurance (module H, Annex IX, point 5.1 of Regulation (EU) 2023/1230) or unit verification (module G, Annex X, points 4 and 5.1). The two cases are listed below.

• Full quality assurance (module H): the CE marking and the notified body's identification number appear on each product (Annex IX, point 5.1).
• Unit verification (module G): the notified body affixes, or has affixed, its identification number with the CE marking (Annex X, points 4 and 5.1).

Annex III of Directive 2006/42/EC required the number only where the full quality assurance procedure of Article 12(3)(c) or 12(4)(b) of the Directive had been applied. Module G is new in the Regulation.

CE Marking Before and After 20 January 2027

Machinery placed on the market or put into service until 19 January 2027 is CE marked under Article 16 and Annex III of Directive 2006/42/EC, and from 20 January 2027 under Articles 23 and 24 of Regulation (EU) 2023/1230; there is no parallel period in which the manufacturer may choose.

According to the Commission, machinery placed on the market before that date must comply with the Directive, and its declaration may also state conformity with the Regulation. Seven points are compared below.

Full correspondence: Machinery Regulation vs Machinery Directive.

Machinery placed on the market under the Directive before 20 January 2027 may continue to be made available (Article 52(1) of Regulation (EU) 2023/1230).

EC type-examination certificates and approval decisions issued under Article 12 of the Directive 2006/42/EC text on EUR-Lex "shall remain valid until they expire" (Article 52(2)). Every date of the change is set out in the Machinery Regulation timeline.

On the marking itself, the 5 mm minimum now comes from Regulation (EC) No 765/2008, the small-machinery waiver is gone, and the notified body number also follows module G.

Which Products Never Carry the CE Marking?

Partly completed machinery never carries the CE marking under Regulation (EU) 2023/1230; it is supplied with an EU declaration of incorporation and assembly instructions, and the CE marking goes on the final machine into which it is incorporated. No Article 25 procedure applies to it (Articles 11, 22 and 24).

Products authorised under the emergency procedure of Article 25c "shall not bear the CE marking" (Article 25c(7)).

Chapter IVa, inserted by Regulation (EU) 2024/2748, has applied since 29 May 2026 and operates only after a Commission implementing act under Article 28 of Regulation (EU) 2024/2747 and an activated internal market emergency mode. The rules for the first group are explained under partly completed machinery.

CE Certificates for Machinery: Who Issues Them?

No authority issues a "CE certificate" for machinery: under module A the manufacturer itself declares conformity without any certificate, and under modules B+C, H and G a notified body issues the certificate or approval for the area it is notified for.

The European Commission's machinery page states that voluntary certificates have no value in market surveillance or customs checks and must not bear a CE marking. The four modules and their documents are listed below.

• Internal production control for machinery (module A, Annex VI): no certificate; the manufacturer draws up the EU declaration of conformity.
• EU type-examination for machinery (module B, Annex VII): an EU type-examination certificate valid for at most five years (point 6.1), renewal requested 12 to 6 months before expiry (point 7.4).
• Full quality assurance (module H, Annex IX): a decision approving the quality system, with no fixed validity but periodic audits (point 4.3).
• Unit verification (module G, Annex X): a certificate of conformity for the examined unit (point 4).

The declaration names the notified body, its number and its certificate (Annex V, Part A, point 8). As of 12 November 2026, NANDO lists 36 active notifications under Regulation (EU) 2023/1230; see notified bodies for machinery.

How Much CE Marking of Machinery Costs

The cost of CE marking a machine depends first on its conformity route: module A needs no notified body, while modules B+C, H and G add a notified body's examination, audit or unit test to the manufacturer's own work. The five legal factors that shape a quote are listed below.

• Annex I status: not listed, Part A or Part B (Article 25(2) to (4)).
• Notified body module: type examination (B), quality-system audits (H) or unit examination (G).
• Union acts: one declaration names every act requiring one (Article 21(3)).
• Translations: into the languages each Member State requires (Article 21(2)).
• Certificate renewal: at most every five years, by a simplified review without tests where neither type nor state of the art changed (Annex VII, point 7.6).

Notified bodies take the interests and needs of SMEs into account when setting fees (Article 25(5)); recital 27 puts SMEs at about 98 % of machinery companies. Their activities are proportionate to size, sector, structure, complexity and serial nature (Article 38(2)).

The Commission's impact assessment SWD(2021) 82 of 21 April 2021 records, as industry estimates, a Directive route split of about 80 % self-assessment outside Annex IV, 10 % self-assessment for Annex IV machinery, 8 % EC type-examination and 2 % full quality assurance.

It estimated the cost of removing internal checks for Annex IV machinery at EUR 2,467 per company, up to EUR 25,000 or more depending on the machinery type; the dated record sits under Machinery Regulation compliance.

Missing or Wrong CE Marking: Formal Non-Compliance and Penalties

A missing or wrongly affixed CE marking is one of the seven grounds of formal non-compliance listed in Article 46(1) of Regulation (EU) 2023/1230.

The seven grounds are: (a) the CE marking affixed in violation of Article 30 of Regulation (EC) No 765/2008 or Article 24; (b) no CE marking; (c) the notified body number wrongly affixed or missing; (d) the EU declaration of conformity missing or incorrect; (e) the technical documentation unavailable or incomplete; (f) the Article 10(6) or 13(3) contact information absent, false or incomplete; and (g) any other administrative requirement of Article 10 or 13 not fulfilled.

Article 46 replaces Article 17 of Directive 2006/42/EC. Member States provide the penalties, which may include criminal sanctions for serious infringements (Article 30(6) of Regulation (EC) No 765/2008); the Regulation sets no EU fine amount.

Article 50(1) of Regulation (EU) 2023/1230 has applied since 20 October 2026, the date by which Member States had to notify their penalty rules. Authorities and procedures are explained under market surveillance of machinery and national penalties.

CE Marking After Import, Resale or Modification

A machine keeps its CE marking through import and resale, but a person who markets it under its own name, modifies it substantially or imports it for first placing on the Union market takes on duties of its own. The four cases are listed below.

• Imports from third countries: new or second-hand machinery is covered when it is first placed on the Union market (recital 10), see used machinery and CE marking.
• Importers: the CE marking and the documents are checked before placing on the market (Article 13(2)), see importer checks before placing on the market.
• Distributors: the CE marking is verified (Article 15(2)(a)), see distributor obligations for machinery.
• Modifiers: whoever substantially modifies a machine becomes its manufacturer (Article 18), see machinery after a substantial modification.

CE Marking of Machinery Questions

Four questions recur about the CE marking of machinery: whether it is a safety approval, trade fairs, machines built for own use and other EU acts.

Is the CE marking a safety approval of the machine?

No: the CE marking is the manufacturer's own statement of conformity (Article 3(25) of Regulation (EU) 2023/1230). The Health and Safety Executive's buyers' guide INDG271 calls it only a claim by the manufacturer that does not in itself guarantee safety.

Can machinery be shown at a trade fair without CE marking?

Yes: Article 4(2) of Regulation (EU) 2023/1230 allows non-compliant machinery at trade fairs, exhibitions and demonstrations if a visible sign shows that it does not comply and will not be made available until it is brought into conformity. Display is allowed; making available is not.

Does a machine built for own use need a CE marking?

Yes: whoever builds machinery and puts it into service for its own use is its manufacturer (Article 3(18)(b) of Regulation (EU) 2023/1230), and the CE marking is affixed before putting into service, meaning its first use for its intended purpose in the Union (Articles 24(2) and 3(13)). No sale is needed.

Does the CE marking of a machine cover other EU acts?

Yes: the CE marking indicates conformity with all Union harmonisation legislation providing for its affixing (Article 3(25)), and one EU declaration of conformity covers all acts that require one (Article 21(3)). Which acts apply together with the Machinery Regulation depends on the machine; see EU product laws that apply together with the Machinery Regulation.