CE marking on a machine is the manufacturer's declaration that it meets every EU law that applies to it, mainly the machinery safety rules. The manufacturer is legally responsible for it, even when the factory is in India.
But responsibility does not stop at the factory gate. If you import the machine into the EU, or sell it under your own name, you take on legal duties as well.
What the manufacturer must do
- Design and build the machine to meet the essential health and safety requirements.
- Carry out and document a risk assessment.
- Apply the correct conformity assessment procedure, which for some high-risk machinery involves a notified body.
- Compile a technical file and keep it available for the national authorities.
- Supply instructions and sign an EU declaration of conformity.
- Affix the CE marking to the machine.
Your duties as importer or brand owner
If you place a machine on the EU market under your own name or trademark, the law treats you as the manufacturer. You then carry the manufacturer's full responsibility, including the technical file.
As an importer, you must check that the manufacturer has done its part before you place the machine on the market. That means the conformity assessment, the technical documentation, the CE marking and the instructions. The EU Machinery Regulation, which replaces the current Directive, sets out importer duties in more detail.
Other EU laws may apply at the same time. Electromagnetic compatibility rules apply to most machines with electronics, and some machines fall under pressure equipment or other rules. See the Low Voltage and EMC Directives.
What to check with an Indian maker
A CE sticker on a quotation proves nothing. Ask for the declaration of conformity, the list of standards applied and the risk assessment. Ask whether a notified body was involved and, if so, for its certificate number, then check it on the EU's NANDO database.
Some Indian makers build to EU requirements regularly and hold complete files. Others have never prepared a technical file. Find out which before you order, because fixing guarding, wiring or documentation after build is slow.
Check the plate and the instructions too. The CE marking, the manufacturer's name and address, the model, serial number and year of construction should appear on the machine. The instructions must be in an official language of the EU country where the machine is used.
This is a legal area. Confirm your obligations with a notified body, a CE consultant or your national market surveillance authority before you sell.
Next step
We check CE documents against the machine during inspection and flag gaps before shipment. To review a machine you plan to import, book a free sourcing review.