znak ce turb

Assume, we are a contractor for the modernization of steam turbines. Modernizations often cover the range of about 10-30% of the turbine set. Should we give the CE marking to the entire tub? Can the CE marking be given by the owner or power plant?


A modernized machine in the light of the CE marking should be treated as new if the scope of the modernization significantly influences the change in the conditions of safety of use. Therefore, if it is a modernization of mechanical assemblies that improves the machine's efficiency, life or reliability, it does not require CE marking (it should be remembered here about Directive 2009/104 / EC). However, if the scope of modernization are control and protection elements, they have a significant impact on safety and the machine-turbine set should be marked with the CE mark.

ldtn1 oxygen distributor pressureMachine – Airfield Oxygen Distributor was designed and manufactured by our Customer – Central Military Bureau of Design and Technology – WCBKT S.A.

The device is intended for oxygen supply to internal systems of military and civil aircrafts. The machine is equipped with vessels for purchasing oxygen from external oxygen generator and possesses compressor for supplying the oxygen to aircraft. It has also electric power generator for independent supply of compressor. For ease of movement on airport it have been built on twin axis trailer with overrun brake.


One of such machines is used to service fighters at the military airport in Malbork

spawarka ruukki


On request of Ruukki Polska, the Internet Design Office has developed an assessment of hazards resulting from the machine's operation and an analysis of the machine's compliance with the requirements of EC directives. The machine directive applies to this machine? 2006/42 / EC, low voltage? 2006/95 / EC and electromagnetic compatibility? 2004/108 / EC.

Here you can find interesting cases of CE marking, other marking, certification, and technical quality issues of machines from China and other countries.

The CE vs China Export mark

The obligation to comply with the directives and the CE marking of machinery has become a major obstacle for imports from China. The production of safe machines and the obligation to develop construction documentation and hazard analysis has become a significant manufacturing cost for many smaller plants. Resourceful managers from the east quickly found a way to create their own official mark - CHINA EXPORT confusingly similar to the EU CE mark. The only difference is that CHINA EXPORT has the letters CE placed in a smaller distance and often, the middle beam of the letter E is equalized with the extreme ones.

The correct pattern of the CE mark is characterized by the fact that the internal circle of the letter C is tangent to the outer circle of the letter E, in addition, the central beam of the letter E is clearly shorter than the extreme as shown in the picture. The sign can be downloaded from the website


znak ce mmznakce


Pro-ecological projects takes more and more place of our activities. Our subsequent project was CE marking of used batteries recycling technology line. The line called KRAB come from Russian company ИРИСМАШ (IRISMASZ http://www.nppiris.vrn.ru/). Russian manufacturers are not obliged to CE mark their machines designated to local market and importer willing to bring the machine to European Union county is obliged to CE mark the machine. Our company performed analysis of compliance of the recycling line acc. to EU Directives. Manufacturer's technical documentation have been revised and completed and appropriate safety marking of the machine attached. All constructional, technical inconsistencies have been specified and removed by our team.




This time, a project of food industry machine. For one of our clients, we have developed the construction documentation, strength analysis and documentation of CE marking of the hoist for loading meat into the milling machine.

The lift is designed for lifting and inverting standardized bins. Drive of lifting mechanisms is realized by a three-phase electric gear drive.

Due to the purpose for the food industry and contact with food, the machine must meet the requirements of standard 1935/2004 - Materials and articles intended for contact with food, and therefore the body of the whole machine has been made of acid-resistant steel. In addition, due to the necessity of frequent cleaning of the whole machine with the use of a pressure washer and disinfectants, machine control devices must meet increased tightness requirements (IP65 degree of protection) and resistance to corrosion. Electrical cupboard have been made of stainless steel.

For safety reasons, the machine was enclosed with a steel mesh cage and the control system allows lifting and lowering only when the access gate is closed.

"a component or equipment not attached to the lifting machinery, allowing the load to be held, which is placed between the machinery and the load or on the load itself, or which is intended to constitute an integral part of the load and which is independently placed on the market; slings and their components are also regarded as lifting accessories"

zaw linowe1

Textile slings and their components

Assembly of one or more sewn webbing components for attaching loads to the hook of a crane or other lifting machine

EN 1492 parts 1, 2 & 4

zaw linowe1
zaw linowe2

Steel wire rope slings and their components

Assembly of one or more steel wire rope legs or an endless sling for attaching loads to the hook of a crane or other lifting machine

EN 13414 parts 1, 2 & 3

zawiesie lancuch

Chain slings and their components

Assembly of one or more chains for attaching loads to the hook of a crane or other lifting machine

EN 818  parts 1 to 8 

ucho nakr
ucho przykr
ucho wkr

Lifting eyelets

Eyelets intended to be placed on the load by threading for lifting it

(when independently placed on the market)

ucho1 spaw
ucho2 spaw
ucho3 spaw

Lifting eyelets

Eyelets intended to be placed on the load by welding for lifting it

(when independently placed on the market)

blacha spaw

Lifting ear

Steel plate with a hole intended to be welded to a load for lifting it

(when independently placed on the market)


Lifting anchor

A device intended to be integrated into a structure (e.g. a concrete units, concrete panel) in order to provide an anchorage for lifting the structure

Rope eyelet


Corner fitting

Corner fittings intended to be integrated in ISO containers by welding for lifting them

(when independently placed on the market)

C hak1
C hak2


Equipment in the form of a ‘C’ used for lifting hollow loads e.g. coils, pipes etc.

EN 13155

(Such equipment is considered as a lifting accessory when it is not permanently attached or fixed to the lifting machinery, in other words, when the machinery can be used to lift loads without the equipment or with other lifting accessories)



Equipment used to handle loads by clamping on a specific part of the load – also known as tongs

EN 13155



Container spreader beams

Container spreader beams placed between lifting machinery and the load in

order to attach it * *

reference: 98/37/EC Committee Doc. 2003.13rev.1


Lifting forks

Equipment consisting of two or more arms fixed to an upright with an upper arm, essentially to lift palletised or similar loads* *

standard: EN 13155

plate clamp
plate clamp2

Plate clamps

Non powered equipment used to handle steel plates by clamping them between jaws * *

standard: EN 13155

lifting magnet

Lifting magnet

Equipment with a magnetic field creating sufficient force for gripping, holding and handling loads  with ferromagnetic properties* *

standard: EN 13155



Forks attached to a lift truck

Forks attached to a masted or variable reach industrial truck for holding the load.


Such forks are part of the machinery subject to Directive 2006/42/EC



fork platform CEQuestion 1. Is it allowed to put into service a machine for lifting goods (forklift or HDS crane), after assembly work platform (basket) for lifting persons ? The platform is CE marked by its manufacturer.

Re. At first we have to enphasis that non-integrated working platforms are not covered by Machinery Directive and may not be CE marked. (CE marking in unlegal in this case). Regarding the forklift truck, it may be allowed to work with work platform, provided that the manufacturer instruction allowes assembly of work platform whitch meets the conditions specified by the manufacturer of the machine.

On the other hand, generally forklifts or cranes are not designed to lift persons (do not meet safety conditions) so installing working platform we create a new machine whitch is subject to the requirements of the Machinery Directive (and others). Not be assumed that it complies the requirements so you need to conduct a conformity analysis, hazard assessment and adapt the design to the essential requirements. Before being allowed to work the new machine should be marked with the CE mark.

The same applies to the front loader forklift.

However, in the UK there are Health and Safety Executive regulations (PM28) allowing to use non-integrated working platform on forklift trucks.
Off course it is allowed by MD as well.


jack1Question 2. Hello, I am manufacturer of pneumatic workshop jack called - snowman, should it be CE marked?

A pneumatic jack - snowman. Yes. This jack is a machine (for vehicle service) is subject to the requirements of the Machinery Directive should therefore bear the CE marking. There is also a standard EN 1494 - Mobile or movable jacks and associated lifting equipment, harmonized with the Directive. The participation of a notified body in the conformity assessment is not a must and depends on assessment procedure chosen. 


motreducQ. 3. Does the gearbox assembly with electric motor need to be CE marked?

Re. It should not. The gear motor alone can not perform a specific function so it is not a machine. But it is a drive system considered as a partly completed machinery and the declaration of incorporation of partly completed machinery should be issued (excluding CE marking). Usually we meet this drive sets with the CE mark label placed on the electric motor but that's because the motor bears the CE mark meaning conformity with the Low Voltage Directive placed by the motor manufacturer (not by the Manufacturer of the gearbox and motor kit) 


Question 4. Is the column type lift for lifting cars a subject of the Machinery Directive and should bear the CE marking?

Re. Yes. The lift is a machine (for vehicle service). It is a subject to the requirements of the Machinery Directive - MD (usually also LVD and EMC) and should therefore bear the CE marking. There is also harmonized standard EN 1493 - Vehicle lifts, that specifies requirements of such machines.

Moreover, such a machine is one of (causing significant hazard) specified in Annex IV of the Directive so choosing the conformity assessment procedure, you can choose full compliance with the standard EN 1493 without the involvement of a notified body or one of the procedures involving the notified body at which full compliance with the standards is not mandatory.

Question 5. Hi, I have a mobile crane on the chassis of the commercial vechicle and would like to expand it with the function of aerial platform. Is such a machine allowed to be put into operation if I mention the mobile crane is CE-marked and the work plaform attached is also CE marked ?

Re. It depends on machine user manual. Typical mobile crane is intended for lifting goods (as purpose of a crane) and is not allowed to lift people. When installing the basket it becomes a different new machine for which safety requirements are significantly different than those referred for cranes. Thus we've got a machine that needs to be examined in the entire process of compliance and CE marking. Only then the machine may be allowed to lift people.

In this example filal machine contains non-CE marked work platform and final machine have been CE marked by manufacturer.

In case that user manual allowes for interchangeble attachments like work platforms it is allowed then to fix it. For exampleŁ
http://manuals.gogenielift.com/parts%20and%20service%20manuals/data/Parts/Telehandlers/645031.pdf is intended to be attached by a final user and it is CE marked as interchangable equipment. However you should ask national market surveilance authorities as lifting of peaople by machines intended for lifting goods may be treated different in EU member states.

Q. 6. Is the use of harmonized standards for the design mandatory?

Re. It is not mandatory. Manufacturer may decide to use the standard or not. Bear in mind that the use of standards can facilitate the process of CE marking. For example,while meeting the 100% of requirements of the standard, we can label the car jack (EN 1494) without the involvment of a notified body but if you decide not to comply the standards then you must engage notified body in the process of CE marking.

Question 7. Hi, I produce wood sawing machine. Sawing machinery are listed in Annex IV of the Machinery Directive 2006/42/EC. Is it mandatory to involve notified body in the conformity assessment process ?

Re. It is not mandatory. It depends on conformity assessment procedure chosen by manufacturer. If your design and fabrication process complies type C standards (specific for this type of machine) and the machine is in full compliance with these standards then you can even follow essessment procedure that do not require involvment of notified body (self assessment and production controll) .

Question 8. Is a machine produced for own use required to be CE marked ?

Re. Yes, it requires a result of this provision :. "Manufacturer" means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for conformity of machinery or partly completed machinery with this Directive, with a view to its being placed on the market under his own name or trademark or for his own use.

Question 9. Are grapples and buckets for excavators subject to EC Directives and should they be CE marked ?

Re. Further analysis of features of the device should be made to answer this question. We can distinguish several types of grippers

a) buckets and grapples with hydraulic or electric drive (scrap grapples, grippers for handling sheet metal, wood grippers, clamshells with hydraulic drive - the so-called. crocodiles) are subject to the Machinery Directive 2006/42/EC and must bear the CE marking. These grippers are interchangeable equipment mounted by the operator changing the function of the machine.

b) simple buckets for excavators not having drives - are not subject to the Machinery Directive 2006/42/EC

In the examples of our designs, you can find several types of grippers.

Question 10. Is a machine built on vehicle or on trailer subject to CE marking ?

Re. Yes, it is and should be CE marked. Constructions on vehicles and on trailers (eg. Hoists, cranes, sawing machines, concrete pumps, ... etc) are subject to the Machinery Directive 2006/42/EC, but the trailer or the vehicle itself does not fall under the Machinery Directive (provided that it is a vechicle covered by type-approval and allowed to be driven on public roads).

Q. 11. Should any product placed on the market have a CE marking ? Is it acceptable to label any product to customer's request or for marketing purposes?

Re. No, you can (even have to) affix the CE mark only the products that are subject to EC Directives and the Directive requires CE marking for the product concerned. It is not allowed to CE mark product not covered by any directive or none of directives it is covered by requires CE marking. There are various products that are subject to the requirements of the EC directives but do not have to (can't) be CE labeled.

Question 12. Is the aerial platform covered by noise Directive 2000/14/EC?

Re. Yes, the aerial platform is specified in the Noise Directive (Art.13) as "working platform" and is subject to noise level marking only that means, noise limits don't apply.

Question 13. What do I do if my product does not fall under any Directive and the client requests a declaration

Re. The product that is not a subject to any directive must not bear the CE marking. What's more, if the product is subject to the Directive and the Directive does not require CE marking for THIS product or do not require CE marking at all it is also not allowed to be labeled with the CE marking.
In such cases, we recoment the manufacturer's to issue a statement in which he describes the explanation of the law. Such a statement should satisfy the purchaser.

Question 14. Is a steam turbine a machine, and should it bear the CE marking?

Re. Yes. The turbine meets the definition of the machine according to the Machinery Directive 2006/42/EC (it has moving parts, is used to drive a generator) so it should bear the CE marking. If a company provides a new turbine then a matter of  CE marking is quite simple because the full technical documentation is available and complience can be analyzed. The situation is worse in the case of turbine repairs that usually comes with a greater or lesser modernization. If modernization has a significant influence on the safety then modernized machine should be treated as a new machine.

Also, the steam turbine is not listed in Annex IV of the Directive therefore notified body is not required to be engaged in the process of CE marking.

Question 15. Does a simple grain storage silo have to bear the CE mark? Silos has no power supply or any trays or mechanical loads.

Re. Described as above silo is not a machine within the meaning of Directive MD 2006/42 / EC. This is also not a low-voltage device that could be subject to the LVD Directive 2006/95/EC (no power supply). If you do not find any relevant EC directives for the silo then it is not subject to the CE marking.

Question 16. Should a hydraulic piston be marked with CE mark ?

Re. No, a hydraulic piston (as well as any pneumatic) has been recognized as a spare part of a machine and hence due to Machinery Directive 2006/42/EC is not an object of CE marking.

Q. 17. Should an electric actuator be marked with CE mark ?

Re. That depends on its type. Electric actuator is not a machine according to a definition of Machinery Directive hence it is not expected to be CE marked due to MD 2006/42/EC. Depending on voltage it is driven by it may be subject of Low Voltage Directive 2014/35/WE (previously 2006/95/WE). If voltage range is 50÷1000 V AC or 75÷1500V DC then it should be CE marked. It is also dealt with by EMC Directive 2014/30/WE (previously 2004/108/WE) and should be CE marked regarding this directive.

smoke cabin


Question 18. We manufacture smokers' cabins. Is the cabin required to be CE marked ?

Re. The cabin is normaly issued with a fan. Regarding to that it should be considered as machine and hence it is required to be CE marked. 



CE bolt

 Question 19. Are bolts and nuts required to be CE marked ?

Re. General use bolts and nuts used for machinary are not covered by any directive and hence can't be CE marked. Besides, there are special non-preloaded (EN 15048) and preloaded (EN 14399) structural bolting assemblies that are a subject of Construction Products Regulation 305/2011 and have to be CE marked. (and SB - Structural Bolt marked)


agregatQuestion 20. Hi, we are providing portable, engine driven power generating sets.  Should they be CE marked ? Which European Directives should be considered ?

Re. Yes, power generating sets ( finished machines ) should be CE marked as they are a subject of Machinery Directive 2006/42/EC as well as Low Voltage Directive 2014/35/EU, EMC - 2014/35/EC, and Noise Directive 2005/88/EC 

The relevant EU standard is EN 12601 - Reciprocating internal combustion engine driven generating sets.

Besides, non-finished power generating sets ( intended to be build in another instalation ) should not be declared as complying all Machinery Directive but should be considered as non-finished machine. They should be still CE marked due to LVD and EMC.

Question 21. We manufacture a pneumatic suspension systems built of rubber cushions. Our customers require certifikate. Should our systems be CE marked ?

Re. There is no Directive requiring CE marking for such products hence it is not allowed to put CE mark on it. You can issue other "manufacturer's certificate / declaration" but CE marking is not allowed. 

jack1Question 22. We supply pneumatic jacks for cars and other purposes. Are such type of jacks a subject of Pressure Equipment Directive (PED) 2014/68/EU (formerly 97/23/EC)  ?

Odp. No. Pneumatic cushions are exluded from PED directive.


Q. 23. There are plenty of almost identical pneumatic jacks on the market. How can I choose the right one (the safe one, properly CE marked)  ?

Re. The first thing that should be checked is manufacturers Declaration of Conformity. Any third party Certificate is not sufficient. Declaration of Conformity should be issued and signed by a manufacturer or his authorized representative in EU. Apart of that User manual should be supplied. We have noticed a common technical bug in many of cheep jacks - the air is supplied and released by a hand operated ball valve. This conctruction does not comply safety rules (EN 1494) as the valve should be self-closing if released in any position.

platformaQuestion 25. We are producing platforms for lifting of machinery. Are the platforms considered as lifting accessory and should they be CE marked ?

Re. No, shuch platforms are not considered as lifting accessory and not covered by machinery directive 2006/42/EC. Should not be CE marked (as well as bulk containers, marine ISO-containers). 
Lifting accessories can be found here: http://inbiuro.com/en/ce-marking/lifting-equipment.html 



podnosnik3aQuestion 26. Should manualy operated jacks (intended for vechicles liffing) be marked with CE mark ? ( e.g. screw jack or hydraulic jack)

Re. Yes, manualy operated jacks are jubject of machinery directive 2006/42/EC and should be CE marked. Be aware that it is not covered by Annex IV as it is not intended for lifting entire vehicle.


Q. 27. Is a hydraulic valve block a subject to CE marking ?

Re. In general, manually controlled hydraulic valves/blocks are a part of machine and they are not to be CE marked. But very often they have features that make them a subject of CE marking under other directives; i.e. solenoid controlled valves/blocks are a subject of CE mark due to LVD, block containing pressure safety valve are a subject to CE mark due to PED 2014/68/EU formerly 97/23/EC (Pressure Equipment Directive).

Q. 28. My company bought a machine that has not been CE marked by its manufacturer. Can we CE mark it ?

Re. CE mark means declaration of the machine producer that it complies relevant directives requirements and may be placed by producer (or entitled representative). You (your company) can CE mark the machine if you can declare with full responsibility that the machine complies requirements and then this machine becomes your product with your name on a nameplate.

Q. 29. Should LVD Directive be refered to in Declaration of Conformity of machine that is electrically driven ? In many cases Low Voltage Directive is ommitted.

Re. If the mashine is supplied at voltage range covered by Low Voltage Directive, LVD (50V ÷ 1000V AC and 75V ÷ 1500V DC) then the machine is a subject to the directive requirements but listing of LVD may be ommitted in declaration. That is written in point 1.5.1. of Annex I of MD 2006/42/EC.

hydraulic press CE


Q. 30. I've purchased used hydraulic press that have been CE marked by its manufacturer. Now I need to modify it for different production purposes. Does it need to be CE marked again ?

Re. You would not need to CE mark it again provided that your modification (tooling modification) is minor and doesn't exceed purposes covered by user manual. If your modification is not covered by the machine intended use then you definatelly have to CE mark the machine again. That doesn't mean your analysis need to cover all subjects done by its original manufacturer. It is sufficient if your analysis covers all aspects/riscs related with your modification.

Q. 31. My product is a tripod support for electric lamp (lamp excluded). The tripod has a small manual winch installed on it for changing its height (lifting and lowering a lamp). Is this a subject to machinery directive or other directives and should that be CE marked ?

Re. That product is not considered as a machine. Regardless of a function of changin its height it is not a lifting function as well and should not be CE marked acc to MD. Regarding LVD it is still not an electrical equipment and hense should not be CE marked due to any directive.

Q. 32. I am producer of automatic welding machine that uses gases stored in high pressure bottles. The bottles are installed of machine. Is my machine a subject of pressure equipment directive ? Besides, the bottles got declaration of conformity with Transportable Pressure Equipment Devices 2010/35/UE

Re. As long as there is no other pressurised gas tank, the machine is not covered by PE Directive just because of presence the bottles . The machine is still a subject to machinery directive.

Hook lift CEmarkQ. 33. My company instals hook lifting devices on trucks for transport of containers. I know that needs to be CE marked but how should we do it ? Should the entire vehicle be CE marked or hook lift device only ?

Re. Machines installed on vehicles are subject to machinery directive but not the entire vechicles (as long as we are talking about type approved road vehicles). So declaration should cover a HOOK LIFT ON A VEHICLE as the vehicle is a part of that entire structure and must be considered in your risc assessment analysis. It still doesn't mean the vechicle is subject of the machinery directive.


tripod winch lamptripod winch2Q.34 One of our Customers asked if his tripod stand intended for holding and lifting a lamp or loud system and equipped with a manual rope winch for lifting it needs to be CE marked on not. 

This particular product don't need to be (can not be) CE marked under Machinery Directive 2006/43/CE but you it might be CE marked under LVD if the tripod is equipped with electrical equipment for powering the device held on it (provided that it is in voltage range covered by LVD) 


tripod liftingQ.35 Another product of our Customers is tripod stand intended for lifting general goods. The tripod is equipped with a manual driven rope winch for lifting. Does it need to be CE marked on not ? 

Yes, this product (although manually driven) is a machine for lifting loads and it is a subject to CE marking under machine directive.




Haven't you found what you are looking for ? Next question can be your. Just email us please :-)



CE marking of vehicles and machines installed on vehicles

Lets consider different types of vehicles:
1. intended for carying goods internally in factory and not allowed to be driven on public roads.
2. vehicles intended to be driven on public roads

Regarding the 1st - those vehicles are ‘machines’ and hence should be CE marked. (they are not considered as road vehicles unless they are allowed to move on public roads).

Regarding the 2nd - these vechicles are excluded from Machinery Directive as they are subject of type-approval of motor vehicles and their trailers with exclusion of machinery mounted on these vehicles.
The last part of the above sentence means that any machines installed on vechicles (eg. elevating work platforms, cranes, cement mixers …) or under vechicle (special rail chassis )are still subject to the directive and hence should be CE marked.


CE marking of road trailers and off-road trailers

We are producing a bespoke trailer intended for carrying goods internally in industrial area of a factory. The trailer will be towed by a tractor and is connected to the tractor's pneuatic system to feed braking system. The trailer is equipped with lights (powered from tractor) but is not intended to travel on public road. Is this trailer a subject to CE marking ? Whitch directives should be considered ? Is that considered as a machine ?

Let's analyze; the trailer complies a definition of a 'machine' described in Machinery Directive 2006/42/EC (first indent od Article 2 letter a). It is not fitted to a drive system but it is intended to be fitted to drive systen whitch is a tractor is this case. So, trailers are considered as machine. There are also exclusions from a directive. Is our trailer excluded ? Second exclusion of Article 1 (e) states - "motor vehicles and their trailers covered by Council Directive 70/156/EEC..." We said our trailer trailer is off-road and will not be a subject to type approval hence, it is not excluded from MD and need to be CE marked under Machinery Directive.

What about Low Voltage Directive 2014/35/EC ? The trailers' ligts are powered by 24 VDC from a tractor. That level of voltage is not covered by LVD hence our trailer is not a cubject to Low Voltage Directive.


CE marking of modified/modernized machinery

A lot of machines have been supplied for a bespoke purposes and after short time of operation you may need to modify it for different purposes. This is a common problem of users. In general, original Declaration of Conformity is not valid as soon as you modified the machine. Sometimes it is clearly written on declaration but don't need to as it is written is Machinery Directive. Hense, the modifier is obliged to CE mark the machine again and then question arises - how can we analyze its conformity with basic requirements when we don't posess desing and calculations ?
It is allowed to presume that machine being modified complies its original requirements and you are obliged to analyze the influence of modification. You need to analyze all risks related/raised by your modification.
As the original Declaration of Conformity is no longer valid we are obliged to raise a new one and new user manual. We don't need to redraw it att but it is sufficient to update the original manual. We have to put a new CE nameplate on the machine as well. Besides, we are responsible for the modification and obliged to keep the documentation for 10 years. This documentation should contain: original manual, CE-nameplate, our analisis and risc assessment and all related with the modernization.


CE marking of outdoor mobile LED screen a trailer

Our product is a huge (200 inch diagonal) LED screen installed on a bespoke trailer. The screen has been designed for outdoor events, presentations etc. and is placed on a telescopic and rotating column. The lifting of a column is maintained by hydraulic cylinder supplied from onboard hydraulic power unit. The trailer is a bespoke solution intended to trevel on public roads. Is this the entire device considered as 'machine' and should be CE marked ?


CE marking of tractor's attachments

There are plenty of attachments, usually hydraulically powered ex. front and rear lifts, loaders, forklifts, cranes, backhoes etc.... How do we clasify them and should they need to be CE marked ? Attachements like these may be provided by tractors' producers' or by third parties. As long as they have been provided with a new tractor as subassembly of the mashine (refered to in manual), they don't need to be CE marked separatelly. In another way, while such a products are placed separaterlly on the market they are 'interchangebla equipment' for machines and then they should be CE marked and Declaration of Conformity as well as user manual should be provided.

tractor attachmtractor front loadertractor grappletractor lift front

(regarding attachments like: grapples, grippers etc.... see question 9 above)


to be continued...





deklaracja EC

There are plenty of CE marking consultants. They can advise about CE marking of anything. There are around 30 European Directives that treates about different products CE marking. You can find consultants that say they work with all of them but as soon as you need to talk about details and specific cases they will rather not help you because their main business goals are trainings and general instructions sales.

We specialize in CE marking of machines and products closely related to machines as electrical devices, pressure equipment... etc.

We provide detailed advice regarding:

New machines intendet to be put on EU market,

Used machines to be modified to comply EC requirements,

Machines imported from non-EU countries, new and used,

We can either advice or prepare CE marking documentation of your product or a product you are going to import from non-EU countries.

We work with all directives related to machines:

Machinery Directive - MD - 2006/42/EC

Low Voltage Directive - LVD - 2006/95/EC, 2014/35/EC

Electromagnetic Compatibility Directive - EMC - 2004/108/WE, 2014/30/EC,

Pressure Equipment Directive - PED - 97/23/EC i 2014/68/EC

Noise Directive - NOISE - 2000/14/EC, 2005/88/EC

MSL3 IMG 3387mCEpanel Ruukki4mCEIMG 0753mCE





autopodnosnikCEMAN DSCF1745mCEExcavatorCE


acc. to standards: EN 280 - Mobile elevating work platforms. Design calculations. Stability criteria. Construction. Safety. Examinations and tests, 

Road-rail vehicles, rail drives EN 15746 - Railway - Track - Road-rail machines

Liftig machinery (EN 1493 - Vehicle lifts, EN 12999 - Cranes. Loader cranes, EN 13000 - Cranes. Mobile cranes)


Dar3 IMG 2363mCEDar4 IMG 2384mCE


acc. to standards: EN ISO 4413 - Hydraulic fluid power – General rules and safety requirements for systems and their components

IMG 0973CEDar2 IMG 2356mCE


EN ISO 16092-1 - Machine Tools Safety -- Presses -- Part 1: Genaral Safety Requirements



Machinery Design Office

mob. UK +44 7427755022 (WhatsApp available)

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