normakte / Assemblies of machinery
Whoever combines several machines into a plant that works as a whole is the manufacturer of that assembly. From 20 January 2027 the Machinery Regulation applies to it – with new particulars in the declaration and evidence spread across many suppliers.
An assembly of machinery exists when several machines, partly completed machines or both are arranged and controlled so that they function as an integral whole – typically with a common control system and common safety functions. Whoever puts it together takes on the manufacturer's obligations for the assembly.
| Document | Where it comes from |
|---|---|
| Risk assessment of the assembly, especially the interfaces: emergency stop, cross-machine safety functions, control system | your own work |
| Declarations of conformity of the purchased complete machines | suppliers |
| Declarations of incorporation and assembly instructions of the partly completed machines | suppliers |
| Evidence for pressure equipment and assemblies, equipment for explosive atmospheres | suppliers and your own assessment |
| Instructions for the complete plant | your own work |
| One EU declaration of conformity for the assembly | your own work |
This obligation is not new: the directives aligned with the New Legislative Framework, such as the Pressure Equipment and ATEX Directives, have required it since 2016, and the Machinery Regulation adopts it explicitly. If more than one act requiring an EU declaration of conformity applies to the plant, a single declaration is drawn up that names them all – for example the Machinery Regulation, the Pressure Equipment Directive 2014/68/EU and the ATEX Directive 2014/34/EU. Each act keeps its own requirements and conformity assessment procedures. If the control system has a network connection, the Cyber Resilience Act is added from 11 December 2027.
Whether a plant counts as an assembly and which acts apply in detail depends on its actual design; the legal texts and the Commission's guides are authoritative.
Suppliers' declarations, your own evidence and the overall declaration in one place – with the article reference for each requirement. Trial file free until 20.01.2027.
Sources. Regulation (EU) 2023/1230, OJ L 165 of 29.6.2023; Regulation (EU) 2024/2847, OJ L, 2024/2847 of 20.11.2024. Summarised; only the official text is authoritative. normakte is not legal advice.