normakte / CE marking and partly completed machinery
The short answer: no CE marking. The long answer explains why — and when there is one after all.
Partly completed machinery cannot, on its own, perform a specific application. It is intended to be incorporated into other machinery or assembled with it. It therefore meets only the relevant requirements of Annex III — not all. And a CE marking would claim what cannot be claimed.
| Document | Instead of | Basis |
|---|---|---|
| EU declaration of incorporation | the declaration of conformity | Art. 22, Annex V Part B |
| Assembly instructions | the instructions for use | Art. 11(7), Annex XI |
| Technical documentation Part B | Part A | Art. 11(2), Annex IV Part B |
| no CE marking | — | Art. 23 |
Point 8 of Annex V Part B requires a statement that the partly completed machinery must not be put into service until the final machine into which it is incorporated has been declared to conform with the regulation. And point 7 requires the undertaking to transmit, on the reasoned request of national authorities, the relevant information — stating how it is transmitted. Intellectual property rights are unaffected.
Where the same assembly falls under other Union harmonisation legislation requiring CE marking — such as the EMC Directive 2014/30/EU or the Low Voltage Directive. It then bears a CE marking, but not for the Machinery Regulation. The distinction belongs in the accompanying documents, otherwise the integrator and market surveillance will read it wrong.
Whoever incorporates the partly completed machinery and turns it into ready-to-use machinery becomes the manufacturer of the complete machine: they issue their own declaration of conformity and affix the CE marking. Your declaration of incorporation and your assembly instructions then go into their technical documentation — Annex IV Part A, point (j).
Not under the Machinery Directive or the Machinery Regulation. Other legislation, such as the Low Voltage Directive, may require CE marking for the product itself.
The manufacturer of the complete machine into which the partly completed machinery is incorporated, after the conformity assessment of the whole machine.
The EU declaration of incorporation and the assembly instructions.
Declaration, assembly instructions, risk assessment and documents of the partly completed machinery in one place – one trial file free until 20.01.2027.
Sources. References from the versions published in the OJ: Regulation (EU) 2023/1230 (OJ L 165, 29.6.2023); Regulation (EU) 2024/2847 (OJ L, 2024/2847, 20.11.2024). The official text prevails; normakte is a drafting aid, not legal advice.