normakte / High-risk machinery (Annex I)
Annex I decides whether you may assess conformity yourself or need a notified body. Here is the complete list – and the path to the decision.
Categories to which a procedure under Art. 25(2) applies:
Categories to which one of the procedures under Art. 25(3) applies:
| Your machine | Permitted procedures | Notified body |
|---|---|---|
| not in Annex I | internal production control (module A, Annex VI) | no |
| Annex I Part B, standards or common specifications cover all relevant requirements | A, B+C, H or G | no for module A, otherwise yes |
| Annex I Part B, standards do not cover everything | B+C (Annexes VII and VIII), H (Annex IX) or G (Annex X) | yes |
| Annex I Part A | B+C, H or G | always |
For Part B, module A is only permitted if the machinery was designed and constructed in accordance with harmonised standards or common specifications covering all relevant essential requirements for that category (Art. 25(3)). Presumption of conformity is tied to standards whose references are published in the Official Journal (Art. 20(1)). Before choosing module A, check which standards are published for your category under the Regulation and whether they also cover the new requirements – for example on software and cybersecurity. Without full coverage, the route goes through a notified body.
The Commission may amend Annex I by delegated acts – adding, removing or moving categories between parts (Art. 6(2)). A category goes into Part A where there is a serious inherent risk and further conditions, for example missing harmonised standards or repeated serious accidents (Art. 6(7)). Check the list before every new declaration.
No. If harmonised standards or common specifications cover all relevant requirements and you have applied them, module A is permitted (Art. 25(3)).
No. Part A covers safety components and embedded systems with self-evolving behaviour through machine learning that ensure safety functions. Software that does not learn and only executes programmed functions is not covered, according to recital 55.
It remains valid until it expires (Art. 52(2)) – for machinery placed on the market under the Directive. For placing on the market under the Regulation, the procedure of Art. 25 applies.
First the manufacturer, who justifies and documents the classification. In case of doubt, consulting a notified body helps; binding interpretation lies with authorities and courts.
Category, reasoning, chosen module and certificates together – with article references. Trial file free until 20.01.2027.
Sources. Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, including the corrigendum of 1.4.2025; Directive 2006/42/EC for the previous regime.
The information has been checked against the official text, paraphrased and shortened; only the official text is authentic.
normakte is a drafting and calculation aid; it replaces neither conformity assessment, nor a notified body, nor a technical assessment by a specialist, nor legal advice.