CE marking refurbished or modified machinery

Modified machinery

Refurbished or modified machinery could be subject to re-evaluation of the CE marking. The extent of the changes made to the original machinery, together with its provenance, can result in several situations. For example:

  • Re-certification
  • Legal obligations on the owner, user or person undertaking such work.

Substantial changes

In some cases where machinery has been so transformed or substantially rebuilt it may have to be considered as new machinery and is therefore subject to the conformity assessment and CE marking requirements of the Machinery Directive.

Minor changes

Originally compliant and CE marked machinery that is refurbished and or where parts are replaced with new similar versions (like for like etc) do not require re-CE marking.

Safety

The change to a substantially different safety strategy may also require re-assessment and compliance with the Machinery Directive, even if the original machine was not CE marked because it pre-dated the Directive.

Example

The substitution of fixed fencing and interlocked doors with photoelectric or laser scanning safety systems requiring additional associated logic control units will probably require re-compliance with the Machinery Directive before the machinery is placed back on the market or put back into service.

Questions? Contact Us

How can a producer evaluate if already produced machinery is refurbished, changed or modified from the original produced machinery? Based on the guideline below you can determine if your machinery should be considered as:

  • New machinery
  • Machinery that needs re-evaluation
  • If a modified EC declaration can be compiled based on the new European implemented directives.

  • Have changes been made to the design from the original produced machinery?
  • Has the intended use of the machinery been changed from the original produced machinery?
  • Have changes been made related to the function from the original produced machinery?
  • Has the design or construction been changed or modified from the original produced machinery?
  • Do changes affect the safety of the machinery from the original produced machinery?
  • Do the changes create new hazards during operation from the original produced machinery?
  • Do the changes introduce new risks from the original produced machinery?
  • Due to changes are new operation methods of control required from the original produced machinery?
  • Has the machinery been modified from manually operated to computer operated from the original produced machinery?
  • Are new computer control aspects implemented from the original produced machinery?
  • Has the automatic programming been changed or modified from the original produced machinery?
  • Are new assemblies added to the machine ( substantial or minor) from the original produced machinery?
  • Do new methods of control replace the previous methods of the machinery concerned from the original produced machinery?
  • Have changes made to the electrical installation of the machinery from the original produced machinery?
  • Have modified or new electrical components deviating from the original components been replaced from the original produced machinery?
  • Have emergency stop devises been changed or modified from the original produced machinery from the original produced machinery?
  • Have warnings or markings been changed or modified from the original produced machinery from the original produced machinery?
  • Have protective devises on the machinery been changed or modified from the original produced machinery?
  • Have the users instructions been modified or change from the original produced machinery?
  • Have the installation instructions been modified or changed?
  • Has the name or model number of the machinery been changed from the original machinery?

If the answer is Yes to one or more of these questions you must take action! In most cases a re-evaluation, re-certification or updating your declarations will be required. Do you have questions or do you need help to re-assess the situation?