CE marking checklist: the complete guide to tick off

CE marking involves numerous steps and documents. With this field-tested checklist you keep the overview and make sure that no important item is forgotten. Ideal for CE officers, design engineers and project managers in mechanical engineering.

1

Preparation and directive research

In the first step you clarify which EU directives and regulations your product falls under. This step is decisive, because a mistake here can invalidate the entire subsequent process.

Classify the product unambiguously: is it complete machinery, partly completed machinery, interchangeable equipment or a safety component?
Identify all applicable EU directives and regulations (e.g. Machinery Directive, Low Voltage Directive, EMC Directive, ATEX Directive)
Define the intended use and reasonably foreseeable misuse of the product in writing
Determine the limits of the machine: space limits, time limits (service life), use limits
Check whether the product falls under Annex IV of the Machinery Directive (special machinery categories with higher requirements)
Research the relevant harmonised standards (type A, B and C standards) and confirm their current edition
2

Carry out the risk assessment

The risk assessment per EN ISO 12100 is the heart of CE marking. It is mandatory for every machine and must be documented systematically and traceably.

Consider all life phases of the machine: transport, assembly, commissioning, normal operation, setting, cleaning, maintenance, troubleshooting, dismantling, disposal
Identify hazards systematically (mechanical, electrical, thermal, noise, vibration, radiation, chemical, ergonomic)
Evaluate risks: determine the severity of the possible harm and the probability of occurrence
Define risk reduction measures using the three-step method: 1. inherently safe design, 2. safeguarding, 3. information for use
Document residual risks and list them in the operating instructions
Have the risk assessment checked and approved by a competent person
3

Design and safety concept

Based on the risk assessment, the safety concept is drawn up and integrated into the design. This is where the previously defined protective measures are actually implemented.

Design safety functions per EN ISO 13849-1 or EN 62061 and determine the required performance level (PL) or SIL
Select and dimension guards per EN ISO 14120
Plan non-separating protective devices (light curtains, pressure-sensitive mats etc.) per EN ISO 13855 (safety distances)
Design and position emergency stop functions per EN ISO 13850
Design the electrical equipment per EN 60204-1
Design safety-related pneumatics and hydraulics per EN ISO 4413/4414
Take ergonomic requirements into account (accessibility, operating height, force required)
4

Compile the technical documentation

The technical documentation must map the entire conformity assessment process traceably in accordance with Annex VII of the Machinery Directive (or Annex IV of the Machinery Regulation). It must be kept for 10 years after the last date of manufacture.

General description of the machine with photos or drawings
Overall drawing and detail drawings, circuit diagrams (electrical, pneumatic, hydraulic)
Complete risk assessment with hazard identification, risk evaluation and evidence of measures
List of the harmonised standards and other technical specifications applied
Description of the protective measures against the hazards identified
Test reports and measurement results (e.g. EMC measurement, earth continuity measurement, noise emission)
Operating instructions in the official language(s) of the country of destination
Declaration of incorporation for partly completed machinery (if applicable) and assembly instructions
Copy of the EU Declaration of Conformity
5

Conformity assessment and completion

Once the technical documentation is complete, the formal conformity assessment follows. Depending on the machine type, it can be carried out by the manufacturer themselves or by a notified body.

Select the conformity assessment procedure: internal production control (module A) or involvement of a notified body (modules B+C, H)
If required: contact a notified body and commission a type-examination or a QM system audit
Draw up the EU Declaration of Conformity with all mandatory details per Annex II of the Machinery Directive or Annex V of the Machinery Regulation
Affix the CE marking: minimum height 5 mm, visible, legible, indelible. Directly on the machine or on the rating plate
Attach the rating plate with: company name and address, machine designation, serial number, year of construction, identification number of the notified body if applicable
Supply the operating instructions with the machine (printed or, under the Machinery Regulation, also digitally with a free paper copy on request)
Archive the technical documentation in an audit-proof way (at least 10 years)

Time frame

The time needed for CE marking depends heavily on the complexity of the machine. As a rough guide:

PhaseSimple machineComplex installation
Directive research1 to 2 days3 to 5 days
Risk assessment3 to 5 days2 to 6 weeks
Safety concept2 to 5 days2 to 4 weeks
Technical documentation3 to 7 days4 to 8 weeks
Conformity assessment1 to 2 days2 to 8 weeks

Important: CE marking is not a process that only begins at the end of product development. Ideally the risk assessment starts as early as the concept phase and accompanies the entire design. That is how costly rework is avoided.

Common mistakes in CE marking

Even experienced manufacturers keep making the same mistakes in CE marking. Avoid these typical pitfalls:

Not all directives considered

Many machines fall under several directives at once (e.g. Machinery Directive + EMC + Low Voltage). If one is overlooked, the declaration of conformity is incomplete.

Risk assessment only pro forma

A risk assessment that was obviously produced just to tick a box and contains no real hazard analysis will not withstand any inspection by the authorities.

Outdated standards applied

Harmonised standards are updated regularly. Applying a withdrawn standard no longer provides a presumption of conformity. Always check the current status in the Official Journal of the EU.

Operating instructions not in the national language

The operating instructions must be available in the official language of the country in which the machine is put into service. Instructions in English alone are not sufficient for the German market.

CE marking affixed incorrectly

The CE mark has a standardised design (based on a grid). It must be at least 5 mm high and affixed visibly and indelibly to the product or the rating plate. Stickers that come off easily are not sufficient.

Documentation not retained

The technical documentation must be available for at least 10 years from the last date of manufacture. For series machinery that means: 10 years after the last unit produced.

Which documents do you need?

In summary, you need the following documents for complete CE marking:

Risk assessment

Per EN ISO 12100

Technical drawings

Overview + detail drawings

Circuit diagrams

Electrical, pneumatic, hydraulic

List of standards

Harmonised standards applied

Test reports

Measurements, tests, validation

Operating instructions

In the national language

Declaration of conformity

Per Annex II Machinery Directive or Annex V Machinery Regulation

Safety evidence

PL/SIL calculation per EN ISO 13849-1 or EN 62061

You define the required performance level (PLr) in the functional safety module and document the achieved result there as well. The calculation of the achieved PL per EN ISO 13849-1 is carried out in SISTEMA, the free tool from the IFA of the DGUV. CE-Copilot does not replace SISTEMA. The SISTEMA report then belongs in your technical file as evidence.

Work through the CE checklist digitally

CE-Copilot digitises your CE checklist and guides you through every step with AI support, from the risk assessment to the finished declaration of conformity.