CE Marking

The legal reality nobody tells first-time builders

A robot arm on its own is not a machine in the legal sense — it is partly completed machinery. The moment you integrate it with conveyors, guarding, a control system and tooling into a working cell, you have manufactured a new machine. And the party who manufactures a machine is responsible for its conformity: in Great Britain under the Supply of Machinery (Safety) Regulations with UKCA marking, in the EU (and for Northern Ireland) under the Machinery Regulation with CE marking. Build a cell for your own use and the duty is still yours — putting machinery into service counts, not just selling it.

That sounds heavy. Here is the reassurance this whole series has been quietly building toward: conformity is not a mountain of paperwork bolted on at the end. It is evidence that you designed the machine safely and can prove it — and if you have followed Parts 1 to 9, you already hold nearly all of that evidence. This part is about assembling it, not creating it.

The Technical File — you have been writing it since Part 2

The Technical File is the documented evidence that the machine meets the essential health and safety requirements. Look at what the series has produced and where it lands:

If a row in that table is thin for your cell, that is your to-do list. Notice what this table really is, though: proof that the documentation-as-you-go approach was never bureaucracy for its own sake. The alternative — reconstructing a risk assessment and validation evidence after the machine is running — is genuinely miserable work, produces worse documents, and is exactly how conformity gets a reputation as a paperwork exercise.

Instructions for use — the last real engineering task

The machine must come with instructions: intended use, residual risks and how they are managed (the direct output of Part 2's residual risk column), operating procedures for every mode, the recovery procedures you wrote during commissioning, maintenance requirements and isolation procedures, and the training operators need. Write it for the 3am audience — the operator with a stopped cell and a torch, not an auditor. If you involved your operators through Parts 8 and 9, most of this is written; it just needs assembling into one document that lives with the machine.

The cell and each machine within it

Here is the part most guides skip: the cell as a whole needs a Declaration of Incorporation, while each individual machine within it — every conveyor, every custom gripper — needs its own Declaration of Conformity. A conveyor you built or specified is a machine in its own right. A custom gripper or end-of-arm tool with its own power systems and moving parts is a machine. Each one needs its own declaration, its own plate, and its own supporting evidence — not just the cell-level document that covers the complete assembly.

The practical approach that works well: one risk assessment for the whole cell, comprehensive enough to cover every hazard associated with every piece of equipment in it. That single assessment then serves as the risk assessment for each individual machine declaration too, because the hazards of a conveyor inside a guarded cell were assessed in context and the measures applied are documented. You are not duplicating work — you are referencing the same document at the right level.

For declarations: if all conveyors in the cell are identical in design and build, one Declaration of Conformity covers them all — you declare the design, not each individual unit separately. The serial numbers of each conveyor can be listed on a single declaration or referenced as a type. Where conveyors differ — different lengths, different drive arrangements — each variant needs its own Declaration of Conformity, because the declaration is for the machine as designed, not just the category.

The robot is different from the machines you build yourself. The robot manufacturer — KUKA, ABB, or whoever supplied it — issues a Declaration of Incorporation for the robot at delivery. You do not produce this; it comes with the robot in the documentation pack. It is explicitly not a Declaration of Conformity, because the robot is partly completed machinery that cannot be put into service on its own. Your job as integrator is to take that manufacturer's Declaration of Incorporation, file it in your Technical File as evidence of correct supply, and then produce your own Declaration of Incorporation for the complete cell.

Declaration, plate and marking

With the Technical File assembled and the machine conforming, the closing steps are short:

• Draw up the Declaration of Incorporation for the cell — identifying the machinery, the responsible person, the regulations and standards applied, signed by someone authorised. Draw up a separate Declaration of Conformity for each individual machine you manufactured within the cell (conveyors, EOAT, any custom-built device). The incorporation declaration is you formally stating the cell meets the essential requirements; the conformity declarations cover each constituent machine
• Fit the machine plate — manufacturer, machine designation, serial, year, and the UKCA or CE marking as applicable
• Retain the Technical File for at least ten years, and keep it maintained — the file describes the machine as it is, so modifications later must be assessed and the file updated. A significant modification can make you the manufacturer of a new machine all over again, which is worth knowing before anyone "just adds a second infeed"

For a standard guarded industrial robot cell, conformity assessment is self-certification — you do not need a notified or approved body involved. That route is reserved for the specific high-risk machinery categories listed in the regulations, which a conventional palletising or handling cell does not fall into. What self-certification absolutely is not is a lower standard: it means the responsibility to get it right sits entirely with you, on the evidence in your file.

Common mistakes

• Assuming the robot's declaration covers the cell. The robot arrives with a Declaration of Incorporation for partly completed machinery — it does not cover the cell, and it explicitly says so
• Leaving the Technical File until the end and reconstructing evidence backwards — the single biggest cause of conformity misery
• Instructions written for auditors instead of operators
• Certifying the design as drawn rather than the machine as built — the as-built updates from Part 9 exist for this
• Modifying the cell later without assessing whether the file — and the declaration — still hold

That's the series — and the point of it

Ten parts ago this began with a floor plan and a claim: that a capable in-house team can build a robot cell properly, for a fraction of what they had been quoted, without cutting a single corner on safety. Layout, risk assessment, safety design, validation, controls, communications, programming, testing, commissioning, conformity — none of it required magic. It required method, honesty about what you don't know, and the discipline to write things down. The machine on your floor with your company's name on the plate is the proof.

If your cell happens to be palletising, the programming part of that journey is one we can shorten to minutes — that is exactly what we built the generator for, out of the same frustration with integrator pricing that started this series.

Series complete

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