Machinery Regulation guide
EU declaration of conformity: definition, mandatory contents, transition to the Machinery Regulation
The legally binding document behind the CE marking: what belongs in it — and what changes on 20 January 2027.
What is a declaration of conformity?
The EU declaration of conformity is the legally binding declaration by the manufacturer that its machinery complies with all relevant requirements of the applicable EU legislation — today the Machinery Directive 2006/42/EC, from 20 January 2027 the EU Machinery Regulation (EU) 2023/1230. It is issued under the sole responsibility of the manufacturer and is the basis on which the CE marking may be affixed.
Important for context: the declaration of conformity is not a test certificate from an authority but a self-declaration. With it, the manufacturer confirms that it has completed the conformity assessment procedure — from the risk assessment through the technical documentation to the operating instructions. For partly completed machinery, its place is taken by the declaration of incorporation together with assembly instructions.
Mandatory contents of the declaration of conformity under the Machinery Regulation
The Machinery Regulation specifies which particulars belong in the EU declaration of conformity. In practice, a fixed structure has become established:
- Name and address of the manufacturer and, where applicable, of its authorised representative in the EU
- The person established in the EU who is authorised to compile the technical documentation
- Unambiguous identification of the machinery: designation, function, model, type, serial number
- The explicit declaration of conformity with Regulation (EU) 2023/1230 — plus any other applicable EU legislation (e.g. the EMC Directive)
- Where applicable, the notified body and the number of the certificate
- Harmonised standards applied (e.g. DIN EN ISO 12100) or other specifications
- Place, date, name, function and signature of the person authorised to sign
Converting the declaration of conformity and providing it digitally
On the cut-off date of 20 January 2027, the legal reference of the declaration must change: instead of the Machinery Directive 2006/42/EC, Regulation (EU) 2023/1230 must be referenced. Anyone building machinery with delivery dates around the cut-off should convert their templates now — a declaration with an outdated legal reference is an avoidable defect that market surveillance authorities notice immediately.
Retention and access are the second stumbling block: the declaration of conformity must be retained for 10 years from the placing on the market and belongs to the documentation of the machine. Digital filing in the machine file behind the QR code of the machine has proven itself — versioned, permanently retrievable and unambiguously assigned to the serial number. A free Word template with all mandatory particulars is available in our templates section.
FAQ
Frequently asked questions
Who may sign the declaration of conformity?
A person of the manufacturer authorised to sign — typically the managing director or an authorised member of management. The declaration is issued under the sole responsibility of the manufacturer.
What is the difference between the declaration of conformity and the CE marking?
The CE marking is the visible mark on the machine; the declaration of conformity is the legally binding document behind it. Without a complete declaration of conformity, no CE marking may be affixed.
Does partly completed machinery need a declaration of conformity?
No. Partly completed machinery receives a declaration of incorporation and assembly instructions — the EU declaration of conformity is only issued by the manufacturer of the complete machinery.
Keep reading
More chapters of this guide
Machinery Regulation: Deadlines and Transition until 20 January 2027
A hard cut-off date instead of a transition period: from 20 January 2027, every placing on the market is governed exclusively by the Machinery Regulation.
Digital Operating Instructions under the Machinery Regulation: What Is Permitted
Paper is no longer mandatory: Article 10(7) permits digital operating instructions — subject to four conditions.
Technical Documentation under the Machinery Regulation: Scope, Retention, Access
From risk assessment to declaration of conformity: what must remain deliverable for 10 years — and what may stay protected.
QR Code on the Machine: How It Satisfies the Machinery Regulation
The Machinery Regulation does not prescribe a QR code — but it does require a permanent digital access route. The code is the de facto standard.
Risk Assessment under the Machinery Regulation: Obligation, Process, Documentation
No CE marking without a risk assessment: the process according to ISO 12100 — and the new Machinery Regulation requirements from cybersecurity to AI.
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