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Partly completed machinery and the EU declaration of incorporation

Selling drive units, robot arms without end effectors, modules or other assemblies that only work once built into a machine? From 20 January 2027 Article 11 of Regulation (EU) 2023/1230 sets your duties. Confirm against the official text on EUR-Lex.

What counts as partly completed machinery (Article 3(10))

An assembly which is not yet machinery as it cannot in itself perform a specific application and which is only intended to be incorporated into or assembled with machinery or other partly completed machinery or equipment, thereby forming machinery.

Your obligations as the manufacturer (Article 11)

DutyWhere in the Regulation
Design and build to the relevant essential health and safety requirementsArt. 11(1), Annex III
Draw up the technical documentation before placing on the marketArt. 11(2), Annex IV Part B
Keep the file and the declaration of incorporation for at least 10 years; source code or programming logic on reasoned request where neededArt. 11(3)
Procedures so series production stays in conformityArt. 11(4)
Mark designation, year of construction, model, series or type and any batch or serial number (or on packaging/accompanying document)Art. 11(5)
Contact address: a single point of contact, in a language the integrator and authorities understandArt. 11(6)
Supply assembly instructions; digital allowed, paper free of charge within one month if requested at purchase; online for at least 10 yearsArt. 11, Annex XI
Supply the EU declaration of incorporation, or give its web address or machine-readable code in the assembly instructionsArt. 11, Annex V Part B
Corrective action, withdrawal or recall; inform authorities where there is a riskArt. 11(9)

What the declaration of incorporation must include (Annex V, Part B)

Annex V Part B lists further items (identification of the product and the declaration statement); use the full list from EUR-Lex or our template.

Points to check

FAQ

Does partly completed machinery get a CE mark?

No CE marking is listed among the Article 11 duties. The supplier issues an EU declaration of incorporation (Annex V, Part B), and the final machine is CE marked by whoever completes it and declares it in conformity.

Can the declaration of incorporation be digital?

Yes. Article 11 allows the internet address or machine-readable code to be given in the assembly instructions, and digital declarations must stay accessible online for at least 10 years.

How long must the file be kept?

At least 10 years after the partly completed machinery is placed on the market, together with the declaration of incorporation.

General information, not legal advice or certification. Source: Regulation (EU) 2023/1230 Article 3(10), Article 11, Annexes III, IV Part B, V Part B and XI, on EUR-Lex.

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Related: declaration of conformity contents · technical documentation (Annex IV) · digital instructions · transitional rule. We sell to businesses only; see Terms.