Assemblies of Machinery

Conformity for Your Plant

Your plant may be legally considered an assembly of machinery under the Machinery Regulation (EU) 2023/1230, thus becoming a single new machine. For the responsible party, this establishes full manufacturer responsibility for the entire plant. We clarify the legal situation, define interfaces on the individual machinery and ensure complete conformity.

Safe Interfaces. Safe Assemblies.

The interlinking of several individual machines to form a single functional and safety-related unit is widespread in industry. At the same time, there is a legal pitfall here, as the company responsible for linking the individual machinery is legally considered the manufacturer of the so-called assembly of machinery. This unit, often colloquially referred to as a system or plant, must undergo the complete conformity assessment procedure. The reason for this is that the safety of an assembly of machinery must be considered holistically to secure all interfaces between the individual machinery.

The conformity assessment for an assembly of machinery does not differ significantly from the procedure for individual machinery. It includes performing a risk assessment for the entire plant, verifying the functional safety of shared and higher-level control systems and compiling comprehensive technical documentation. In doing so, we ensure that all interfaces between the individual machinery are safely assessed and documented. During the planning phase of the system, we are at your side to request the necessary information about the individual machinery and find ways to avoid machinery assemblies in a legally compliant manner.

We check the criteria for an assembly of machinery and show you the necessary steps to comply with legal obligations.

Questions, Answers, and Our Services Regarding Assemblies of Machinery

When Is a Group of Machines Considered an Assembly of Machinery?

Answer: A group of machines is considered a single unit if a technical connection exists between several machines in terms of production and safety. The decisive factor is that the interconnection creates a closed unit with close interactions. For this reason, the hazards of the group as a whole are not covered by the conformity of the individual machines. As a result, it is essential to issue a new Declaration of Conformity to confirm that the assembly as a whole is safe in accordance with the current state of the art.


Our Service: Before we provide support in the complex conformity assessment procedure for an assembly of machinery, we carefully check whether it actually constitutes an assembly in the legal sense. We support you in the early stages of the project and evaluate options for avoiding an assembly of machinery in a legally compliant manner. This allows you to rule out future costs and liability risks for machinery from other manufacturers. We are also happy to mediate between you and your clients to clarify the question of an assembly of machinery in a neutral manner.

Who Is the Manufacturer of an Assembly of Machinery?

Answer: The manufacturer of the assembly is the party responsible for linking several individual units of machinery. This is often a general contractor, an integrator, or the operator itself, provided that it carries out the interconnection independently. This new manufacturer assumes full responsibility for the safety of the entire system. It must ensure that the interaction of the individual machinery does not give rise to any unacceptable risks and that interfaces are controlled in terms of safety. In addition, the manufacturer is responsible for carrying out the conformity assessment procedure.


Our Service: We support you in fulfilling your complex manufacturer responsibilities in a legally compliant manner. We take over the operational implementation of the conformity assessment procedure for your entire system. We prepare the necessary risk assessment and evaluate the interactions between the individual machinery. You will receive documentation ready for decisions on the basis of which you can sign the declaration of conformity for the entire system with confidence. Furthermore, we are happy to review the contract and mediate between all parties involved to clearly identify the responsible entities. If you do not wish to act as the manufacturer of an assembly of machinery, it is necessary to address the legal framework at an early stage.

What happens to the CE markings on the individual machines?

Answer: Please do not remove the markings and type plates from the individual machinery when you link them together to form a complete system. The original CE markings and declarations of conformity for the individual machinery remain valid but are no longer sufficient in the context of the assembly. The documentation for the individual machinery becomes a mandatory part of the new technical documentation for the entire system. The CE marking for the entire system thus encompasses the individual machinery and their interfaces. This creates something greater than the sum of the individual parts.


Our Service: First, we review and consolidate the documentation for the individual machinery. In doing so, we identify gaps in the interface considerations of the original manufacturers and carry out the necessary new analyses. We then integrate all certificates and evidence into new uniform technical documentation for the entire system that meets all legal requirements. We are also happy to support you in purchasing to ensure all relevant documents are requested when procuring individual machinery, which facilitates the creation of the overall documentation.

What Documents Are Required for an Assembly?

Answer: When creating an assembly of machinery, a new conformity assessment procedure is required. This procedure includes a new risk assessment that specifically applies to the assembly. In addition, proof of the functional safety of the common control system and the respective performance level must be provided. Master instructions for use, a new type plate, and a new EU declaration of conformity for the entire system are also mandatory. In principle, the procedure is the same as for a single unit of machinery. The difference lies in the complexity as risks associated with purchased parts or machinery from other manufacturers are often unknown. Without a solid documentation basis, the effort required to assess conformity often increases exponentially.


Our Service: We create all the necessary documents from a single source, including the overarching risk assessment, the validation of common safety functions, the new declaration of conformity, and the overarching instructions for use. We ensure that the documents are consistent and free of contradictions. You do not have to deal with the various standards and documentation for the individual machinery. Ideally, you should involve us at an early stage of the project. This allows us to define the scope of delivery for purchased machinery in advance with precision so that a seamless and cost-effective integration into the overall system is achieved.

Can Classification as an Assembly of Machinery Be Avoided?

Answer: Yes, classification can be avoided if the criteria of an assembly of machinery are not fully met. The decisive factor is often the so-called safety-related connection. If it is possible to separate the individual machinery from each other in terms of safety, there is no assembly within the meaning of the Machinery Regulation (EU) 2023/1230. In practice, we often achieve this by decoupling the individual machinery from each other in terms of safety and using them as independent safe units. As long as an event on one unit does not lead to a hazard on the adjacent machinery, no new CE marking is required for the entire system.


Our Service: We advise you right from the layout phase of your system. We analyze the planned interlinking and develop concepts for the safety-related decoupling of the individual machinery. We show you ways in which you can legally avoid the manufacturer obligations for an assembly by using intelligent interface design. If decoupling is not technically feasible, we efficiently guide you through the necessary conformity procedure.

Our Working Method at a Glance

LEGAL DEFINITION

We clarify the legal situation at the interface and assess whether your machinery or plant is considered an assembly of machinery. By clearly defining the limits of manufacturer responsibility, we minimize the risk of you unknowingly assuming the obligations of your suppliers.

SYSTEMIC REASSESSMENT

We carry out the new risk assessment and validation of the common safety technology. With a view to the overall system, we consolidate the data from the individual machinery. Finally, we mathematically prove the reliability of the linked safety functions.

DOCUMENTATION FROM A SINGLE SOURCE

The technical documentation for an assembly of machinery is extensive and complex. We integrate all original documents, test reports, and interface considerations into a coherent set of documentation. We also draw up the new EU declaration of conformity and the overarching instructions for use. This allows your employees to focus fully on commissioning the system.

Your Free Initial Consultation

Clarify the question of responsibility before ordering the first unit of machinery. Are you planning to interlink machinery? We check at an early stage whether the manufacturer obligations for the system can be technically avoided or carry out the necessary conformity procedure for you. We support you from the purchase of components to the declaration of conformity ready for signature.


Contact us for a no-obligation initial consultation. We ensure the complete conformity of your assembly.

Further Components of Machinery Safety

The assessment of an assembly of machinery has a profound impact on the processes of various suppliers. We ensure that all threads come together in one place and that the documentation is complete.

CE Coordination

Many parties are often involved in creating an assembly of machinery. We manage communication between you, your suppliers, and the specialist departments of the future operator. We ensure that all supplier documents are available on time and keep an eye on the progress of the project.

Conformity Assessment

As the assembly is considered a new product, the conformity assessment procedure must be completed in full. We guide you safely through all legal modules. We accompany you from the initial assessment to the final CE marking on the type plate.

Safety Assessment

Integrating an entire system into the production hall often requires measures regarding the building infrastructure or existing machinery and systems on site. We evaluate these interfaces with the surrounding environment and clarify requirements at the site that go beyond the legal and normative requirements.