Every machine sold into the European Union has to carry a CE mark. What varies enormously is the paperwork behind that mark. This page explains what a compliant delivery looks like, and where the gaps usually appear when a machine is unpacked on the buyer’s floor.
What the mark legally commits the supplier to
CE marking is the manufacturer’s declaration that the machine meets the applicable EU directives. For packaging and converting machinery, three usually apply:
- Machinery Directive 2006/42/EC — covers mechanical hazards, guarding, controls, emergency stops and stability.
- EMC Directive 2014/30/EU — covers electromagnetic emissions and immunity, relevant as soon as the machine has drives and inverters.
- Low Voltage Directive 2014/35/EU — applies to equipment operating in the 50–1000 V AC range, which covers most packaging lines.
The mark itself is a sticker. The legal weight sits in the documents that accompany it.
The document set to expect
- Declaration of Conformity (DoC) — one page, signed, naming the machine, the directives, the harmonised standards applied and the authorised representative.
- Technical file — risk assessment, drawings, electrical schematics, component list, calculation notes. Buyers rarely receive the full file, but the supplier must be able to produce it on request.
- Instruction manual in the language of the destination country — not English by default. This is one of the most common non-conformities.
- Nameplate — manufacturer, model, serial number, year, voltage, frequency, power, weight.
The harmonised standards most often cited are EN ISO 12100 for risk assessment and EN 60204-1 for electrical equipment of machines. If a DoC cites neither, ask why.
Five gaps that show up at installation
- DoC arrives after the machine. Customs may release the container, but a notified body or a customer audit will ask for the document first.
- Guarding removed for shipping. Interlocks are disconnected so the machine fits the crate, and nobody reconnects them.
- Emergency stop circuit bypassed. Often done during commissioning to speed up testing, never restored.
- Manual language mismatch. The machine ships to Spain with an English manual, or with a machine-translated one that no operator can follow.
- DoC signed by a trading company that is not the manufacturer named on the nameplate, with no mandate to act on the manufacturer’s behalf.
What to check before the machine leaves
- DoC signed and dated, machine serial number matching the nameplate.
- Guards and interlocks functioning during the factory acceptance test.
- Manual in the destination language, printed or as a file you can print.
- Electrical drawing matching what is actually in the cabinet.
At arrival, walk the machine before signing the delivery note: guards in place, e-stops tested, nameplate data matching the order.
A note on scope
CE marking is a self-declaration process for most packaging machinery, which means the quality of the file depends entirely on the supplier’s discipline. This page describes what a complete delivery looks like; it is not legal advice. Where a machine is being integrated into an existing line, responsibility for the final assembly usually sits with the integrator.