The regulation and date to keep in mind
The starting point is Regulation (EU) 2023/1230 on machinery. The text published in the Official Journal of the European Union identifies the act and its subject matter; to check a specific provision, consult the Regulation and its annexes rather than relying solely on summaries or commercial materials.
The key date is 20 January 2027, when the Regulation starts to apply. For a project spanning the transition, record when the product is expected to be placed on the market or put into service, and compare that date with the applicable legal text. The date alone does not determine the scope or the procedure that would apply to a particular product.
Treat the timetable as part of the review, not as a substitute for it. Record the expected date alongside the product configuration to which it refers. If that configuration changes, check whether the documentation still describes it. This helps avoid basing a decision solely on the year the project began or the purchase date of a component.
Define the product before calling it a robot
“Robot” is a useful engineering description, but it is not enough to establish a legal classification. The Regulation addresses machinery and its requirements; determining whether a particular piece of equipment or assembly falls within its scope requires consulting the text itself. The product name, its appearance, or the fact that it has an articulated arm does not settle the question on its own.
Record the intended purpose, functions, product limits, working environment, and expected interactions with people or other equipment. Separate what the manufacturer specifies from the conditions introduced by integration. This information helps organise the review, but does not in itself constitute a legal conclusion. If the robot is part of a cell or installation, also document what is integrated and what is modified.
This definition is clearer when the system is described in parts and the relationships between them are explained. Record which equipment is supplied, which elements the integrator adds, and which functions arise only once the assembly is put together. The aim is to have enough information to support the analysis, not to anticipate a classification based on how the system is presented. A functional description and definition of limits help everyone reviewing the project work from the same configuration.
Responsibilities in manufacturing and integration
The review can be organised along the supply chain without assuming that the integrator always has the same legal position. Record who manufactures the product, who markets it under their own name, who incorporates components, and who puts it into service. Assigning responsibilities in a particular case requires consulting the relevant provisions and examining each actor’s role; preserving traceability of decisions, changes, and documents makes that analysis easier.
Do not assume that every adjustment has the same legal consequence. If functions, safeguards, or the configuration change, record what was altered and the reasons for the decision. Characterising a change and identifying any resulting obligations require examination of the facts and applicable legal text; this guide does not determine whether a particular modification is substantial.
For traceability to be useful, link each change to the person who decided on it and to the documentation that explains it. A list of modifications without context may not clarify which part of the product was affected or what considerations informed the decision. Keep the versions of drawings, instructions, and configurations for the different project stages so that the original information can be distinguished from the information describing the integrated assembly.
Conformity assessment and documentation
The first step in an assessment is to identify which provisions apply to the particular product; this guide does not determine its conformity assessment procedure. As a working method, link each identified requirement to the analysis, the measure adopted, and the available evidence. Do not extrapolate a single procedure to all robots or configurations.
The EU declaration of conformity and the CE marking should be reviewed in relation to the provisions applicable to the product. Do not treat them as a stand-alone recipe, independent of the category and the analysis required. A matrix linking each identified requirement to the design measure, documentation, and person responsible can help organise the review.
The matrix makes it possible to see where evidence exists and where work remains, without turning a lack of documentation into an automatic conclusion about the product. It can include the requirement reference, the decision taken, the supporting document, and the person who must complete or review the record. If an issue depends on information that is not yet available, mark it as pending. This makes the status of the analysis visible rather than presenting an open question as resolved.
Harmonised standards: support, not a substitute for analysis
References to standards may form part of the technical review. For each reference, check its identification, publication, and relationship to the applicable act using an official source; do not treat a reference as valid merely because it appears in an old catalogue, presentation, or third-party list. The documentation considered for this article does not make it possible to confirm the status of specific standards.
A technical standard does not replace reading the Regulation or determining the product’s scope. Check which requirements it covers and whether the cited version has been published for the relevant framework. If a reference does not address a particular risk or function, document how that aspect has been handled. Standard selection depends on the product and the official status of each reference, so this guide does not prescribe a universal list.
Record which version was consulted and which part of the analysis it supports. This makes it easier to revisit the reference if the configuration changes or the documentation needs updating. It also prevents a reference used for an earlier product from being transferred without verification to another system with different functions, limits, or integration conditions. A standard can support a justified assessment, but it does not automatically answer every conformity question.
Checklist for a specific robot
To begin, gather the product description, intended purpose, relevant drawings or configuration, manufacturer’s instructions, changes made, and expected date of placing on the market or putting into service. Next, identify which legal categories might be relevant and which actors are involved. Record in writing what information is available and which questions still depend on a technical or legal decision.
Then consult the Regulation on EUR-Lex or in its official publication and, separately, official sources on relevant standards. Note the article or annex under consideration, the standard and its version, available evidence, the conformity assessment procedure identified, and who must close each issue. If significant changes have been made, review their effect before treating existing documentation as valid. The useful outcome is not to claim that “the robot complies” because it belongs to a category, but to maintain a verifiable justification for that product, that configuration, and that point in time.
As a final review, compare the documented description with the product actually expected to be marketed or put into service. Check that the instructions, change records, and technical evidence refer to that configuration and that no issues remain unassigned. If differences appear between what was planned and what was installed, incorporate them into the analysis rather than assuming the initial documentation covers them. This check keeps the focus on the particular product and makes explicit which decisions still require attention.