Be careful when modifying existing machinery wrt CE marking

In case you want to modify existing machinery, you need to determine whether the modification is a ‘substantial’ modification. If the outcome is that the modification is substantial, the machinery has to be treated as ‘new machinery’, requiring a new declaration of conformity and new CE marking.

Being treated as new machinery be aware that the machinery should comply with the latest regulations. This could lead to other changes to the machinery than just the changes caused by the modification.

The person who carries out the modification, that might be you, becomes responsible for the inherent safety of the machinery. If not delegated he becomes the manufacturer with the corresponding obligations.

To determine whether a modification is substantial a risk assessment of the modification is carried out. When the outcome of this risk assessment is that existing risks are increased, the nature of existing risks is changed, or new risks are introduced, then the modification is substantial.

It is strongly advised to consult the original manufacturer of the machinery in this risk assessment.

In case contacting the original manufacturer is impossible, or the original manufacturer doesn’t cooperate, BKL can assist in this assessment and advise in the steps to be taken to ensure your machinery complies with the latest regulations.

For a (Dutch) explanation of the Inspectorate SZW see: Let op bij aanpassen Machines