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Use this CE marking machinery directive triage tool to decide whether an AMR drive unit is a component, partly completed machinery, safety component or complete machine, then see the CE marking machinery directive 2006/42/EC requirements route, transition date risk and evidence file expected by an OEM buyer.
The calculator output is useful only if it changes buyer-facing evidence. These conclusions turn the tool output into the route memo, declaration pack and engineering actions an OEM usually needs.
| Scenario | Likely route | Decisive question | Next action |
|---|---|---|---|
| OEM buys an AMR wheel module with motor, brake and encoder. | Component or partly completed machinery. | Can the module perform an independent machinery function after installation? | Define integration limits and request a DoI or component evidence pack. |
| Manufacturer sells a full AMR tugger in the EU in late 2026. | Directive 2006/42/EC full machinery route. | Is the first placing on the EU market before 20 January 2027? | Complete risk assessment, technical file, instructions, EU DoC and CE marking. |
| Same AMR platform launches EU series production in 2028. | Regulation (EU) 2023/1230 route. | Do software, autonomous movement or safety functions fall into updated risk categories? | Refresh legal references, high-risk checks and digital documentation. |
| Drive contains STO and is sold as a safety-related subsystem. | Safety component review before claims are published. | What exact safety function, PL/SIL target and diagnostic coverage are claimed? | Validate the claim and check notified body triggers under the selected framework. |
The tool keeps legal claims traceable to official EU sources and flags where public data is not available instead of inventing lead times, fees or certification guarantees.
| Ref | Source | Date basis | Supports |
|---|---|---|---|
| S1 | Directive 2006/42/EC consolidated text EUR-Lex | Consolidated version dated July 26, 2019 | Scope, manufacturer obligations, partly completed machinery, declarations and CE marking duties. |
| S2 | Machinery sector overview European Commission | Accessed July 29, 2026 | Commission transition context, guidance links and Machinery Regulation overview. |
| S3 | Regulation (EU) 2023/1230 on machinery EUR-Lex | Official Journal text published June 29, 2023 | Post-transition framework, Annex I Part A (AI/machine learning safety), digital instructions (10-year availability), and updated economic-operator obligations. |
| S4 | Corrigendum to Regulation (EU) 2023/1230 EUR-Lex | Published July 4, 2023 | Corrected application-date wording used for the 20 January 2027 boundary. |
| S5 | Harmonised standards for Machinery Directive European Commission | Accessed July 29, 2026 | Use of harmonised standards as evidence for essential health and safety requirements. |
| S6 | Guide to application of the Machinery Directive, edition 2.3 European Commission DocsRoom | Edition 2.3, published April 2024; accessed July 29, 2026 | Practical interpretation of machinery, partly completed machinery and technical files. |
| S7 | ISO 3691-4:2023 driverless industrial trucks ISO | Published June 2023; accessed July 29, 2026 | Safety requirements and verification scope for driverless industrial trucks, including AGV/AMR terminology. |
| S8 | IEC 61800-5-2:2016 safety requirements IEC | Publication date April 18, 2016; accessed July 29, 2026 | Functional safety requirements for safety-related power drive systems and drive safety sub-functions. |
| S9 | ISO/TR 22100-4:2018 (IT security and machine safety) ISO | Accessed July 29, 2026 | Guidance on integrating IT security (cybersecurity) into the ISO 12100 risk assessment to prevent safety hazards. |
| S10 | Regulation (EU) 2023/1230 Article 50 (Penalties) EUR-Lex | Official Journal text published June 29, 2023 | Member States must lay down effective, proportionate, and dissuasive penalties for infringements by October 2026, including removal from the market. |
| S11 | Regulation (EU) 2026/1744 digital omnibus on AI EUR-Lex | Published July 24, 2026; enters into force July 27, 2026; accessed July 29, 2026 | AI Act alignment for high-risk AI systems in machinery, including delegated acts for AI safety requirements by 2 August 2028 and interim use of relevant AI Act standards or common specifications. |
| S12 | Regulation (EU) 2023/1230 on substantial modification EUR-Lex | Official Journal text published June 29, 2023 | Formal definition of substantial modification (Article 3) transferring manufacturer obligations, and classification of independent software as a safety component. |

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