Supply of Machinery (Safety) Regulations 2008, UK wide
Machinery CE and UKCA Marking
Conformity marking is a supply duty rather than a user duty. AL23 Safety supports manufacturers, importers and in-house engineering teams through machinery conformity under the Supply of Machinery (Safety) Regulations 2008, for clients UK wide. The duty lands on people who do not expect it, most often the end user who linked three machines into a production line.
What is CE and UKCA marking for machinery?
A declaration that the work has been done, not a sticker you buy
The mark is the visible end of a process rather than the process itself. Before machinery is placed on the market or put into service, the responsible person must identify the applicable product regulations, carry out a machinery risk assessment, design against the essential health and safety requirements, compile a technical file, complete the correct conformity assessment route, sign a declaration of conformity, supply instructions in English and only then affix the marking.
The mark is therefore a legal claim by a named person that the machine meets the essential health and safety requirements and that evidence exists to prove it. Affixing it without the file behind it is an offence rather than a paperwork slip.
Who needs one
Whoever places the machinery on the market or puts it into service
- Manufacturers of machinery supplied into the Great Britain market, whether sold, hired or given away.
- Importers and distributors bringing machinery in from outside Great Britain.
- Anyone assembling separate machines into a line controlled to function as an integral whole. That assembly is new machinery and the assembler takes on the manufacturer duties for it.
- Anyone substantially modifying an existing machine. HSE's position is that a modification creating a significantly new hazard or increasing an existing risk can produce, in effect, a new machine with a new responsible person.
- Businesses building machinery for their own use, since putting machinery into service is caught as well as selling it.
- Suppliers of partly completed machinery. They issue a declaration of incorporation and assembly instructions rather than a declaration of conformity. No mark is affixed to it.
The regulations that apply
Your legal framework, in plain terms
The Supply of Machinery (Safety) Regulations 2008 remain in force across the UK and were not revoked after Brexit. They sit alongside the Health and Safety at Work etc. Act 1974 and are enforced for workplace machinery by HSE. They place duties on the responsible person, meaning the manufacturer or whoever else places the machinery on the market. The Provision and Use of Work Equipment Regulations 1998 are the counterpart duty on the user. That is a separate matter, covered on our machinery safety, PUWER and LOLER page.
Essential health and safety requirements
Machinery must satisfy the requirements in Schedule 2 to the Regulations, covering guarding, controls, stability, energy supplies, ergonomics, noise, vibration and information for use.
Risk assessment
The responsible person must determine the hazards that apply to the machine, then design and build against that assessment. It is the mechanism by which the essential requirements are met.
Technical file
A file evidencing conformity must be compiled and kept available to the enforcing authority. Failing to supply it on request is itself a breach.
Conformity assessment
Most machinery can be self assessed by the responsible person. The Regulations list higher risk categories, including certain saws, presses and vehicle servicing lifts, where an approved or notified body must be involved.
Declaration and marking
A signed declaration of conformity must accompany the machinery. The CE or UKCA marking is affixed only once everything above is complete. Instructions must be supplied in English for machinery placed on the GB market.
Harmonised and designated standards
Standards are voluntary. You may meet the essential health and safety requirements by any route you can defend. Build to a standard on the published list and you gain a presumption of conformity with the requirements that standard covers, which shifts the burden of proof in your favour.
In Great Britain the list is the designated standards published by government. In the European Union the equivalents are the harmonised standards listed in the Official Journal. Mostly they are the same documents under different labels. The ones doing the heavy lifting for machinery are BS EN ISO 12100 for risk assessment plus BS EN ISO 13849-1 or BS EN 62061 for safety related control systems. Check the current designated standards list before relying on a presumption of conformity, since entries are added and withdrawn.
The marking position now and the change in January 2027
CE marking continues to be recognised in Great Britain with no end date, under legislation in force from 1 October 2024. Manufacturers may use either UKCA or CE for machinery placed on the GB market. UKCA is an alternative rather than a requirement. No deadline is pushing you to switch. Northern Ireland follows EU rules under the Windsor Framework. CE marking applies there, with UK(NI) alongside CE where a UK body carries out the assessment.
The next change is dated. The draft Supply of Machinery (Safety) (Amendment etc.) and the EU Machinery Regulation (Enforcement etc. in Northern Ireland) Regulations 2026 were debated in the Commons on 30 June 2026 and are due to come into force on 20 January 2027. They confine the 2008 Regulations to England, Wales and Scotland. New regulations 12A and 12B open a route onto the GB market for machinery conforming to EU Machinery Regulation 2023/1230, subject to the essential health and safety requirements and English-language documentation. A new regulation 12C creates a qualifying goods route for Northern Ireland machinery into GB. EU Regulation 2023/1230 applies directly in Northern Ireland from the same date. Machinery already compliant with the 2008 Regulations has transitional protection. If you are specifying machinery for delivery in 2027, that date belongs in the contract discussion now.
What the service covers
From who holds the duty to a file you can defend
- Identification of the responsible person, which on integration projects is rarely who the parties assumed.
- Scope determination, separating machinery, partly completed machinery and assemblies of machinery.
- Gap assessment against the essential health and safety requirements, requirement by requirement.
- Machinery risk assessment structured to BS EN ISO 12100, covering every lifecycle phase including setting, cleaning and fault finding.
- Safety related control functions and the performance level or safety integrity level claimed for them, linked to our functional safety and SIL assessment work.
- Standards selection against the current designated standards list, claiming the presumption of conformity only where it genuinely applies.
- Technical file structure, contents and retention, plus review of the instruction manual for required content and English-language supply.
- Declaration of conformity content, the correct signatory and whether an approved or notified body has to be involved in the assessment route.
- Second hand and imported machinery documentation, where files are usually incomplete, plus substantial modification assessment where you have changed a machine.
Our process
Find the responsible person, then build the evidence
- 01
Establish the duty
We work out who is placing the machinery on the market, what the product is in regulatory terms and which regulations bite.
- 02
Assess the machine
We assess the machinery against the essential health and safety requirements and the standards you rely on, on site where possible.
- 03
Build the evidence
We map what exists into a technical file structure and specify what is missing, in the order it needs producing.
- 04
Close the gaps
We support the engineering changes, the risk assessment rewrite and the instruction manual, then review the declaration before anybody signs it.
- 05
Handover
We leave you with a file you can defend and a process your engineers can repeat on the next machine.
What you get
A file that survives an enforcing authority's scrutiny
- A conformity gap report with each finding tied to a specific essential health and safety requirement.
- A technical file index showing what exists, what is missing and who is producing it.
- A machinery risk assessment in a format that survives scrutiny from an enforcing authority or a customer's auditor.
- A reviewed draft declaration of conformity for your signature.
- A written position on the marking route, covering CE, UKCA and the January 2027 changes as they affect your product.
What we need from you
Drawings, documents and who is selling what to whom
- General arrangement drawings plus electrical and pneumatic schematics for the machine or line.
- Existing risk assessments, declarations and supplier documentation for bought-in modules.
- The instruction manual in whatever state it is currently in.
- Access to the machine, ideally running and during a maintenance task.
- The commercial position, meaning who is selling what to whom. That determines who holds the duty.
Why AL23 Safety
We sequence the gaps so the machine can still ship
Accountable
Where a machine on your floor is marked but the file does not exist, we will tell you plainly. We do not sign off paperwork to make a delivery date.
Expert and chartered
We scope the work, appoint the right specialist where an approved body or a control system engineer is needed and turn the results into an action plan you can actually deliver. AL23 is not itself an approved body. The declaration is always signed by you as the responsible person.
Practical, not just compliant
We sequence the gaps so the machine can be shipped or commissioned, rather than presenting one undifferentiated list of everything wrong.
UK wide
We support machinery conformity across the UK, from single special purpose machines to full line integrations, alongside our wider manufacturing health and safety work.
Find out who actually holds the duty
A short call usually settles it
Tell us what the machine is, who built it and who is supplying it to whom. That is usually enough for us to say whether you are the responsible person and what follows from that.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usYes. CE marking continues to be recognised in Great Britain with no end date, following legislation in force from 1 October 2024. You may use either CE or UKCA for machinery placed on the GB market. UKCA is an alternative rather than a requirement and there is no cut-off date forcing a change.
Very possibly. Where separate units are arranged and controlled to function as an integral whole, the assembly is machinery in its own right. Whoever put it together carries the manufacturer duties for it. That means a risk assessment covering the interfaces, a technical file for the line, a declaration and a mark. The individual machines keeping their own marks does not discharge that.
As a minimum, the general arrangement and circuit drawings, the risk assessment and how each hazard was addressed, the standards applied, design calculations, test results, the instruction manual and the declaration of conformity. It must exist before the machine reaches the market and be available to the enforcing authority on request.
No. This is the most common misunderstanding we correct. Conformity marking is a supply duty discharged before the machine reaches you. PUWER is the user duty. It applies to the machine as installed, with your people, your interlock keys and your maintenance regime. A correctly marked machine can fail PUWER on the day it is commissioned.
The amendment due in force that day confines the Supply of Machinery (Safety) Regulations 2008 to England, Wales and Scotland. It opens a route allowing machinery conforming to EU Machinery Regulation 2023/1230 onto the GB market, subject to the essential health and safety requirements and English-language documentation. That Regulation also applies directly in Northern Ireland from the same date, with transitional protection for machinery already compliant with the 2008 Regulations.
Cost is driven by the complexity of the machine, whether a technical file exists already, how many safety functions need assessing and whether an approved body has to be involved. Reviewing a supplier's file is a small job. Building one retrospectively for a line assembled five years ago is not. Send drawings and a description and we will scope it honestly.
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