Rank: Guest 
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I understand that companies supplying machinery must CE mark it and provide either a certificate of conformity or a certificate of incorporation with the equipment.
If you are a company buying the equipment and then incorporating it into another machine because YOU are going to use it for manufacturing (i.e. not supply it to anyone else), do you still have to assess and CE mark the final machine?
Hope this makes sense!
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Rank: Super forum user 
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gkelly,
I did have to check this out at my previous employer so:
To the best of my knowledge, officially YES.
Sorry that probably does not help.
Mind as long as it complies with PUWER98 etc. would there really be a problem?
I do know of some people who specialise in this so can officially find out or put you in touch if you need something actually CE marking.
No link to me I'm just a previous satisfied customer.
Probably best to do by PM so as not to break any forum rules?
HTH
Paul
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Rank: New forum user
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Hello,
this may not be the answer you are looking for but-
I was recently reviewing the Dec 2009 issue of the Rospa Journal, on page 15 the following artical which may impact on the way you go forward:
" Procedures for safety approval of machinery manufacture and supply"
"The revised European Union Machinery Directive comes in to force on the 29th Dec,it transposes into the UK legislation as the Supply of Machinery ( Safety) regulations 2008 (SI 2008/1597)"
There are 3 methods of assessing whether machinery meets the regulations, which depends mostly on whether the machinery is categorised as requiring special assessment (typically machines involved in sawing,moulding,safety critical movement etc)
Self assessment - which is allowed for less safety critical machinery
EC Type Examination -a product not manufactured wholly in accordance with the new standards must be assessed by a "notifyed body" appointed by by the department for Business Inovation and Skills
Full Quality Assurance - must be used where machinery is categorised as requiring special assessment
I would suggest a review of the legislation, read the full artical available via Rospa, hope this is of a benifit
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Rank: Forum user
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Afternoon all,
first one on the new directive. Firstly, is it a machine as defined? if it is machinery, is it on the list of equipment that is excluded from the directive? (eg. medical, automotive, nuclear where failure may lead to release of radiation etc)
is it a component?, is it a spare part?, is it being supplied? etc.
best bet - go to OPSI, or BERR web pages and download a copy of the SMR, ascertain whether you need a DoC, or DOI before going to a notified body. it could be the item you wish to use is already being used in an EU compliant machine.
yours aye
db
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Rank: Guest
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Thanks everyone for their contributions so far.
DB
It is a machine and it's not excluded. The company buys specific machine components (with EC certificates of incorporation) and then puts them together to create a manufacturing processing line.
They have been making the manufacturing lines they need in this way for many years. They supply them to themselves.
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Rank: Super forum user
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gkelly,
Following your last post, giving greater detail, I would almost certainly say in this case you will need to CE mark.
Especially if the unit goes outside the factory it was built even if in the same co.
As you suggest the equipment is bespoke, then you may well need to utilise a notified body.
There is something on the BERR info explaining this, but don't have my copy to hand at the mo.
HTH
Paul
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Rank: Forum user
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As I understand CE marking, it is required (with documentary evidence) for any equipment being marketed within the EU.
However, the mark only means that the equipment complies with certain standards and you still need to assess it as the safety of equipment can be improved, depending on how you use it.
If you are incorporating a piece of equipment within other equipment, then you must assess the whole thing to ensure it is safe to use.
I believe it then only needs a further CE mark if you are then selling on the equipment.
Regards fsp
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Rank: Super forum user
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gkelly,
Just checked, see the following link.
If the equipment is as you describe, then it is a machine and comes under the "supply of machinery regs" and even if for your own use MUST be CE marked and a technical file may eventually be required but can ONLY be requested by HSE.
Thus it MUST comply with all relevant legislation (EMC, Low Voltage, Machinery etc) and thus harmonised standards.
Beware though of the transition between EN954/13849/62061.
That is apart from PUWER98 et al.
Link:
http://www.berr.gov.uk/files/file52968.pdf
See page 6 for definition of machinery.
See pg 10 for definition of manufacturer which clarifies the requirement.
HTH
Paul
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Rank: Forum user 
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As i understand it all new machinery or old machinery that you change the performance or function of needs to be CE marked.
If you are incorporating it into a machine or as part of a line where the machines function together as one, then the line needs to be CE marked etc.
But, like everything else, just because it is CE marked doesn't mean that it is safe, so a puwer assessment needs to be carried out if you are using it at your work.
So to your original question, my answer would be yes, it needs CE marking IMO
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Rank: Forum user
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morning again all,
just checked the 08 regs refer to part I 3.(1)(a)(ii) - you will need to mark it.
Db
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Rank: Guest
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My continued thanks for all the advice given on this question.
Having spent sometime today reading the 1992 (amended) and 2008 Regs as I understand it we should have been CE marking similar processing lines we have installed in the past too.
Since we have not done this and the new Regs revoked the 1992 Regs and only apply to machinery placed on the market or put into service from 29/12/09, can we (going by the letter of the law) limit our assessment on any lines put in before 29/12/09 to comparison with PUWER and avoid retrospective CE marking?
I accept we now need to CE mark any new line we install on site.
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Rank: Super forum user
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I would suggest that this is the case.
Every Technical Inspector I have had discussions with at HSE (not very many mind!) has always pushed PUWER.
I was at a lecture given by one, where a “member” of the audience had been prosecuted by HSE under PUWER even though the equipment was CE marked, they did NOT follow the CE route.
Quote: “PUWER is easier to prove”
Even if equipment is CE marked, it still has to be assessed against PUWER requirements as both issues are separate legislation, i.e. machinery directive etc. & use of work equipment directive.
I would guess that if you comply with PUWER then you are "now" doing what is reasonably practicable.
Not saying you were right before mind! ;-)
Remembering that the best designed but poorly installed CE marked piece of machinery could still be dangerous and not comply with PUWER.
I have "heard" that HSE will push PUWER first.
Retrospective CE marking is difficult as it must go so far back through the design process, you may as well prepare the technical file there and then as you go!
Believe me I tried it! Well I was VERY VERY involved, it is not something one person can easily do with machinery due to the diverse range of skills required.
CE marking a machine for compliance with the new approach directives is enshrined really in the machine concept right from the start, it is not something that you can add on later really, well not in my experience of doing it anyway!
HTH
Paul.
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Rank: Forum user
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Morning all,
My input onn the above again.
I think it may be worth mentioning why the HSE may be leaning towards puwer98 over SMR. PUWER is for when the machine is being used i.e. the employer wishes the employee to operate the machinery under the scope of HASAW and subsiquent legislation. SMR refers to the product being produced i.e. that the machine when leaving the works has been designed and tested in such a way that it is not inherently dangerous, what the purchaser does with the machine once (s)he becomes the owner is up to them.
this can get realy interesting when dealing with equipment that comes from regions where in the case of US equipment the onus lies primarily with the manufacturer at all times (try to get clarification on a point from one and youll see what I mean), or SE Asia where the ethos is one of here is the kit now use common sense and you wont get injured (they were completely bewildered by SMR as they thought it was given that you would not stand under a fully loaded 300t SWL Lifting Frame!).
yours aye
Db
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