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The Machinery Safety Regulation and the CE Mark

Machinery safety regulation guide: checking the CE mark, declaration of conformity, Turkish manual and technical file when buying; the 20 January 2027 change.

  • Published:
  • 10 min read
  • Bursa SİSTEMER OSGB Technical Team

In brief

When a new machine is placed on the market, the manufacturer prepares the technical file, draws up the declaration of conformity, affixes the CE mark and supplies instructions for use in Turkish. The Machinery Safety Regulation (2023/1230/EU) published on 16 October 2026 largely enters into force on 20 January 2027, replacing the 2009 regulation. The employer as user checks these documents on delivery, and installs, uses and has the machine periodically inspected safely under the Work Equipment Regulation.

The machinery safety regulation: which one, and from what date?

In Turkey, the design and manufacturing requirements for new machinery are set by the Ministry of Industry and Technology's machinery safety regulation. As of November 2026, two texts are on the agenda together:

  • Machinery Safety Regulation (2006/42/EC): Published in Official Gazette No. 27158 of 3 March 2009, and applies until 20 January 2027.
  • Machinery Safety Regulation (2023/1230/EU): Published in Official Gazette No. 33402 of 16 October 2026. Some articles entered into force on the date of publication, and the other provisions enter into force on 20 January 2027; the old regulation is repealed on that date (Art. 51 and 52).

The transitional provision (provisional Art. 1) states that machinery placed on the market in conformity with the old regulation before 20 January 2027 may not be prevented from being made available on the market, and that EC type-examination certificates issued under the old regulation remain valid until they expire. The practical consequence is this: for a machine you order today and take delivery of in 2027, ask the supplier which regulation the declaration of conformity refers to and whether this is consistent with the machine's date of placing on the market.

The logic of both texts is the same: responsibility lies with the manufacturer, and the user buys the right machine and uses it safely. Below we explain what to look at from the perspective of the employer as user.

The boundary of responsibility between manufacturer and user

Under Art. 11 of the new regulation, the manufacturer designs and manufactures the machine in accordance with the essential health and safety requirements in Annex 3; before placing it on the market, prepares the technical file in Annex 4, carries out or has carried out the conformity assessment, draws up the EU declaration of conformity and affixes the CE mark. The importer (Art. 14) may not place the machine on the market without checking that these steps have been fulfilled; the distributor (Art. 16) is also obliged to verify the CE mark, the declaration of conformity and the instructions for use in Turkish.

The obligations of the employer as user arise from the Regulation on Health and Safety Requirements for the Use of Work Equipment:

Who?Main responsibilityBasis
ManufacturerSafe design, technical file, conformity assessment, declaration, CE, Turkish instructionsMachinery Safety Regulation Art. 11
ImporterNot placing non-conforming machinery on the market, checking documentsArt. 14
DistributorVerifying the presence of CE, declaration and Turkish instructionsArt. 16
Employer as userChoosing a machine suited to the work, not creating additional hazards, meeting minimum requirements, maintenance and periodic inspectionWork Equipment Regulation Art. 5 and 6
Person making a substantial modification to a machineIs deemed the manufacturer and assumes the manufacturer's obligationsMachinery Safety Regulation Art. 19

The last row is especially important for metal and automotive supply plants in Bursa that carry out line modernisation. Adding robot feeding to a machine afterwards or changing its safety control system may count as a substantial modification if it creates a new hazard or increases the existing risk; the person making this change is regarded as the manufacturer for the purposes of the regulation. Annex II of the old regulation also states clearly that the EC declaration of conformity relates only to the machine in the state in which it was placed on the market and does not cover components added later or subsequent operations by the end user.

The CE mark and machine nameplate on delivery

The CE mark on machinery must be visible, legible and indelible on the machine; if the nature of the machine does not allow this, it is affixed to the packaging and the accompanying documents (new regulation Art. 25). If a notified body was involved in the conformity assessment, that body's identification number is also next to the CE mark.

Also look for the following on the machine or its nameplate (Art. 11/5 and 11/6):

  • The manufacturer's name or registered trade mark, postal address and website or e-mail address.
  • Model, series or type designation.
  • Year of construction.
  • Batch or serial number, if any.

The serial number on the nameplate must be the same as the number on the declaration of conformity and the invoice. A mismatch may indicate that the declaration was drawn up for another machine.

How to read a declaration of conformity

The declaration of conformity is the document in which the manufacturer declares, under its own responsibility, that the machine conforms to the regulation. It is called the "EC declaration of conformity" in the old regulation and the "EU declaration of conformity" in the new one. Under Annex II of the old regulation, the declaration contains the following information:

  1. The business name and full address of the manufacturer or its authorised representative.
  2. The name and address of the person authorised to compile the technical file.
  3. A description of the machine with its generic denomination, function, model, type, serial number and commercial name.
  4. An express statement that the machine fulfils the relevant provisions of the regulation and, where appropriate, a reference to other legislation.
  5. Where applicable, details of the notified body that carried out the type examination or approved the quality system.
  6. The harmonised standards and other technical specifications used.
  7. The place and date of the declaration and the identity and signature of the person authorised to sign it.

In the new regulation, the content of the declaration is set out in Annex 5 Part A; if the declaration is drawn up in another language, a Turkish translation is attached (Art. 22/2). The manufacturer may supply the declaration with the machine or indicate in the instructions for use the web address or a machine-readable code through which the declaration can be accessed; a digital declaration remains accessible online for at least 10 years (Art. 11/9).

The Turkish user manual and the technical file

Section 1.7.4 of Annex I of the old regulation requires all machinery to be accompanied by instructions prepared in Turkish; if the original instructions are in another language, they are supplied with a Turkish translation. Written warnings on the machine must also be in Turkish. The new regulation allows instructions to be supplied in digital format; however, the manufacturer indicates on the machine how to access the instructions, keeps them online in a printable and downloadable form for at least 10 years, and, if the user requests it at the time of purchase, supplies a free paper copy within one month. Instructions and safety information must be in Turkish, clear and easy to understand (Art. 11/7 and 11/8).

When receiving the manual, look not only at its presence but at its content: installation and fixing requirements, safe use and maintenance steps, residual risks and the PPE to be used, noise emission values and training needs. For example, if the A-weighted emission sound pressure level at the workstation exceeds 70 dB(A), this value must be stated in the manual.

The technical file, on the other hand, is often misunderstood. The technical file is the document the manufacturer prepares to prove the machine's conformity and keeps available for the market surveillance and inspection authority for at least 10 years (Art. 11/3); it is not a document that must be handed over to the user. What needs to be in your file as the user is the CE mark, the declaration of conformity and the Turkish instructions.

CE checklist when buying a machine

  1. Check under which regulation the machine was placed on the market and the date of the declaration.
  2. See that the CE mark is permanently on the machine.
  3. Compare the serial number on the nameplate with the declaration and the invoice.
  4. Check that the declaration has a signature, date and the standards applied written on it.
  5. Receive the Turkish instructions for use; if digital, record the access address.
  6. Give the installation, fixing and energy connection requirements in the manual to the installation team.
  7. At commissioning, test that the guards, emergency stop and interlocked covers work.
  8. Update the risk assessment for the new machine.
  9. Give operator training at the machine and record it.
  10. If the machine falls within the scope of Annex III, add it to the periodic inspection schedule.

The employer's job does not end after installation

A CE-marked machine is not automatically safe where it is installed. Under Art. 7 of the Work Equipment Regulation, periodic inspection of equipment whose safety depends on installation and assembly conditions is carried out by authorised persons after installation and before first use. Under Annex III, machine tools such as presses, press brakes, guillotines, lathes and milling machines are inspected once a year unless the standard sets a shorter interval; for details, see our article on periodic inspection intervals for work equipment.

A new machine is also a new source of hazard: a change of technology and equipment requires the risk assessment to be renewed regardless of its validity period. Removing or disabling guards afterwards undermines the safety concept on which the CE is based; we covered this topic in our article on machine guards. Machine documents may also be requested in supplier audits by OEM customers; for preparation, see our article on preparing for a supplier OHS audit.

When new machines are commissioned, Bursa Sistemer OSGB plans the risk assessment under our OHS specialist services and the initial and annual inspections under our periodic inspection service. For risks specific to the metal sector, see our metal and machinery page, and for tracking inspection dates, the OHS calendar tool.

Frequently Asked Questions

Does a CE-marked machine also need periodic inspection?

Yes. The CE mark shows the machine's conformity at the moment it was placed on the market. Machines in Annex III undergo periodic inspection by authorised persons after installation and once a year unless the standard sets a shorter interval.

Is a user manual only in English acceptable?

No. Both the old and the new regulation require instructions for use to be in Turkish. If the original instructions are in another language, a Turkish translation is supplied with them.

If we modify the machine, does the CE remain valid?

The declaration of conformity covers only the machine in the state in which it was placed on the market. Under the new regulation, a person who makes a substantial modification that creates a new hazard or increases the risk is deemed the manufacturer and assumes the manufacturer's obligations.

What about machines bought before 20 January 2027?

Machinery placed on the market in conformity with the old regulation before this date may not be prevented from being made available on the market. EC type-examination certificates issued under the old regulation also remain valid until they expire.

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Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.

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