Old Machines Without CE Marking: Meeting Minimum Requirements

What does CE marking show, and what does it not show?

A sentence we often hear in workshops is: "This machine has no CE marking, so there's nothing we can do." Yet CE marking shows that a machine complied with product legislation at the moment it was placed on the market. It does not show whether the machine is used safely in your workshop today; if the guard on a CE-marked machine has been removed, the CE marking does not protect it.

The text governing use at the workplace is the Regulation on Health and Safety Requirements for the Use of Work Equipment. The regulation does not look at CE marking; it gives the employer these obligations:

Art. 5: Work equipment is suitable for the work to be done. If it cannot be made completely free of hazards, measures are taken to reduce the risk to an acceptable level. The equipment being hired or temporary does not change this obligation.
Art. 6: The employer ensures that work equipment complies with the minimum requirements in Annex I and that this is maintained through maintenance and periodic inspection.
Art. 10 and 11: Operating instructions are prepared and workers are trained before use.

Safety compliance of old machinery therefore starts not with looking for a CE certificate but with assessing the machine point by point against Annex I. In metal and machinery workshops in Bursa, lathes, milling machines and presses decades old are still running; most of these machines can be used safely with the right upgrades.

Safety compliance of old machinery: assessment against Annex I

The main points to check on an old machine under Annex 1 of the Work Equipment Regulation, and the gaps we often see:

Annex I item	Check question	Common gap	Example upgrade
2.1 Control devices	Are controls visible, marked and outside the danger zone?	Worn button labels, pedal attached to the body	Labelling, pedal guard, relocating the control
2.2 Starting	Does the machine start only by a deliberately operated control?	Restarting by itself when power returns	Circuit with undervoltage (no-volt release) protection
2.3–2.4 Stopping and emergency stop	Is there a safe stop, and is an emergency stop accessible where needed?	No emergency stop, or far from the operator	Emergency stop button in an accessible position
2.5 Ejection of parts	Can swarf, broken tools or workpieces be ejected?	Open chuck, no transparent shield	Chuck guard, shield
2.8 Moving parts	Is access to parts such as belts and pulleys, gears, shafts and chucks prevented?	Open belt and pulley, cover removed and not refitted	Fixed guard or interlocked cover
2.9 Lighting	Is the point of operation sufficiently lit?	No machine lamp	Lighting mounted on the machine
2.13–2.14 Maintenance and isolation	Is the isolation device visible and lockable?	No main switch, or it cannot be locked	Lockable main switch, lockout-tagout
2.15 Warnings and markings	Are the warnings needed for safety on the machine?	No warning labels	Warnings and signs in Turkish
2.19 Electricity	Is there protection against direct and indirect contact?	Exposed terminals, missing earthing	Panel cover, earthing measurement

Record the assessment as one page per machine: machine name and serial number, gap identified, risk score, recommended measure, owner and deadline. For guard types, see our machine guards guide.

Example: an old universal lathe

Imagine we are assessing together an old universal lathe in a workshop whose nameplate has no CE marking. The findings and decisions might be:

Open chuck: The rotating chuck and workpiece can be reached by hand. Decision: interlocked chuck guard; the spindle should not turn when the guard is open.
No emergency stop: The operator can stop the machine only from the main switch. Decision: an emergency stop button in a position the operator can easily reach.
Missing belt and pulley cover: The rotating belt at the back is exposed. Decision: bolted fixed guard.
Main switch cannot be locked: During maintenance someone could start the machine by mistake. Decision: a main switch that takes a padlock, and a lockout-tagout instruction.
Ejected swarf: Swarf flies into the operator's face. Decision: transparent shield, plus safety glasses.

After these upgrades the machine is reassessed, operating instructions in Turkish are posted next to it and the operator is trained before use. The machine's age and CE status do not change, but the risks in Annex I have been addressed.

What to check when buying a second-hand machine

The check you do before buying a second-hand machine is cheaper than the upgrade you will do afterwards:

Ask for the user manual in Turkish. Art. 10 of the regulation requires instructions given to workers to be prepared taking into account the manufacturer's user manual in Turkish.
See whether the guards, emergency stop and interlocking devices come with the machine.
Ask for the latest periodic inspection report and maintenance records.
Have the electrical panel and earthing connection checked.
See the machine in place and running; note noise, vibration and leaks.
Put the gaps from the Annex I table in writing at the quotation stage; include the cost of upgrades in the purchasing decision.

Machine upgrade plan step by step

Draw up an inventory. List all machines in the workshop, regardless of age and CE status.
Screen against Annex I. Apply the table above to each machine.
Prioritise. Rank the gaps by their score in the risk assessment; open access to moving parts and the lack of an emergency stop are usually first.
Choose the measure. Think of engineering measures first: fixed or interlocked guards, two-hand controls, light curtains. A gap closed only with instructions and PPE remains a gap.
Implement and verify. After the upgrade, reassess the machine and test the guard's function.
Document. Complete the instructions, training record and maintenance record for each machine.
Plan periodic inspection. Machines such as presses, press brakes, lathes, milling machines and guillotines are listed in Annex III; unless the standard or manufacturer provides for a shorter interval, the maximum interval is 1 year. For details, see our article on periodic inspection intervals.

Note

20 January 2027 and "substantial modification"

The new Machinery Safety Regulation (2023/1230/EU), published in the Official Gazette of 16 October 2026, largely enters into force on 20 January 2027. The regulation defines as a "substantial modification" a change made after placing on the market that was not foreseen by the manufacturer, affects safety by creating a new hazard or increasing an existing risk, and, for example, requires adding a protective device that changes the existing safety control system. The natural or legal person making such a change is regarded as the manufacturer under the regulation and is subject to the manufacturer's obligations (Art. 19). A simple fixed guard and a comprehensive conversion that rebuilds the safety control circuit are not the same thing; for the second type, obtain expert advice on product legislation.

Major maintenance and repair, and periodic inspection

Upgrades sometimes affect the machine's load-bearing structure or electrical installation. Art. 6/A of the Work Equipment Regulation separately governs operations such as welding or cutting on the structure of lifting equipment, and major maintenance and repairs defined in the relevant standards. Under Art. 7, periodic inspection is carried out after major maintenance and repair, when fixed equipment is moved, and before the first use of equipment whose safety depends on installation conditions. The inspection is carried out by authorised persons registered on EKİPNET (the Ministry's register of authorised inspectors), and the contract is approved on İSG-KATİP (the Ministry's online OHS registration system) at least one day before the inspection.

Common mistakes

Thinking "no CE, so not our responsibility". The obligation for use lies with the employer; CE status does not change this.
Fixing guards with wire or tape. Annex I 2.8.1 requires guards to be robust and not easily removed or made ineffective.
Bridging the interlock. Disabling the door switch turns the guard into decoration.
Not keeping instructions next to the machine. Art. 10 of the regulation requires instructions to be kept with the work equipment.
Not rechecking after the upgrade. A new guard may have created a new trapping point.

In our OHS specialist service, we screen the machine inventory against Annex I and prioritise the upgrade plan; with our periodic inspection service, we plan the inspection of upgraded machines. For sector-specific risks, see our metal and machinery sector page, and for product legislation, our article on the Machinery Safety Regulation and CE marking.

Frequently Asked Questions

Is it prohibited to use a machine without CE marking?

What is decisive for use at the workplace is meeting the minimum requirements in Annex I of the Work Equipment Regulation; a machine cannot be considered safe until the gaps against Annex I are closed. For a newly purchased machine, ask the seller for the CE marking and declaration of conformity; this is the seller's and manufacturer's obligation under product legislation.

Can CE marking be obtained retrospectively for an old machine?

CE marking is based on a conformity assessment by the person placing the product on the market or regarded as the manufacturer under product legislation. The workplace's aim is usually not to obtain CE marking but to bring the machine into line with Annex I; for conversions that trigger product legislation, obtain expert advice.

Is periodic inspection needed after an upgrade?

Periodic inspection is required after major maintenance and repair. In addition, machines listed in Annex III are inspected at least once a year unless a shorter interval is provided for.

Which gaps should be prioritised on old machines?

Open access to moving parts, the lack of an emergency stop, the inability to lock out energy and the risk of electric shock usually score highest. The priority is set by the score in the risk assessment.