CE Marking/Technical Files/Declarations of Conformity

CE marking / technical files and declarations of conformity – the plain english explanation

What is a CE mark?
The industry talks about the need for any automated gate to be ‘CE marked’ to comply with the requirements of the European Machinery Directive 98/37/EC, but what exactly does this mean?

In the UK this European Law is implemented by The Supply of Machinery (Safety) Regulations 1992. An automated gate is considered a machine, and as such must meet essential health and safety requirements, these are outlined within a number of standards. The ‘machine’ must be CE marked as proof of compliance with all the relevant standards.

The marking consists of the letters “CE”, affixed visibly, legibly and indelibly to the machine, along with a unique identification number. This must be accompanied by the name of the responsible person (generally the installation company in the case of gates).

It is worth noting that a gate that is not CE marked may possibly be safe but is not legal.

What standards are relevant to an automated gate / barrier?
The general ‘machine’ requirements are laid down in the standard BS EN954.

Additional requirements pertaining to specific areas of the machine are provided for in the standard BS EN 60204 (regarding electrical requirements) and BS EN 13849 (regarding safety related parts of the control system).

Further guidance pertaining to specific machine requirements is detailed in the following standards:

  • BSEN 13241 for automated gates
  • BSEN 12453 safety requirements of powered gates
  • BSEN 12604 mechanical requirements for gates
  • BSEN 12978 requirements for safety devices
  • BSEN 6571 requirements for barrier type parking control equipment

The above regulations also go hand in hand with the requirements under the Consumer Protection Act 1987 which covers both civil and criminal liability.

Who is responsible for CE marking?
CE marking is carried out by the manufacturer in the factory when the machine as a whole is made in the factory, taken to site and plugged in with no additional modifications made to it.

CE marking is more generally made in situ (on site) when initially a manual gate is installed and then transformed into a machine by fitting the relevant automation equipment. In this instance, the installer of the automation equipment has the responsibility to CE mark the gate.

What is the Technical File?
Current guidance states that a technical file must be complied and be provided with the automated gate, what should be contained within the technical file?

  • Overall drawings of machinery together with drawings of control circuits
  • Full detailed drawings and calculations, test reports as may be required in order to check conformity with the essential health and safety requirements
  • A list of the essential health and safety requirements, the transposed harmonised standards applicable, standards adopted, any other technical specifications applied
  • A description of the methods adopted to eliminate hazards presented by the machinery
  • For declaration of conformity with a transposed harmonised standard any technical report on tests conducted by the responsible person or competent body or laboratory
  • A copy of the instructions drawn up in accordance with the provision of information

What is a Declaration of Conformity?
All new gates should be supplied with a Declaration of Conformity. The Declaration of Conformity is a special document which the person responsible for CE marking draws up to say that the product meets all of the requirements of the applicable directives. The Declaration of Conformity must contain:

  • Name and address of the responsible person
  • Description and identification of the machinery
  • A sentence declaring that the machinery fulfils the provisions of the Machinery Directive 2006/42/EC. Where relevant, similar sentences relating to other directives which are applicable or details of the risk assessment
  • A reference to the harmonised standards used (if appropriate) eg: EN 13241-1:2003
  • References to other technical standards and specifications used
  • Signature, date and place of the declaration