CNC machine or machine tool
Machine tools have dedicated safety standards, guarding and control system requirements, and networked controllers that bring the CRA in; presses sit on the EU high-risk list.
Regimes engaged, per market
Standing when pasted with its name: mapped
What the file has to hold
- Technical file (10 of the 15 regimes, including Machinery Reg, CRA, EMC)
The technical documentation: design, drawings, bill of materials, the standards applied, the conformity assessment route, and the evidence that the requirements are met. Kept for the retention period the regime sets, typically ten years from the last unit placed on the market. - Declaration of conformity (8 of the 15 regimes, including Machinery Reg, CRA, EMC)
The EU or UK declaration of conformity (or the food-contact declaration of compliance), signed by the manufacturer, naming the product, the legislation and the standards, and the notified or approved body where one was involved. - Risk assessment (Machinery Reg, CRA, UK Machinery, OSHA/ANSI)
The documented hazard identification and risk assessment for the product across its lifecycle, updated when the design, the use or the field data changes. - Test reports (8 of the 15 regimes, including Machinery Reg, CRA, EMC)
Test reports from an accredited or accepted laboratory against the standards the technical file names, tied to the exact model and revision tested. - Labelling and instructions (11 of the 15 regimes, including Machinery Reg, CRA, EMC)
Markings on the product and packaging (conformity mark, identification, warnings, manufacturer and importer details) and the instructions and safety information in the language of the market. - Traceability records (Machinery Reg, UK Machinery)
Batch, lot or serial identification on the product, the records that tie a unit to its production and supply chain, and UDI where the device rules require it. - Third-party certificate (OSHA/ANSI, UL/NRTL)
A type-examination certificate, notified or approved body certificate, or listing from a recognised laboratory, with the scope and the expiry. - FCC authorisation (FCC Part 15)
The FCC Supplier's Declaration of Conformity, or the grant of certification with the FCC ID, and the compliance statement in the manual. - Substance declarations (RoHS, REACH, UK RoHS, UK REACH)
Safety data sheets for mixtures and supplier material declarations for articles: the trail that shows what is in the product against the restricted lists. - Registrations (WEEE, UK WEEE)
Producer, establishment, device or product registrations in the databases the regime names (EUDAMED, EPREL, CPNP, the WEEE and battery registers, FDA registration and listing). - Cybersecurity documentation (CRA)
The software bill of materials, the vulnerability handling and disclosure policy, the stated support period, and the secure update mechanism, as the connected-product rules expect.
Duties that continue after sale
- Market surveillance cooperation (Machinery Reg, UK Machinery)
Answer an authority's request for the technical file, the declaration and the supply chain within the time it sets, in a language it accepts, and cooperate with any corrective measure it requires.
Licensed controls: Machinery Reg Art.10 · Machinery Reg Art.43, 44 - Incident reporting (CRA)
Notify the authority when a product has caused, or could cause, an accident, injury or serious incident, through the channel the regime names (the Safety Business Gateway, the MHRA, the FDA, SaferProducts.gov) and within its clock.
Licensed controls: CRA Art.14, 16 - Recall readiness (Machinery Reg, UK Machinery)
Be able to identify affected units, reach the customers who hold them, issue a notice in the required form, offer the remedy the rules require, and show the authority the effectiveness of the action.
Licensed controls: Machinery Reg Art.45, 46 - Traceability records (Machinery Reg, CRA, UK Machinery)
Keep the records that identify which batch went to which customer, and the identification on the product that lets a unit be traced back, for the retention period the regime sets.
Licensed controls: Machinery Reg Art.17, 18, 19 · CRA Art.23 - Security updates and vulnerability handling (CRA)
Provide security updates for the stated support period, run a coordinated vulnerability disclosure process, and report actively exploited vulnerabilities and severe incidents within the reporting clock.
Licensed controls: CRA Art.13, Annex I · CRA Art.54, 55 - Producer responsibility for take-back (WEEE, UK WEEE)
Keep producer registrations current in each market, report the quantities placed, and finance collection and treatment of the product and its batteries at end of life. - Substance list watching (RoHS, REACH, UK RoHS, UK REACH)
Track additions to the restricted and candidate substance lists, re-check supplier declarations against them, and update customer communication and labels when a substance in the product is added.
This week
Check the control system performance level claimed in the file against the standard the risk assessment names.
What holding one is evidence for
Requirement text and evidence artefacts from a human-verified corpus. Data licensed to Conformity Sheet by The Art of Service Pty Ltd, revocable, non-transferable.
Machinery Reg: EU Machinery Regulation (Regulation (EU) 2023/1230)
Machinery Reg Art.10 Obligations of manufacturers of machinery and related products (Article 10)Article 10 imposes the central manufacturer obligations: (a) ensure the EHSR Annex III compliance + carry out risk assessment per Annex III 1; (b) draw up the technical documentation per Annex IV + retain for 10 years; (c) carry out the applicable conformity assessment procedure (Article 25); (d) draw up the EU declara...
Common gap: Machine placed without Annex IV technical documentation
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.8, 9 Essential health and safety requirements and sectoral coordination (Articles 8-9 + Annex III)Article 8 imposes the central requirement: machinery and related products placed on the market or put into service shall comply with the essential health and safety requirements (EHSR) set out in Annex III. Annex III covers: 1.1 general principles of safety integration (eliminate / reduce / inform), 1.1.9 protection ag...
Common gap: Product placed without Annex III EHSR compliance file
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.21, 22 EU declaration of conformity and EU declaration of incorporation (Articles 21-22)Article 21 requires the manufacturer to draw up the EU declaration of conformity per Annex V before placing on the market or putting into service. By drawing up the EU DoC the manufacturer assumes responsibility for compliance. The EU DoC is kept for 10 years. Article 22 sets the EU declaration of incorporation for par...
Common gap: Machine placed without EU DoC
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.23, 24 CE marking principles and affixing rules (Articles 23-24)Article 23 applies the general principles of the CE marking per Regulation (EC) 765/2008 to machinery. Article 24 sets the affixing rules: CE marking visible, legible, indelible, affixed before placing on the market; for high-risk products subject to Annex I requiring notified-body assessment, the NB identification num...
Common gap: CE marking on partly completed machinery
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
Machinery Reg Art.25 Conformity assessment procedures (Article 25)Article 25 sets the conformity assessment routes. (1) Default (non-Annex-I): manufacturer self-assessment via Annex VIII (internal production control) + Annex IV technical documentation. (2) Annex I high-risk products: mandatory third-party involvement. The manufacturer chooses among Annex IX (EU type-examination + pro...
Common gap: Annex I (Class B) product self-declared without notified-body involvement
EU Machinery Regulation (Regulation (EU) 2023/1230) on compliance.theartofservice.com
CRA: EU Cyber Resilience Act
CRA Art.2 Scope - Products with Digital Elements (Article 2)Article 2 sets the scope: the Regulation applies to PDEs whose intended purpose or reasonably foreseeable use includes a direct or indirect logical or physical data connection to a device or network. Carve-outs include: products covered by sector-specific Union law (medical devices under MDR/IVDR, motor vehicles under ...
Common gap: Applying CRA to a medical-device PDE that is in fact governed by MDR cybersecurity requirements (sectoral carve-out applies)
EU Cyber Resilience Act on compliance.theartofservice.com
CRA Art.13, Annex I Manufacturer obligations and essential requirements (Article 13 + Annex I)Article 13 imposes the central manufacturer obligations: (1) design, develop and produce the PDE to ensure an appropriate level of cybersecurity based on the cybersecurity risk assessment in Article 13(2); (2) Article 13(6) due diligence on third-party components integrated in the PDE including FOSS dependencies; (3) A...
Common gap: No documented support period or support-period shorter than the product's reasonably expected lifecycle
EU Cyber Resilience Act on compliance.theartofservice.com
CRA Art.31 Technical documentation (Article 31 + Annex VII)Article 31 requires the manufacturer to draw up the technical documentation for the PDE before it is placed on the market and to keep it up to date during the support period. The technical documentation contains the items in Annex VII: general description, design and manufacturing of the product including risk assessme...
Common gap: Technical documentation lacking Annex VII items (e.g. no SBOM, no risk assessment)
EU Cyber Resilience Act on compliance.theartofservice.com
CRA Art.27, 28 Presumption of conformity and EU declaration of conformity (Articles 27-28)Article 27 establishes a presumption of conformity for PDEs that conform with: (a) harmonised standards or parts thereof published in the Official Journal; (b) European cybersecurity certification schemes adopted under (EU) 2019/881 designating the schemes as offering presumption of conformity with all or part of the e...
Common gap: EU declaration of conformity missing Annex V required content
EU Cyber Resilience Act on compliance.theartofservice.com
CRA Art.32 Conformity assessment procedures (Article 32)Article 32 sets the conformity assessment routes: (1) Default PDE - Module A (internal production control - self-assessment by the manufacturer); (2) Important PDE Class I (Annex III Class I) - Module A if the manufacturer applies harmonised standards or European cybersecurity certification, otherwise Module B+C (EU ty...
Common gap: Self-assessment (Module A) for an Important Class II or Critical PDE
EU Cyber Resilience Act on compliance.theartofservice.com
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Build my conformity sheetTreadmill or fitness equipment · Commercial HVAC or refrigeration unit