CE marking in export: a step-by-step process and timeline plan for machinery and construction products

For a manufacturer shipping products to the European Union market, CE marking is not a choice; it is the legal precondition for placing on the market. The most common mistake is starting the process late: the order is taken, production is planned, and because conformity assessment is left to the very end, the shipment is delayed.

In this article we treat two product families, machinery and construction products, separately, because the path each follows differs from the other. Our aim is to explain the process in plain language and to give a realistic timeline plan that you can build backwards from your shipment date.

What exactly does CE marking show?

CE marking is the manufacturer's declaration that the product meets the essential requirements of the EU legislation that applies to it. It is not a quality award or a marketing badge; it is the legal key to the free movement of the product within the European Union and the European Economic Area. Responsibility largely rests with the manufacturer: choosing the right legislation, producing the required evidence, and keeping the technical file ready are the manufacturer's obligations.

Machinery products: which path is followed?

For machinery, the framework has been updated with the new Machinery Regulation (2023/1230), which replaces the long-applied Machinery Directive 2006/42/EC; it is important to confirm the transition timeline for your product. For most machinery, the manufacturer carries out the risk assessment (EN ISO 12100 is the basic reference), prepares the technical file, draws up the instruction manual, and signs the declaration of conformity themselves.

For machinery categories listed as high-risk, the situation changes; for these products the assessment of a notified body comes into play. For this reason, the first step is always to clarify which category the product falls into and whether the self-declaration path or the notified body path applies.

Construction products: which path is followed?

Construction products fall under the Construction Products Regulation (CPR, 305/2011). If the product falls within the scope of a harmonised standard (hEN), the manufacturer is required to draw up a Declaration of Performance (DoP) and affix the CE marking.

The decisive point here is the system for assessment and verification of constancy of performance (AVCP). Depending on the system the product falls into (1+, 1, 2+, 3, or 4), the role of the notified body changes from type testing to certification of factory production control. Determining the harmonised standard and the correct AVCP system from the start is the most critical decision of the process; the wrong class nullifies the entire test and inspection plan.

Step-by-step process

• Identify the product and the legislation that covers it; for construction products, determine the harmonised standard.
• Identify the applicable essential requirements and the conformity module or the AVCP system.
• Plan the required tests and build the technical file.
• Work with a notified body if required; its role changes according to the legislation and the class.
• For construction products, set up factory production control and operate it in a sustainable way.
• Draw up the Declaration of Performance or the declaration of conformity.
• Affix the CE marking in accordance with the rules and keep the technical file, usually for ten years.

A realistic timeline plan

Giving a single duration would be misleading. The decisive factors are the scope, the amount of testing required, and whether a notified body is needed. For a relatively simple machine on the self-declaration path, the process can move in a few weeks. For a construction product that requires testing and a notified body, spreading over several months is normal. The healthiest method is to plan backwards from the shipment date; tests and setting up factory production control are most often the longest items, so starting early directly protects the delivery time.

Frequently asked questions

Can we affix the CE marking ourselves?

For most machinery and for construction products in the low AVCP classes, yes; the responsibility rests with the manufacturer. For high-risk machinery categories and high AVCP systems, the involvement of a notified body is mandatory.

Is there a single CE certificate?

No. CE is not a single certificate but a declaration of conformity with the legislation. The outputs that emerge are the technical file, the performance or conformity declaration, and the marking itself.

Is testing mandatory for every product?

As much as the harmonised standard and the AVCP class require. Some classes require type testing and continuous surveillance of factory production control; in others the manufacturer's own assessment is sufficient.

Is the same marking valid for the United Kingdom?

No. After Brexit the United Kingdom applies its own marking regime; the CE assessment carried out for the EU is not considered sufficient on its own, and a separate assessment is required.

Where to start?

Eurocert is a conformity assessment body that has worked in testing, inspection, and certification since 1999. To determine the right legislation and harmonised standard, plan the required tests, and prepare the timeline, review our machinery CE certification service or contact us; let us build a road map suited to your product family together.