Guides

Standards and safety in handling technology

A manipulator is a machine in the sense of European law. That means risk assessment, technical documentation, operating instructions and a declaration of conformity – and from January 2027 the new Machinery Regulation. What that means in practice is set out here.

Author
Dr.-Ing. Philipp Schwittek
Reading time
8 minutes
Updated
28. August 2026
The key points
  • Machinery Directive 2006/42/EC is replaced by Machinery Regulation (EU) 2023/1230, applicable from 20 January 2027.
  • EN ISO 12100 is the basic standard for the risk assessment of any machine.
  • EN 14238 covers hand-guided manipulators, EN 13155 non-fixed lifting devices.
  • Anyone substantially modifying a machine may become its manufacturer – with all the duties that entails.
  • Industrial safety regulations govern operation, the Machinery Regulation governs placing on the market. Both concern the operator.
01

What changes from 2027

Machinery Directive 2006/42/EC is replaced by Regulation (EU) 2023/1230, which applies from 20 January 2027. As a regulation it applies directly in all member states without national transposition. Much of the content stays familiar; new elements include requirements for cybersecurity, provisions for machines with self-evolving behaviour and the option of digital instructions – with a paper version still to be supplied on request. For classical handling technology little changes in practice, but the documentation has to be moved onto the new basis.

02

The standards that actually apply

EN ISO 12100 is the foundation: it describes how a risk assessment is carried out systematically – define limits, identify hazards, estimate risk, evaluate, reduce, re-evaluate. For hand-guided manipulators EN 14238 applies; for non-fixed lifting devices EN 13155. Where control technology with a safety function is involved, EN ISO 13849-1 with its performance level is added.

  • EN ISO 12100 – risk assessment and risk reduction
  • EN 14238 – hand-guided manipulators
  • EN 13155 – non-fixed load lifting attachments
  • EN ISO 13849-1 – safety-related parts of control systems
  • EN ISO 11228-1 – manual handling: lifting and carrying
03

The trap: substantial modification

Anyone modifying an existing machine so that a new hazard arises or an existing risk increases carries out a substantial modification – and thereby becomes, in law, the manufacturer of a new machine. That means: own risk assessment, own documentation, own declaration of conformity, own CE marking. A larger gripper, an extended reach or an additional drive can cross that threshold. We therefore document modifications to our units as a matter of course – that is exactly the record that is missing later.

04

What belongs in the file

The CE mark is the visible tip of documentation that has to be complete: risk assessment, design and manufacturing records, evidence of the standards applied, test reports, operating instructions in the local language and the EU declaration of conformity. These records must be kept for ten years and presented to market surveillance authorities on request. Without them there is no CE – whatever the nameplate says.

05

Operation is a chapter of its own

The Machinery Regulation governs placing on the market; industrial safety regulations govern operation. As operator you need a risk assessment for the work equipment, defined inspection intervals, a competent person for the inspection, instruction of the operators and the operating instructions at the place of use. These duties do not transfer to the manufacturer, not even under a full-service contract.

Frequently asked questions

Frequently asked questions about Standards & safety

Does a manipulator need CE marking?

Yes. A manipulator is a machine in the sense of European law and requires a risk assessment, technical documentation, operating instructions and an EU declaration of conformity. The CE mark is the visible result of those records, not a substitute for them.

What changes with Machinery Regulation (EU) 2023/1230?

It replaces Machinery Directive 2006/42/EC and applies from 20 January 2027. New elements include cybersecurity requirements, provisions for machines with self-evolving behaviour and the admissibility of digital instructions – a paper version still has to be provided on request.

When does a modification become substantial?

When a new hazard arises or an existing risk increases and this is not controlled by simple protective measures. A new machine then arises in law, with its own risk assessment, documentation and declaration of conformity – and whoever carried out the modification becomes the manufacturer.

Which standard applies to hand-guided manipulators?

EN 14238 covers hand-guided manipulators; the basic standard for risk assessment is EN ISO 12100. For non-fixed lifting devices EN 13155 applies in addition.

About the author

Dr.-Ing. Philipp Schwittek

Managing Director, Entracon Planungsgesellschaft mbH

Engineer with a doctorate, specialising in plant engineering, digital design and process automation – from simulation through to commissioning.

  • Sizing
  • Design
  • Plant engineering
  • Standards and safety
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