Changes to machines—whether mechanical or functional—can affect their compliance with applicable regulations. In many cases, a new conformity assessment and updated CE marking are required. A professional evaluation of each modification minimizes legal and operational risks.

Table of contents

  1. What Are Machine Modifications and Upgrades?
  2. Process of Assessing Machine Modifications
  3. GCB’s Approach to Machine Modifications
  4. Why Follow the Compliance Process?
  5. When Is a New Conformity Assessment Required?
  6. GCB’s Services for Post-Modification Assessments

What Are Machine Modifications and Upgrades?

A modification or upgrade refers to a significant structural, technical, or functional change that impacts the machine’s operation, safety, or regulatory compliance. Under Directive 2006/42/EC and Regulation (EU) 2023/1230, such changes may require a new conformity assessment and updated CE certification.

Process of Assessing Machine Modifications

Each project begins with an analysis to determine whether the modification:

  • alters the machine’s structure,
  • affects safety functions,
  • changes the original risk assessment,
  • introduces new hazards.

If any answer is “yes,” the following steps are necessary:

  • conducting a new conformity assessment,
  • updating the technical documentation,
  • issuing a new EU Declaration of Conformity,
  • applying new CE marking.

GCB’s Approach to Machine Modifications

GCB provides end-to-end support for machine upgrades, including:

  • verification of documentation and risk assessment,
  • technical testing and inspections,
  • implementation of updated harmonized standards,
  • preparation of new documentation and declarations,
  • collaboration with manufacturers and integrators.

Why Follow the Compliance Process?

Failure to follow the correct procedure can lead to:

  • invalidation of CE marking,
  • administrative penalties,
  • liability in the event of accidents,
  • prohibition of machine operation.

Proper procedures allow for:

  • compliance with current standards,
  • increased operational safety,
  • improved performance,
  • reduced legal risk.

When Is a New Conformity Assessment Required?

According to European Commission guidelines, a new conformity assessment is necessary when:

  • the machine’s intended use is changed,
  • a modification affects safety functions,
  • the machine is integrated with other equipment,
  • its functionality or operating parameters are altered.

GCB’s Services for Post-Modification Assessments

GCB supports companies in conformity assessments following modifications by providing:

  • impact analysis of design changes,
  • preparation of the required technical documentation,
  • coordination of the certification process,
  • support in communications with notified bodies.