ALTAMENTE ROBOTICS · CONFORMITY AND DOCUMENTATION

Conformity, documentation
and safe deployment

From the actual task and configuration to usable evidence, clear responsibilities and safe commissioning.

CE marking, product conformity and the safety of the customer installation are connected. Each needs verification within its applicable scope.

Start with your situation

We first identify the product, intended purpose, operating environment and legal roles. Labels such as humanoid, service robot or cobot do not determine the complete regulatory scope.

01

Selecting or buying a robot

We review the intended task, operating limits, configuration and availability of supporting evidence before the purchasing decision.

Deployment assessment
02

Importing or supplying a robot

We identify the supply route, responsibilities, required evidence and open questions before a particular unit is first placed on the EU market.

Roles and responsibilities
03

Deploying a robot at a customer site

We connect product documentation with the actual workplace, task, protective measures, operators and acceptance procedure.

Robot deployment
04

Changing a robot or its skills

Before changing a task, tool, software or AI model, we assess the impact on risks, the original evidence and responsibility.

Modifications after import
05

Using AI, cameras or cloud services

We identify AI functions, personal and operational data, remote administration, access rights, transfers and updates.

AI and data
06

Representing a technology vendor

We help prepare customer use cases, localisation, pilots, integration evidence and the division of work with your team.

For technology vendors

The path to conformity starts with the legal framework

The output is a relevant procedure and body of evidence for the actual product, configuration and intended use. There is no universal list of certificates for every robot.

  1. Applicable legal framework. Intended purpose, supply boundary, finished or partly completed machinery, overlapping legislation and market-entry and commissioning dates.
  2. Requirements. Relevant essential requirements, risk assessment and responsibility for meeting them.
  3. Conformity assessment procedure. Select a permitted route and establish whether a notified body is required.
  4. Documentation, tests and standards. Prepare and evaluate the evidence required by the chosen procedure; documentation and verification develop together.
  5. Declaration of conformity. The responsible manufacturer issues it once compliance is established. Partly completed machinery requires a declaration of incorporation and assembly instructions.
  6. CE marking. Affix it where applicable legislation requires it, only after all relevant conditions have been fulfilled.
CE marking does not mean that the EU or another authority has approved a product as safe. It indicates declared conformity with applicable requirements. It does not, by itself, establish the safety of any task or customer installation. A generic or voluntary certificate does not replace the correct conformity assessment procedure.

A certificate under one directive or one standard does not automatically establish compliance with every law applicable to the actual product configuration. For each document, check the model, version, configuration, covered requirements and connection to the relevant declaration of conformity.

Machinery Directive 2006/42/EC uses the EC declaration of conformity; Regulation (EU) 2023/1230 uses the EU declaration of conformity. Partly completed machinery does not bear CE marking under machinery legislation, although another applicable law may require CE marking.

Primary sources: European Commission — CE · Manufacturer obligations · Directive 2006/42/EC · Regulation 2023/1230

Modifications after import need a new decision

Extending a function can change safety conditions and legal responsibility for the modified product. The original evidence must be assessed against the actual configuration.

  • A new task, operating area or form of human contact.
  • A different tool, accessory, sensor or connection to other equipment.
  • Changes to control, safety functions, remote administration or autonomy limits.
  • New software, an AI model, a learned skill or training that changes robot behaviour.
Not every modification is substantial and not every update requires new CE marking. The assessment considers what the manufacturer anticipated, changes in intended purpose, new hazards or increased risks and any additional protective measures required.

RoHS has its own change rule: under Article 11, an importer or distributor can assume manufacturer obligations when supplying under its own name or trademark or modifying equipment in a way that may affect conformity. Changes therefore also require assessment against the other legislation applicable to the configuration.

Primary sources: RoHS — Article 11

From 20 January 2027, the Machinery Regulation explicitly defines substantial modification by physical or digital means. If its conditions are met, the person performing the modification assumes manufacturer obligations and ensures the applicable conformity assessment. Under that regulation, an importer or distributor can also become the manufacturer when supplying under its own name or trademark or making a modification that may affect conformity.

Skill training and HRI: we first define permitted behaviour, task boundaries, speeds and forces, contact conditions, oversight and failure responses. We validate the new version against agreed criteria and record its impact on risks and evidence. For AI subject to the relevant regime, we distinguish changes predetermined and documented in the original assessment from substantial modifications; machinery AI also requires consideration of its sectoral framework.

  • Before a change: describe the difference from the approved configuration and decide the verification scope.
  • Before release: test affected functions, update evidence and identify the responsible entity.
  • During operation: maintain version records, controlled updates, change approvals and a route back to a verified configuration.

Primary sources: Regulation 2023/1230, Articles 3, 17 and 18 · Blue Guide 2022 — product changes · AI Act, Article 43 — AI modifications · AI Act, Article 25 — value-chain roles

Actual supply and work determine the roles

The label “partner” or “integrator” does not replace a legal role. Before a pilot or delivery, we document system boundaries, evidence and responsibilities.

RoleWhat must be clarified
ManufacturerResponsible for product conformity, the relevant assessment, technical documentation, declaration, marking and instructions. Manufacturer obligations
EU importerBefore a product from a third country is placed on the EU market, checks the relevant assessment, technical documentation, the applicable declaration, CE marking where required and accompanying information. Under the Machinery Regulation from 20 January 2027, the role also includes retaining the EU declaration and ensuring access to technical evidence under Article 13; partly completed machinery follows Article 14 and a declaration of incorporation. The customs declarant and product-law importer may be different entities. Regulation — Articles 13–14 · Importers and distributors
DistributorActs with due care, checks required markings and accompanying information, and handles the product without compromising conformity. Importers and distributors
Integrator / manufacturer of the completed assemblyAssess separately whether the work creates an assembly of machinery, a new product or a substantially modified product, and who is responsible for the completed system. Directive — definition of machinery · Regulation — changes and roles
Operator / employerAddresses safe workplace use, instructions, operators, maintenance and applicable inspections. Product CE marking does not replace these operational duties. Use of work equipment
ALTAMENTEProvides the agreed integration and documentation coordination, evidence records and preparation for specialist verification. Any additional legal role is determined by the actual supply arrangement and a separate agreement.

Product conformity and installation safety

A robot also needs assessment in the context of the task, workplace, people and other equipment. Robot documentation may not cover the completed application.

  • Application boundaries, tools, accessories and connections to machinery, the building and information systems.
  • People movement, public access, shared space, human contact and reasonably foreseeable misuse.
  • Protective measures, stopping, safe states during failures and authorisation to resume operation.
  • Acceptance criteria, documented on-site verification, instructions, operators and maintenance.

Where work-equipment safety depends on installation conditions, Directive 2009/104/EC requires an initial inspection after installation and before first use, and inspection after assembly at a new location, under relevant national rules. We define the conditions of a controlled pilot and subsequent routine operation separately.

Primary sources: Directive 2009/104/EC, Article 5 · Machinery Directive · Machinery Regulation

Regulatory applicability matrix

Verified on 5 October 2026. Each row depends on the actual product and intended use; this is not a set of mandatory certifications for every robot.

For the actual supply: exact model and unit, hardware, software, AI and tooling configuration, intended use, first placement on the EU market and, where relevant, commissioning date. For EPR, also establish first supply and the responsible party in each destination Member State. Manufacturing, shipping dates or a generic certificate do not replace this record.

AreaWhen to check it and relevant datesPrimary evidence
Machinery Directive 2006/42/ECMachinery first placed on the EU market or put into service up to 19 January 2027 within the directive’s scope. Check transitional rules for units already lawfully placed on the market; manufacturing or import dates alone do not determine the regime.EC — Machinery · Directive
Machinery Regulation (EU) 2023/1230Machinery and related products within its scope from 20 January 2027. Assess manufacturer, importer and distributor duties and the impact of changes. Previously lawfully placed products may benefit from applicable transitional rules.EC — application · Regulation, Articles 52 and 54
RED 2014/53/EUA robot or accessory with radio equipment, Wi-Fi, Bluetooth, etc. Check the supplied configuration and the scope of radio, EMC and safety evidence. RED applies from 13 June 2016; selected cybersecurity requirements from August 2025, with the CRA transition from 11 December 2027.EC — RED and cybersecurity requirements
RoHS 2011/65/EUWhere electrical or electronic equipment falls within scope. Check material evidence, exclusions and exemption validity, documentation, EU declaration and CE marking. National transposition deadline: 2 January 2013; the previous directive was replaced from 3 January 2013. Extended scope for previously uncovered EEE from 22 July 2019.RoHS — Articles 2, 4, 7, 13–15 and 25–26
Batteries — Regulation (EU) 2023/1542Batteries, including those incorporated in a robot. Generally from 18 February 2024, with staged dates; waste/EPR rules from 18 August 2025. Check category and the applicable procedure, evidence, declaration/CE and registration/EPR in the destination country. Other requirements have separate dates.Regulation — Articles 1, 17–20, 55–56 and 96
CRA (EU) 2024/2847Products with digital elements within its scope. Manufacturers report actively exploited vulnerabilities and severe security incidents from 11 September 2026; main requirements from 11 December 2027.EC — reporting · EC — CRA
WEEE 2012/19/EUEEE within scope. National transposition deadline: 14 February 2014; open scope from 15 August 2018, subject to exclusions. Registration, reporting, separate collection and e-waste financing by destination country and role. Environmental/EPR duties, rather than an additional CE certificate.WEEE — Articles 2, 12–16 and 24–25
AI Act (EU) 2024/1689, amended by 2026/1744According to the actual AI function, intended use and classification, rather than automatically because a robot includes AI. Generally from 2 August 2026, with exceptions. High-risk under Article 6(2) / Annex III: Chapter III, Sections 1–3 from 2 December 2027. High-risk under Article 6(1) / Annex I: relevant requirements from 2 August 2028. Machinery AI requires the sectoral treatment explained below.Current Article 113 · EC — enacted amendment
Workplace safetySeparately from product conformity, for the actual installation, task, people and connected equipment. Risk assessment, safeguards, acceptance, operators and relevant work-equipment inspections under national rules.Directive 2009/104/EC — Article 5
EMC 2014/30/EUFrom 20 April 2016. Electromagnetic emissions and immunity of equipment within its scope; fixed installations have specific rules.EC — EMC
LVD 2014/35/EUFrom 20 April 2016. Electrical equipment within the relevant voltage range. Machinery legislation addresses machinery electrical hazards; a separate power supply or charger may have its own regime.EC — LVD · Directive, Annex I, section 1.5.1
GDPR (EU) 2016/679From 25 May 2018. Where personal data are processed: purpose, lawful basis, scope, retention, access and transfers.EC — GDPR

The European Commission allows manufacturers of machinery placed on the market before 20 January 2027 to also state conformity with Regulation 2023/1230 where applicable. This does not remove the requirement to comply with Directive 2006/42/EC until then. Mentioning the future regulation alone therefore does not establish whether particular evidence is correct.

Primary sources: EC — Machinery

Additional regimes may apply by purpose, such as medical devices or explosive atmospheres. Overlaps and exclusions follow the actual product and supply arrangement.

Cybersecurity from import to updates

Remote administration and software changes can affect both data and safe robot behaviour. Define product, integration and operational responsibilities before deployment.

CRA: from 11 September 2026, manufacturers of products within scope must report certain actively exploited vulnerabilities and severe incidents affecting product security. Main requirements apply from 11 December 2027. Check scope and transitional rules for the product and responsible entity; these duties cannot be assigned to every robot user indiscriminately.

  • Map software, firmware, network interfaces, cloud services and vendor remote access.
  • Define permissions, network separation, data transfers and intervention records.
  • Agree secure updates, supported versions and recovery of a verified configuration.
  • Identify vulnerability contacts, incident escalation and cooperation with the responsible manufacturer.
  • Assess the impact of attacks or changes to data and software on safety functions and overlapping RED and machinery requirements.

Primary sources: EC — CRA reporting · CRA — Articles 14, 69 and 71 · EC — RED · Machinery Regulation

AI and data: the actual function matters

Conversation, task control and a safety function do not automatically have the same AI regime. We define classification alongside product documentation and the customer system boundary.

The 2026 change: the AI Omnibus entered into force on 27 July 2026. The Machinery Regulation is now in AI Act Annex I, Section B, point 21. For AI classified as high-risk under Article 6(1) within this sectoral framework, Article 2(2) limits direct AI Act applicability and requirements are addressed through sectoral legislation. A generic package of obligations therefore cannot be applied to every robot.

Separate AI functions can fall under another regime, including specific Annex III categories. We also assess applicable transparency rules and prohibited practices. Performance optimisation or user assistance is not necessarily a safety component; whether its failure endangers health and safety also matters.

  • Data map: what is captured, what stays local, what goes to the cloud and who can access it.
  • Remote administration: permissions, network separation, intervention records, updates and incident responsibilities.
  • Learning from demonstrations: collection purpose, permission to use data, retention and further supplier use.
  • Operations: model and configuration versions, autonomy limits, oversight, failure responses and change assessment.

Primary sources: EC — AI Omnibus · AI Act, Article 2 · AI Act, Annex I · AI Act, Article 6 · EC — AI Act · EC — personal data protection

Standards provide a technical route to evidence

We select standards according to function and system boundaries. Assessment checks the current edition, relevant European EN version, Official Journal citation and restrictions, and the requirements actually covered.

ApplicationExamples of technical evidence and their limitsPrimary source
Industrial robot and applicationISO 10218-1 / -2: robot safety and integration of an industrial application or cell. Platform mobility or use in areas accessible to the public requires a separate scope review.ISO 10218-1 · ISO 10218-2
Driverless industrial truckISO 3691-4: safety of relevant driverless industrial trucks and their systems, including AGVs or AMRs meeting its definition. The operating zone also matters; it does not cover every mobile robot.ISO 3691-4
Personal care robotISO 13482: personal care robots within its scope, including certain physical contact applications. It does not universally cover service humanoids and excludes robots used as medical devices.ISO 13482
Risk and control-system safetyISO 12100: risk assessment and reduction throughout the machine lifecycle. ISO 13849 / IEC 62061: safety-related control parts and functional safety according to the chosen solution. The application assessment determines the actual functions and required safety level.ISO 12100 · ISO 13849-1 · IEC 62061

A new ISO or IEC edition is not automatically a harmonised European standard cited under the applicable legislation. Harmonised standards are voluntary and provide a presumption of conformity only for the requirements they cover, under their citation conditions. Other technical solutions need appropriate evidence. A standard, test report or voluntary certificate does not by itself replace compliance with legal requirements and the responsible manufacturer’s declaration.

Primary sources: EC — harmonised standards · EC — machinery standards · EC — assessment and documentation

What we prepare for you

The scope follows the actual model, version and planned task. The result should be usable evidence for the manufacturer, customer and relevant specialists.

Handover connects vendor evidence with the actual customer application. The customer receives a traceable view of conformity, missing evidence, responsibilities and verification needed before a change or release of a new version.

  • A map of the exact model and unit, hardware/software/AI configuration, tooling and intended use.
  • A record of first EU market placement and any commissioning date, legal framework and responsible parties; destination countries for EPR.
  • An evidence/version register linking declarations, certificates and tests to their covered requirements and configuration.
  • A plan for localising instructions and customer information with appropriate specialist review.
  • Preparation for specialist verification, required testing and a notified body where the assessment route requires one.
  • Acceptance criteria, integration evidence and change records for the actual deployment.

Service scope: ALTAMENTE provides the agreed preparation, integration and coordination. Responsibility for conformity and the relevant declaration belongs to the entity determined by law; the appropriate parties perform specialist testing and assessments under the selected procedure. Their involvement is defined before work begins.

ALTAMENTE

Let’s clarify your actual case.

Send the model, configuration, intended task, operating location and planned supply or modification. We will identify the initial evidence needed and propose a scope of cooperation.

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