Robots, electrical control cabinets and automation components become part of a specific application through integration, programming and protective measures. The technical documentation must explain how that final application is used safely and how the required evidence fits together.
Integrating robots, cobots or AGVs: who is responsible?
The component may be technically capable, but its final safety and conformity depend on the actual application, programming, operating modes, safeguards and interfaces. The system integrator may become the manufacturer of the completed machine or assembly.
Questions to clarify
- Is the supplied item complete machinery or partly completed machinery?
- Do the declaration and instructions for use or assembly instructions match its status?
- Are integration conditions, safety functions, protective zones and residual risks described?
- Who assesses the interfaces and prepares the overall risk assessment?
- Who compiles the final technical documentation and signs the declaration?
Relevant support: Assemblies of machinery, Safety concepts & protective measures, Documentation review
An EU address, but weak conformity evidence
A local address does not establish that a product is compliant. The named party’s role and the quality of the technical evidence must be assessed. This matters especially where an integrator relies on the supplied product for its own conformity assessment.
Questions to clarify
- Are the manufacturer, importer and representative roles identifiable?
- Does the nameplate match the declaration and the supplied variant?
- Are instructions, standards references and test reports plausible?
- Is the product’s status and permitted integration clear?
- Can the evidence support the integrator’s risk assessment?
Relevant support: EU & UK authorised representative, Documentation review, Manufacturers outside the EU & UK
Instructions, warnings and languages
The language of user information needs to suit the target market and the actual users. Supplier documents also need to be usable by the integrator. Language requirements should be established before integration, commissioning or acceptance.
Questions to clarify
- Which destination countries and user groups are involved?
- Are instructions for use and assembly instructions in an appropriate language?
- Do warnings on the product, in the instructions and on the HMI agree?
- Are residual risks communicated clearly to the people exposed?
- Who provides and checks the required translations?
Relevant support: Technical documentation, Documentation review, Importers of technical products
Electrical control cabinets: a separate product or part of the machine?
The assessment depends on how the electrical control cabinet is designed, supplied and placed on the market, and who assumes responsibility. An electrical control cabinet built as part of a machine under the machinery manufacturer’s responsibility is a different situation from an independently supplied product. Electrical, EMC and other applicable requirements must be considered for the actual arrangement.
Questions to clarify
- Who defines the design, components, circuit diagrams and functions?
- Is the electrical control cabinet separately placed on the market?
- Does the supplier manufacture to detailed customer specifications or take its own manufacturer responsibility?
- Does the electrical control cabinet implement safety functions, and what evidence supports them?
- Which declarations and technical records are needed for the final machine?
Relevant support: CE & UKCA conformity assessment, Safety concepts & protective measures, Technical documentation
Documentation gaps at acceptance and commissioning
Missing nameplate information, inconsistent warnings or incomplete supplier records often become visible late in a project. A structured review separates urgent safety questions from documentation corrections and assigns a clear next action.
Questions to clarify
- What documents exist, and which products or areas do they cover?
- Which gaps affect safety or the conformity assessment?
- What must be requested from the supplier?
- What must be assessed or updated internally?
- Does the change require an overall installation assessment?
Relevant support: Documentation review, Assemblies of machinery, Machinery users, retrofit & modernisation
These examples describe recurring project questions, not findings about individual manufacturers or suppliers. The appropriate conclusion depends on the actual product and supply arrangement.