The Machinery Directive is one of the only CE Directives to require the Manufacturer to have arepresentative located in the EU – someone who can be contacted by EU officials in the event that the
Technical Construction File is required for inspection (a very rare occurrence). You are not required to have
an EU representative for the Low Voltage Directive, EMC Directive, and most other Directives.
If you have products that are CE compliant with the Machinery Directive, please consider the following:
- The Machinery Directive refers to this representative as a “Compiler”. Don’t confuse the term – this person does not “compile” any documents. Consider the term “compiler” to mean your “CE representative in the EU”.
- Your “Representative” is not required to have possession of your Technical Construction File (TCF). They must only have a relationship with the manufacturer such that they can obtain the TCF if requested by EU officials.
- You only need someone in the EU that agrees to serve as your CE Representative. Keep in mind that they may never be called upon. If you have a corporate office of any kind in the EU, they can serve as your “representative”.
- You are required to have a “contract” with your “representative” that defines their duties. There is no required format, and the definition can be as simple as serving as liaison between EU officials and the Manufacturer (i.e. message and document forwarding).
- If you have a corporate lawyer located in the EU, they can serve as your representative. Sales offices and sales partners are also an option.
- The contact information for your CE Compiler (who serves as your “representative”) is required to be indicated on your CE Declaration of Conformity (DoC). Keep this in mind when defining their duties – each customer is to recieve a copy of your CE DoC – it will have your company information.
CE Compiler Service References: If your product complies with the Machinery Directive and you do
not have a company representative in the EU, these companies offer contract CE compiler services in
the EU – they are independent organizations not related to CertifiGroup. This information is provided
as a convenience. Prices vary and can include annual fees.
