CE marking on a robot: what it does and does not tell you

A CE mark on a robot is the manufacturer's declaration that the product met the applicable EU rules when it was placed on the market, not an approval by any authority. For a humanoid or robot dog sold today, those rules are mainly the Machinery Directive, the Radio Equipment Directive for anything with Wi-Fi or Bluetooth, and EMC requirements. The Machinery Regulation takes over in January 2027.

This article explains what each piece of legislation covers, what a declaration of conformity proves and what it does not, and which questions are worth asking before a robot appears in front of the public. It is general information, not legal advice.

What the CE mark actually means

The European Commission describes CE marking as showing that a product sold in the European Economic Area has been assessed against EU safety, health and environmental requirements. The same page also says plainly that the mark does not mean a product has been approved as safe by the EU or another authority. The manufacturer does the conformity assessment, compiles the technical file, issues the EU declaration of conformity and puts the mark on the product.

The EU's Your Europe portal for businesses makes the same point from the manufacturer's side. There is no central approval body, and the CE mark is the manufacturer's statement of compliance at the moment the product enters the market. The portal also notes that anyone who sells a product under their own name or brand counts as the manufacturer. A third party who modifies the product after sale may mean CE compliance no longer applies.

Three consequences follow for anyone hiring or buying a robot:

• The mark is a legal claim, not a test certificate. Its value depends on the work behind it.
• It describes the product as it was placed on the market. Later hardware changes, add-ons or heavy modifications may take it outside what was assessed.
• It says nothing about how a robot is used at your venue: crowd density, floor surface, operator skill or show choreography.

The Machinery Directive: the core rules for moving robots

The Machinery Directive 2006/42/EC is the main EU law for products that move under their own power. The Commission summarises the definition of machinery as an assembly of components, at least one of which moves, joined together for a specific application, driven by a power source other than human or animal effort. A battery-powered humanoid or quadruped that walks and moves its limbs fits that description.

The directive sets mandatory essential health and safety requirements. Manufacturers can show they meet them by applying voluntary harmonised standards. The Commission explains that references to these standards are published in, and withdrawn from, the Official Journal of the EU by Commission implementing decisions. A standard only gives a presumption of conformity while its reference is listed there.

This matters for robots because the harmonised standards were written mostly for industrial machines, not for bipedal robots walking among visitors. Work on a dedicated standard for legged robots is still under way, as covered in our article on ISO 25785-1 for legged and humanoid robots. Until it is finished, a manufacturer may rely on a risk assessment and more general standards. A declaration of conformity should show which ones were used.

The Radio Equipment Directive: anything with a radio

Most robots used at events connect to a tablet, a remote controller or the venue network over Wi-Fi, Bluetooth or mobile data. That brings in the Radio Equipment Directive 2014/53/EU. According to the Commission, its essential requirements cover safety and health, electromagnetic compatibility and efficient use of the radio spectrum. For certain categories they also cover protection of personal data and privacy, and protection against fraud.

The cybersecurity part is recent. Commission Delegated Regulation (EU) 2022/30 switched on cybersecurity, data protection and anti-fraud requirements for certain radio equipment. It has applied since 1 August 2025. The Commission states that on 16 February 2026 it adopted a delegated regulation repealing those RED cybersecurity rules with effect from 11 December 2027. That is the date the main obligations of the Cyber Resilience Act apply. The handover is explained in more detail in our article on the Cyber Resilience Act and the RED.

In practice, a connected robot placed on the EU market between August 2025 and December 2027 should have a declaration that addresses these RED cybersecurity requirements where they apply to it.

The EMC Directive: interference in both directions

The Electromagnetic Compatibility Directive 2014/30/EU deals with electrical and electronic equipment disturbing other equipment, or being disturbed by it. The Commission describes two goals: limiting the electromagnetic emissions equipment produces and ensuring equipment has enough immunity to keep working normally.

For events this is not a theoretical point. Exhibition halls and stages are full of wireless microphones, LED walls, radio intercoms and many visitors' phones. EMC compliance shows that the robot was designed and tested against agreed limits. It does not guarantee that a robot's control link will stay stable in a crowded radio environment on the day. That is a site and operations question, covered in our guide to safety at public events with robots.

For radio equipment, the RED's own essential requirements already include EMC, so check which acts the declaration actually lists rather than assuming all three appear by name.

What a declaration of conformity proves

The EU declaration of conformity is the document behind the CE mark. The Commission lists its contents: identification of the product, the legislation it is issued under, the manufacturer or authorised representative, any notified body involved, and references to the harmonised standards or other technical specifications applied.

A declaration proves that a named, legally responsible party has formally claimed conformity with specific laws for a specific product. That is useful. It gives you a model to match against the robot that arrives, a list of standards, and someone accountable if the claim turns out to be wrong.

It does not prove that an independent body tested the robot, unless a notified body is named. It does not prove that the version on site is the one assessed. And it does not cover choreography, software a supplier added later, or the layout of your event.

The Commission also warns about so-called voluntary certificates. These are documents from bodies without notified status that can look official. Its conformity assessment page says such certificates are not a recognised means of proving compliance with EU harmonisation legislation. Only notified bodies may issue certificates of compliance for harmonised products within their designated area. A glossy "CE certificate" from an unknown test lab is not a substitute for the manufacturer's declaration.

Your Europe adds that technical documentation must be kept for at least 10 years after the product is placed on the market, and provided to authorities on request. The CE mark itself must be visible, legible and indelible, with a minimum height of 5 mm.

What changes in January 2027

The Machinery Regulation (EU) 2023/1230 was adopted on 14 June 2023. According to the Commission, it applies on a mandatory basis from 20 January 2027, and machinery placed on the EU market before that date must comply with the directive. The Commission's harmonised standards page confirms that the directive will be repealed by the regulation on that date. The new regulation adds provisions on AI-driven safety functions and cybersecurity.

For anyone hiring robots, the date of placing on the market is the key point. A robot imported in 2026 under the directive does not lose its CE mark in 2027 because the law changes. Robots placed on the market from 20 January 2027 will need declarations that refer to the regulation. What the regulation changes for humanoids and robot dogs is covered in our article on the 2027 Machinery Regulation.

What this means for event organisers

• Ask for the EU declaration of conformity, not just a photo of the CE label. Check that the model and manufacturer match the robot being supplied, and note which directives and standards it lists.
• Ask whether the robot has been modified. Custom hardware, additional sensors or third-party payloads may fall outside what the manufacturer assessed. Put the question in writing when you brief a robot supplier.
• Treat "CE certificates" from unknown labs with caution. The manufacturer's declaration, and a notified body certificate where one is required, are what count.
• Do not confuse conformity with a safe event plan. CE marking covers the product. Exclusion zones, operator staffing and crowd management are still your and the supplier's responsibility, and they belong in your risk assessment and your insurance and liability arrangements.
• Note the dates. For robots placed on the market from 20 January 2027, expect declarations under the Machinery Regulation, and expect cybersecurity to move to the Cyber Resilience Act from 11 December 2027.

Frequently asked questions

Does a CE mark mean a robot has been approved by the EU?

No. The European Commission states that CE marking does not mean the EU or any other authority has approved a product as safe. It is the manufacturer's own declaration that the product met the applicable EU rules when it was placed on the market. Independent testing by a notified body is only involved where the relevant legislation requires it, and the declaration of conformity will then name that body.

Which EU directives usually apply to a humanoid robot or robot dog today?

For a battery-powered robot that moves, the Machinery Directive 2006/42/EC is the core law until 20 January 2027. Robots with Wi-Fi, Bluetooth or mobile connectivity also fall under the Radio Equipment Directive 2014/53/EU, which includes safety and electromagnetic compatibility requirements. The EMC Directive 2014/30/EU deals with interference. The declaration of conformity should list exactly which acts the manufacturer applied.

Is a robot with a CE mark under the old directive still legal after January 2027?

According to the European Commission, machinery placed on the EU market before 20 January 2027 must comply with the Machinery Directive, and the new Machinery Regulation applies to machinery placed on the market from that date. The key point is when the individual robot was first placed on the EU market, not when it is used at an event. This is general information, not legal advice.

What should I ask a robot supplier about CE marking?

Ask for a copy of the EU declaration of conformity for the exact model being supplied, and check the manufacturer name and product identification. Note which directives and standards are listed and whether a notified body is named. Ask whether the robot has been modified since purchase. Be cautious with so-called voluntary certificates, which the Commission says are not a recognised way to prove compliance.

How this article was made: written by the humanoid4rent editorial team with AI assistance; every factual statement was checked against the sources listed below on 2026-11-03. Spotted an error? Write to info@humanoid4rent.com.