CE marking for control panels: the integrator's guide for 2027

This is technical guidance from a PLC manufacturer, not legal advice. For edge cases, the reference is the text of the directives and regulations, their official application guides and, where it applies, a notified body.

Outside Europe: CE marking is for the European market. In North America the usual route is UL or CSA certification; the note on PLC certification further down explains what that means for the controller.

Component or assembly: why your panel is a new product

We hear the same sentence from integrators with twenty years of experience: "every component in the panel has CE, so the panel has CE." It does not work that way.

The CE mark on each component covers that component, under the conditions its manufacturer declared. The power supply manufacturer answers for the power supply, and the PLC manufacturer for the PLC. Nobody has assessed your combination: your layout, wiring, clearances, ventilation and loads. That assessment is yours, because you place the assembly on the market or put it into service.

• The CE marks of the components are your foundation, not your roof. They save you from testing what their manufacturers already tested, as long as there is real documentation behind them.
• What you add is what you must justify: assembly, wiring, integration and the way the parts work together.

Done properly, this is a commercial advantage. The integrator who delivers each panel with its technical file in order wins the jobs that others lose the day the end client, or their auditor, asks for the paperwork.

Which EU directives and regulations apply to a control panel or machine

For most panels and machines with a PLC, the map looks like this. One EU declaration of conformity can list every act that applies.

• Low Voltage (2014/35/EU): electrical safety of the assembly (shock, fire, overheating) for equipment from 50 to 1000 V AC or 75 to 1500 V DC. For panels, the usual route is the EN 61439 series, with design verifications and a routine verification of each panel you build.
• EMC (2014/30/EU): the assembly must not emit interference above the limits, and must keep working with the interference of its environment. For industrial sites, the generic standards are EN 61000-6-4 for emission and EN 61000-6-2 for immunity. This is the directive that fails the most assemblies.
• RoHS (2011/65/EU): restricts hazardous substances such as lead, mercury and cadmium in electrical and electronic equipment, and a control panel is one. Keep the RoHS declarations of the components in the file. Check the exclusions for large scale fixed installations and large scale stationary industrial tools if your project could fall under them.
• Radio Equipment (2014/53/EU): a product that includes a radio module is usually radio equipment as a whole, and then RED covers its safety and EMC instead of the Low Voltage and EMC directives. Since 1 August 2025, Delegated Regulation (EU) 2022/30 also asks internet connected radio equipment to protect the network and personal data, with the EN 18031 standards as the reference; check the restrictions listed with them in the Official Journal.
• Machinery (2006/42/EC, then 2023/1230): applies when you deliver a complete machine or partly completed machinery. It takes in the safety objectives of the Low Voltage Directive for the electrical part, which you solve with EN 60204-1, and it requires a documented risk assessment.

What changes with the Machinery Regulation (EU) 2023/1230

The Machinery Regulation replaces the Machinery Directive and applies from 20 January 2027. Machinery placed on the market before that date stays under Directive 2006/42/EC. If you sell machines, plan the change now: the declaration of conformity of a machine delivered in February 2027 must cite the Regulation.

Cyber Resilience Act. If your panel or machine connects to a network and you place it on the market as a product, check Regulation (EU) 2024/2847. Its reporting duties for actively exploited vulnerabilities apply from 11 September 2026, and most of its other obligations from 11 December 2027.

The technical file: what it must contain

The technical file is the evidence that your assembly complies. You do not send it to anyone by default: you keep it for market surveillance authorities for at least 10 years: from the date the product is placed on the market under the Low Voltage and EMC directives, and from the date of manufacture (of the last unit, in series production) under the Machinery Directive. The reasonable minimum for a control panel or a machine:

1. General description: what it is, what it does, where it is installed, and a unique identification (model, serial number).
2. Electrical schematics and panel layout as built, not as designed three revisions ago.
3. Critical components: list with their declarations of conformity and datasheets (power supply, PLC, protective devices, drives, safety devices), plus their RoHS declarations.
4. Risk assessment: mandatory for machinery and good practice always. Hazards, measures and residual risks. The document that describes the safe states of your PLC program belongs here.
5. Standards applied and how each requirement was verified: calculations, EN 61439 design verifications, EMC installation rules applied, and your own or laboratory test reports.
6. Instructions: installation, environmental conditions, maintenance and warnings.
7. EU declaration of conformity: one document that lists the acts and standards the product meets, signed by an authorised person. For partly completed machinery, the declaration of incorporation.

The rule that saves the most time: build the file while you build the assembly. Rebuilding it afterwards costs more, takes longer and usually uncovers the mistake described at the end of this guide.

Where control panels fail: EMC

Electrical safety rarely fails, because electricians know it well. Assemblies fall on electromagnetic compatibility, and almost always for one of these three reasons.

1. The drive installed without its EMC chapter

Drives installed without their line filter, without shielded motor cable, or with the shield not bonded 360 degrees at both ends. It is the first source of emission in a typical panel, and the drive manufacturer explains how to avoid it in the EMC chapter of the manual. If your assembly has a drive, that chapter is part of your file: apply it and record that you applied it.

2. Components with a CE mark and no documents behind it

Cheap power supplies and peripherals whose CE letters have never seen a laboratory. This is where the chain of responsibility breaks: you integrate, you sign, you answer for it. A critical component without real conformity documents is a gap in your technical file, and often the noise source that fails your emission test.

3. Wiring that undoes the design

You can build a whole panel with excellent components and lose the EMC in the wiring: shields left floating or bonded without a plan, signal cables parallel to power cables, no equipotential bonding, filters far from the cable entry. The EMC of an assembly is built with the panel layout; it does not come with the components.

Do you need a laboratory or a notified body?

If your machine is on one of these lists, or might be, do not settle it by reading a blog post, this one included. Talk to the notified body before you design, not after.

What to ask each component supplier

Ask for these documents when you buy each critical component and file them at once, not on the day you need them:

• EU declaration of conformity of the component, with the directives and standards it meets.
• Datasheet with the conditions of use: temperature range, overvoltage category, mounting requirements.
• EMC installation instructions when the component needs them (drives, switched mode power supplies, filters).
• RoHS declaration, often included in the EU declaration of conformity.
• Safety components: certificate from the relevant body and reliability data (PL or SIL) where it applies.

A serious supplier sends this without hesitation. A supplier who cannot send it is telling you something about their CE mark.

The documentation mistake that invalidates the most declarations

A declaration of conformity that cites standards the technical file does not back up. It is the most common failure and the quietest one.

The declaration says "complies with EN 61439-1, EN 61000-6-2, EN 61000-6-4", and the file holds no evidence that those standards were applied: no design verifications, no recorded installation rules, no tests, no technical justification. Sometimes it is worse: editions withdrawn years ago, or standards copied from the declaration of another product.

In an inspection or a claim, that paper does not protect you; it points at you. Before you sign, go through the cited standards one by one and ask: which document in the file proves this? If a standard has no answer, create the evidence or remove it from the declaration.

CE marking a control panel in seven steps

1. Define what you deliver: panel, radio equipment, complete machine or partly completed machinery.
2. List the EU acts that apply (Low Voltage, EMC, RoHS, RED, Machinery) and the standards you will use, in their current editions.
3. Collect the declarations, datasheets and installation instructions of every critical component when you buy it.
4. Do the risk assessment and design the panel layout with the EMC rules from the start.
5. Verify: EN 61439 design and routine verifications or EN 60204-1 tests, and EMC tests when the risk asks for them.
6. Close the technical file and the instructions, and keep them for 10 years.
7. Sign the EU declaration of conformity, check every standard it cites against the file, and affix the CE mark.