This is an orientation for plant managers, not legal advice. Machinery compliance depends on the specific line, its configuration and how it is placed on the market. Verify every point with your own notified body, compliance consultant or counsel before you sign a purchase contract.
The key date and the transition question
Regulation (EU) 2023/1230 applies from 20 January 2027, and Directive 2006/42/EC is repealed with effect from the same date (Certifico consolidated text, 2025; BAuA). The articles on notified bodies already applied from 20 January 2024.
Machines can continue to be placed on the market under the Directive until 19 January 2027 (BAuA). IBF describes the change as a key-date cutover rather than a transition period: a machine placed on the market from 20 January 2027 must comply with the Regulation.
The practical point for an imported line: what counts is when the machine is placed on the EU market, generally when it is first made available there, not when it leaves the factory. A line ordered in late 2026 that arrives in 2027 should be planned for the Regulation.
What changes for a non-EU manufacturer
Under the Regulation, a machine made outside the EU needs an economic operator established in the EU: a manufacturer, an authorized representative, an importer or a distributor (Automation Magazine). For a pultrusion line bought directly from China, that operator is usually the EU buyer acting as importer, or an authorized representative appointed by the manufacturer. The Regulation's English text spells the role authorised representative.
Authorized representative (Art. 12)
- Appointed by the manufacturer under a written mandate.
- Cannot be mandated to design or build the machine or to draw up the technical file.
- Keeps the technical documentation and EU declaration of conformity for at least 10 years.
- Not mandatory if an EU importer fills the economic-operator role (EcoComply; EUVerify).
Importer (Art. 13)
- Places the machine from a third country on the EU market.
- Verifies that conformity assessment was carried out and checks the documentation.
- Puts its own name and contact details on the machine.
- Keeps the EU declaration of conformity for 10 years (EUVerify).
Branding decides who the manufacturer is
Under the EU product framework, a company that places a product on the market under its own name or trademark is treated as the manufacturer, with the manufacturer's obligations (Danish Safety Technology Authority, Know your role, Dec 2020). An importer or distributor that rebrands a machine takes on those obligations.
For a pultrusion machine, the name on the nameplate and on the declaration of conformity decides who signs and who answers to market surveillance. A machine with the factory's name on the nameplate and a trader's name on the declaration is the kind of inconsistency that fails checks. Ask every supplier, in writing, whose name will appear on each document.
The documents that travel with the line
- Technical file: risk assessment, design drawings, calculations, test reports, list of standards applied, and the instructions. Drawn up by the manufacturer.
- EU declaration of conformity: signed by whoever places the machine on the market under its own name, in the language required by the Member State.
- CE marking on the machine, with manufacturer and, where relevant, importer details.
- Instructions: the Regulation permits digital instructions instead of paper for the first time (Operations Engineer). Check the article text for when a user can request a paper copy.
For a pultrusion line, the risk assessment has to cover the whole assembly, not just the puller. Typical hazard areas are the hot die platens, pinch points at the clamps or caterpillar belts, the flying cut-off saw, hydraulic pressure, and resin and styrene handling at the bath or injection box. If creel, puller and saw come from different suppliers, agree in writing who assesses the assembly.
Whether a given line falls into the Regulation's higher-risk categories that require a notified body was not covered by the research behind this page. Other EU acts, such as electromagnetic compatibility rules, may also apply. Confirm the conformity-assessment route and the full list of applicable acts with your notified body.
If you later modify an installed line substantially, for example by adding a second puller or changing the control system, you may take on manufacturer obligations for the modified machine. Ask counsel before rebuilding.
What Henan Zhongsheng and the Shanghai exporter plan to do
pultruded.com does not claim that any machine currently holds CE marking under the Regulation. The table below lists the steps planned by Henan Zhongsheng Composite Material Co., Ltd., the manufacturer, and the Shanghai export company, the exporter of record. Cells marked TBD are not yet decided.
| Item | Plan | Status |
|---|---|---|
| Name on nameplate and EU declaration of conformity | To be decided per order and stated on the quotation before contract | TBD · ask factory |
| EU authorized representative appointed | Appoint one for orders where the buyer does not act as importer | TBD · ask factory |
| Harmonized standards applied | List to be published per machine type | TBD · ask factory |
| Risk assessment per machine type | Prepared by the manufacturer as part of the technical file | TBD · ask factory |
| Technical file | Drawn up by the manufacturer for each machine type offered to EU buyers | TBD · ask factory |
| Instructions | Digital instructions in the buyer's language; paper on request | TBD · ask factory |
| Control panel standard | CE-oriented panel for EU orders | TBD · ask factory |
| Notified body involvement | Depends on conformity-assessment route | TBD · ask factory |
| FAT | Run before shipment; buyer may send SGS, BV or TÜV at its own cost | Accepted |
Legal entity, measurable specs, FAT, payment milestones, electrical compliance, spares and warranty. Buying a pultrusion line from China: checklist
Who builds the machine, who exports it, and how to arrange a factory audit. Manufacturing partner
Questions buyers ask
- When does the EU Machinery Regulation 2023/1230 apply?
- From 20 January 2027. Directive 2006/42/EC is repealed with effect from the same date, and machines may be placed on the market under the Directive until 19 January 2027 (BAuA). One source describes a transition period; most do not, so confirm with your notified body.
- Does a Chinese pultrusion machine need an EU authorized representative?
- It needs an EU-established economic operator. If the EU buyer acts as importer, an authorized representative is not mandatory; otherwise the manufacturer appoints one under a written mandate (EcoComply; EUVerify).
- Is a pultrusion machine on pultruded.com CE marked?
- This site makes no claim that any machine currently holds CE marking under the Regulation. The readiness plan above shows which steps are planned and which are undecided.
- Who signs the EU declaration of conformity?
- The company that places the machine on the market under its own name or trademark, as manufacturer. If an importer rebrands the machine, it takes on the manufacturer's obligations (Danish Safety Technology Authority, Dec 2020).
- Can the instructions be supplied digitally?
- Yes. The Regulation permits digital instructions instead of paper for the first time (Operations Engineer). Check the article text for when a user may request a paper copy.
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