Does CE Marking Expire? No, But These 5 Changes Can Break It
On January 20, 2027, the EU Machinery Directive stops applying. Every machine you shipped before that date keeps its CE marking. A machine leaving your plant the next morning gets judged against a different law.
That date catches a lot of manufacturers off guard, because CE marking has no expiry date printed anywhere. The marking stays valid for years. What can break it is change: in the law, in the standards, or in the product itself.
Here’s how each of those changes works, and what you need to do when one happens.
The short answer: CE marking has no expiration date
CE marking does not expire.
It applies to each unit at the moment that unit is placed on the EU market, and it stays valid for that unit for as long as the product is in use.
A CE marking stops covering new units when the law, the harmonised standards or the product design change after the conformity assessment was done.
The key idea is that compliance gets checked unit by unit, at a specific moment. A machine that complied on the day it was sold still complies years later, even if the rules have moved on since.
YourEU Declaration of Conformityworks the same way. It has no expiry field, and it stays valid as long as the product and the legislation it lists stay the same.
The trouble starts with the units you haven’t shipped yet. Those have to comply on the day they go out the door, which is why the five changes below matter.
1. The Notified Body certificate expires
Some products can’t be self-declared. They need a Notified Body, which usually issues an EU-type examination certificate. Unlike the CE marking, that certificate can have an end date.
Under the Machinery Directive, the manufacturer had to ask the Notified Body to review the EC type-examination certificate every five years. Notified Bodies working under other EU laws often print a validity period on the certificate too.
If the certificate lapses, units you’ve already sold are fine. You just can’t keep placing new units on the market based on that certificate until it’s renewed.
Self-declared products don’t carry this risk, since there’s no certificate to expire. The conformity assessment annex of each law decides whether your product needs a CE marking Notified Body or can go through self-declaration.
2. The law changes
The clearest example right now is machinery. Regulation (EU) 2023/1230 replaces the Machinery Directive 2006/42/EC and applies from January 20, 2027.
Some sources, including AI assistants, give January 14, 2027 as the date. That date appeared in the original text published in the Official Journal. A corrigendum later moved it, along with the other key dates in the Regulation, six days later. The correct date is January 20, 2027.
Machines placed on the market under the Directive before that date stay compliant, and distributors can keep selling them. Machines placed on the market from January 20, 2027 onwards need to meet the new Machinery Regulation, with an updated technical file and a new Declaration of Conformity that cites it.
If you hold an EC type-examination certificate issued under the old Directive, Article 52 of the Regulation keeps it valid until its own expiry date. Plan the renewal under the new rules well before then.
The Cyber Resilience Actadds another layer from December 11, 2027. It brings cybersecurity requirements to most products with digital elements, including many machines, on top of the CE marking they already carry.
3. A harmonised standard is replaced
Most manufacturers show compliance by applying harmonised standards. Those standards get revised, and the old version eventually stops giving you presumption of conformity.
The European Commission publishes a specific date for this in the Official Journal, called the date of cessation of presumption of conformity of the superseded standard. After that date, a product built to the old version loses the automatic benefit of the doubt.
Units already sold aren’t affected. Ongoing production is. If you keep making the same product, you need to check it against the new version of the standard.
Often the changes are small and the product already meets them. Sometimes a new test or a tighter limit shows up. A gap analysisbetween the old and new versions tells you which, and the result goes into your technical file.
4. You change the product
A CE marking covers the product as it was assessed. Change the design and the assessment may no longer describe what you’re shipping.
Typical triggers include swapping a critical component for another supplier’s part, changing the power supply, adding a radio module, or releasing firmware that touches safety or connectivity functions.
Not every change calls for a full new assessment. You need to check whether the change affects any essential requirement, update the risk assessmentif it does, and keep the technical file in line with the product you actually make.
If the change brings new legislation into scope, the Declaration of Conformity needs updating too. Adding a radio module, for example, brings the Radio Equipment Directive into the picture.
5. Someone else modifies it after sale
The last change happens outside your control. A customer, an integrator or a service company modifies the product after it has been placed on the market.
If that change counts as a substantial modification, the original CE marking no longer covers the product. Whoever made the change takes on the role of manufacturer, with all the obligations that come with it.
The Machinery Regulation is the first EU law to define substantial modification in binding text. For other products, the concept still comes from the Commission’s Blue Guide. Adding a robot to an existing production line is a typical case, and the Regulation sets a four-part test for substantial modification that decides whether a change crosses the line.
Does a used product need a new CE marking?
Age alone doesn’t break a CE marking. A machine sold in 2015 with valid CE marking keeps it.
Reselling a used product inside the EU doesn’t require anything new. Placing on the market happens only once in a product’s life, and that moment has already passed.
Importing a used product from outside the EU works differently. For EU law, that’s the first time the product is placed on the market, so it has to comply with the legislation in force on the day it’s imported, regardless of when it was built.
What happens to your CE marking when things change
Change
Units already sold
New units
What to do
Notified Body certificate expires
Still compliant
Can’t be placed on the market until renewed
Renew before the expiry date
The law changes
Still compliant
Must meet the new law from its application date
Update the technical file and the Declaration of Conformity
A harmonised standard is replaced
Still compliant
No presumption of conformity under the old version after the cessation date
Run a gap analysis against the new version
You change the product
Still compliant
Must match an updated assessment
Review the risk assessment and the technical file
Someone else makes a substantial modification
The modified unit loses its original CE coverage
Not affected
The person who modified it becomes the manufacturer
Think of CE marking as a snapshot of compliance at the moment of sale. Keeping it valid for new units comes down to watching three things: the legislation that applies to your product, the harmonised standards you use, and the changes you make to the product.
A simple change-control habit covers most of it. Before any design change, any standard revision or any new regulation’s application date, ask whether your technical file still describes what you ship.
Shipping units whose marking no longer matches the product carries the same risks as selling without CE marking: withdrawals, recalls and fines.
If one of these five changes is coming up for your product, we can tell you what it means for your technical file and what needs updating. Get a quote and we’ll take a look.
