How to verify an EU Declaration of Conformity: fraud and red flags when buying machinery

“It has CE marking. There is a certificate. It cleared customs.” Three assurances designed to end any discussion about machinery conformity.

The document looks official, the supplier sounds confident and customs did not stop the shipment. The buyer assumes somebody has already checked everything.

We see this scenario repeatedly. A machine clears customs, its owner produces an attestation supplied by the seller and says that “CE has been taken care of”. Then we read the document. It confirms far less than the buyer was promised.

At the top: “CERTIFICATE”, a logo, references to directives and a CE symbol. Further down: limitations on the assessment, identification of one particular sample, or a statement that the manufacturer must still draw up a Declaration of Conformity. In one document we examined, the right to use the marking was expressly conditional on drawing up the declaration and complying with the applicable directives. The document itself pointed to obligations it did not replace.

The seller nevertheless presented it as the answer to two different questions: whether the machine met the requirements and whether its documentation was complete. If a supplier understands the limits of an attestation but sells it as sufficient confirmation of conformity for the entire machine, that is not unfortunate wording. It is a deliberate misrepresentation to the buyer.

No document needs to be forged. An authentic document can be used while knowingly assigning it a meaning it does not have. Small print on an attestation does not excuse the large claim made in the sales offer.

The European Commission warns about these unregulated, often voluntary certificates. They may create the impression that they demonstrate compliance with EU law even though they are not a recognised means of doing so. They must not be confused with certification performed by a notified body under the correct procedure and within the correct scope.

Then the machine clears customs and the seller gains another argument: “If anything were wrong, they would never have released it.” They released it. That does not mean they confirmed everything the salesperson said.

EU legislation separates the issues explicitly. Release for free circulation under a customs procedure must not be treated as evidence of compliance with Union law. Customs release does not turn an attestation into an EU Declaration of Conformity or an EC or EU type-examination certificate. Nor does it extend the scope of an assessment already carried out.

The buyer may therefore receive the machine, pay freight and duties, install it in the factory and only then discover that the document used to reassure them before purchase does not establish what it was supposed to establish.

That is why How to verify an EU Declaration of Conformity starts with a more basic question: did you actually receive a declaration? After that, you must verify the issuer, the connection to the specific machine and the legal meaning of every supporting document invoked by the supplier.

The machine cleared customs. That does not prove the seller told the truth.

1. First check whether you received a declaration: a certificate is not a substitute

“It is even better than a declaration. An independent organisation issued it.” That claim is designed to persuade a buyer that the requested document has been replaced by something superior. Stop asking questions, the argument goes. Be grateful that the supplier arranged extra certification.

An EU Declaration of Conformity is not a cheaper version of a certificate. It cannot be replaced by a document carrying a more recognisable logo. The Machinery Regulation (EU) 2023/1230, which generally applies from 20 January 2027, assigns different functions to these documents. Before examining signatures and numbers, establish what kind of document is in front of you.

EU type-examination is a procedure, not a decorative title

EU type-examination—module B—is defined in Annex VII to the Machinery Regulation. A notified body evaluates the technical design from the technical documentation and examines a complete specimen representative of the intended production.

It is not enough for somebody to review uploaded files, find a few standards references and issue a document headed “Conformity”. An EU type-examination certificate has defined content. It identifies the notified body, the manufacturer and the examined type. It includes a statement on compliance with the applicable requirements, relevant dates and any conditions attached to issue.

Its significance comes from the procedure performed, not from the font size used for the word “CERTIFICATE”.

Even a valid EU type-examination does not complete the entire conformity assessment. Under the B+C route, the manufacturer must ensure that production machinery conforms to the approved type and to the Regulation. The manufacturer then draws up the EU Declaration of Conformity.

The notified body examined the type. The manufacturer remains responsible for what was built and supplied.

A voluntary attestation does not become a mandatory certificate because a salesperson says so

Suppose the buyer receives an attestation covering selected tests or a limited documentation review. The supplier presents it as evidence that the complete conformity assessment has been performed. When asked for the declaration, the supplier replies: “But you already have the certificate.”

This is where the discussion must stop being about appearance and return to actual scope.

An attestation may cover only a defined part of an assessment. A test report may contain useful measurements. Neither fact proves that an EU type-examination took place or that the manufacturer drew up an EU Declaration of Conformity.

The European Commission warns against unregulated certificates that create the impression of establishing compliance with EU law. They must not be equated with certification required by legislation and carried out by a notified body within the appropriate scope.

If a supplier knows these limitations but deliberately presents an attestation as the required certificate or as a substitute for the declaration, the supplier is misleading the buyer. This is not “additional safety”. It is an assertion that legal obligations were fulfilled when the document does not establish that they were.

You do not always need to forge a certificate. Sometimes it is enough to lie about what it does.

Not every machine requires type-examination, but every machine requires the correct procedure

Do not correct one mistake by introducing another. The Machinery Regulation does not require EU type-examination for every machine. The applicable procedure depends on the product category and the conditions set by the legislation. Internal production control is available for categories not listed in Annex I.

The absence of a notified body certificate does not automatically mean non-compliance. Its presence does not automatically guarantee compliance either.

The first question is therefore not: “Do you have some kind of certificate?” It is: “Which conformity assessment procedure did you apply, and where is the EU Declaration of Conformity for this machine?”

Five attachments in an email do not replace the one document that is still missing.

2. The manufacturer exists—but does not know it issued the declaration

In one case from our practice, a Chinese supplier issued a declaration using the identity of a real Italian company. The company was named as the manufacturer even though it knew nothing about the use of its details.

No fictitious company was needed. A real one was more convincing.

That is precisely why a quick internet search could reassure the buyer. The company existed, worked with machinery and had a European address. At first glance, the verification result looked excellent.

But the search confirmed only that the company existed. It did not confirm any relationship with the machine being supplied.

In such a case, the declaration does not merely contain an accidental address error. It assigns responsibility to a company that never accepted it. The manufacturer is apparently European. The only problem is that it does not yet know it became the manufacturer of this machine.

Someone else’s company details are not a mandate

The Machinery Regulation requires identification of the manufacturer and, where relevant, the authorised representative. The declaration is issued under the sole responsibility of the manufacturer. It must also identify the person signing and state on whose behalf that person signed.

These fields are not spare spaces for the name of a company that looks reassuring on official paperwork.

Knowingly issuing a declaration under another company’s identity, without its knowledge or authority, is impersonation of the manufacturer. It is not a documentation service. It is not “CE support”. It is not a minor clerical defect that can be cured by changing the footer.

A related mechanism appeared in a public warning issued by Ente Certificazione Macchine in February 2023. It concerned a false declaration for a TCM-XB315 hydraulic metal baling press. An Italian organisation had been assigned the role of “Technical File Representative”, which it expressly denied performing.

It was not named as the manufacturer. That distinction matters. In both cases, however, the buyer could find a real organisation in the declaration whose involvement existed only on paper.

The presence of a European company in a document does not establish that the company agreed to be there.

Manufacture in China is not evidence of fraud

Impersonation must be distinguished from legitimate outsourced manufacture. An Italian company may commission the design or manufacture of machinery in China, place it on the market under its own name and perform the obligations of the manufacturer. It does not need to machine every component itself or own the building in which the equipment was assembled.

The problem is not a Chinese factory combined with an Italian name on the declaration. The problem is an Italian name used without that company’s genuine involvement.

In the first case, a manufacturer uses a contractor. In the second, somebody else’s identity is used to persuade a buyer that a different organisation stands behind the machine. Country of origin does not resolve that distinction. The actual roles must be confirmed.

Ask the company, not only the person who sent you its details

Where doubts arise, contact the entity named in the declaration through a channel established independently of the supplier. Do not rely exclusively on an email address printed in the suspicious document or on the person introduced by the seller as “our contact in Europe”.

Attach the declaration, the machine identification data and a photograph of the rating plate. Ask about this document and this machine:

“Do you confirm that your company is the manufacturer of the identified machine and that the attached declaration was issued by you or under your authority?”

If the company is named as an authorised representative, ask it to confirm that role and the scope of its mandate. Do not turn it into the manufacturer merely because its office is closer to your factory.

“Do you work with companies in China?” is far too broad. The answer may truthfully be “yes” while telling you nothing about the declaration under investigation.

No response is not proof of forgery. An unequivocal denial from the company supposedly responsible for the document is not a minor formal omission. It requires identification of the real manufacturer and the actual basis for the claimed conformity.

A replacement PDF from the same supplier does not close the case merely because the company name has changed.

A company register tells you whether an organisation exists. It does not tell you who signed in its name or accepted its responsibility.

3. The certificate number matches, but the machine model does not

“We checked the certificate. It is in the database.” Good start—provided somebody also read the rest of the record.

A genuine number can be inserted into an altered document. A supplier can also send an authentic certificate for a different product. In both cases, a search engine may find the number. It will not determine whether the supplier is using it within its real scope.

The number stays; the data changes hands

TÜV Rheinland publishes a warning concerning certificate number AK 50352718 001 for an air compressor. According to the issuer, the company name in the document was changed.

This is not a theoretical possibility invented for training. The issuer identifies a specific certificate number and a specific type of manipulation.

A buyer who checks only the number may never see the problem. The database contains the certificate. The product category looks familiar. Verification ends. The buyer checked precisely the element that had not been changed.

Compare the supplied copy with the issuer’s data: the organisation covered by the document, product designations, scope, dates and version. A matching string of characters in the upper corner is not enough.

A number can be copied without performing a single test. That is exactly what makes the technique attractive to a fraudster.

Finding a certificate number proves that the number exists. It does not prove that the rest of your PDF is genuine.

“It is the same series.” Which configuration was actually assessed?

The second mechanism does not require any PDF editing. Imagine that a supplier presents an authentic EU type-examination certificate for a press in a defined configuration. The ordered version uses a different workpiece feed arrangement and different safeguards for the working area. The documents do not explain whether that version falls within the assessment.

The seller replies: “It is the same series. The differences are minor.”

The frame looks similar. The colour matches. Only the way a person can reach dangerous movement has changed. Apparently a detail—especially to somebody who will never operate the press.

An EU type-examination certificate must identify the examined type and state any conditions attached to its issue. It may include annexes. The Regulation also provides for additional approval of modifications that may affect conformity or the conditions for validity of the certificate, recorded as an addition to the original certificate.

That does not mean every variant always requires a separate certificate. It means the assessed scope must be established from the documentation, not from similar catalogue names.

If a supplier knows that the offered configuration is outside the scope of the certificate but states that it is covered, the buyer is being deliberately misled. The authenticity of the certificate does not make that statement true.

Compare document with document—and then compare both with the machine

Verification should operate on two levels.

First, compare the supplied copy with the issuer’s information. Check the full document designation, responsible organisation, models, assessment scope, dates and all available annexes. If a public database provides only an abbreviated entry, ask the issuer to confirm the copy and explain its scope. “The number was found” does not answer those questions.

Second, compare the documentation with the equipment being supplied. Match the identification in the EU Declaration of Conformity against the machine marking, instructions and supporting documents. Examine the safety-relevant configuration, not merely the model name.

A type-examination certificate identifies a type. It need not list the serial number of every unit subsequently manufactured. The absence of the individual machine’s serial number from that certificate does not automatically make it irrelevant. There must, however, be a demonstrable connection between the delivered unit and the approved type.

Instead of asking the body only, “Does this number exist?”, ask:

“Does the attached copy correspond to the document you issued, and does its scope cover the identified model and the described configuration?”

That question cannot be dismissed so easily with a screenshot from a search page.

A certificate covers what was assessed—not everything the supplier happens to list in its catalogue.

4. The organisation is notified—but notified for what?

“Check it yourself. We are on the European Commission’s list.” The supplier sends an identification number and a link to NANDO. The organisation is genuinely listed. Its name and address match.

That still does not establish that it was authorised to perform this assessment for this machine.

Notification has a defined scope. It is not a general licence to issue any certificate under a familiar logo.

One number, specific powers

The Commission allocates one identification number to each notified body, even where that body is notified under several pieces of legislation. The digits alone do not reveal the products and procedures covered by its notification.

Suppose a body is notified to perform EU type-examination of vehicle servicing lifts. A press supplier produces a document issued by the same organisation and says that type-examination of the press has also been “taken care of”.

The organisation exists. It is notified. Even the machinery legislation may match. The scope does not.

This is not a missing stamp that can be added later. Authority to assess one machinery category does not create authority to assess every other category.

“If they can assess a lift, they can surely assess a press.” Perhaps they have relevant technical expertise. But you are not checking a salesperson’s opinion about a laboratory’s versatility. You are checking the legal scope of notification.

How should a notified body be checked in NANDO?

Go beyond the search result containing the body’s name. The verification should cover five elements.

For older documents, take account of transitional provisions. Authority to issue new certificates under the Regulation and the continued validity of an earlier EC type-examination certificate are separate questions.

If the body’s status has changed, investigate the effect on the specific document. Do not assume that every earlier certificate automatically became invalid. Do not assume that the change is irrelevant either.

NANDO is used to verify notification. It is not a database confirming the authenticity of every certificate copy supplied by a seller. Authenticity must be checked with the issuer.

A link to the Commission does not finish the verification. Sometimes it merely reveals where the supplier hoped you would stop reading.

The same logo is not enough—and neither is accreditation

For an international group, identify the exact legal entity responsible for the assessment. Do not assume that notification of one group company automatically extends to every company using the same brand.

This does not prohibit the use of other laboratories. The Machinery Regulation permits subcontracting and the use of subsidiaries, but the notified body retains full responsibility for the tasks performed. It must be clear who acted on its behalf and who owns the result. “They are our partner” does not settle that issue.

The same applies to the argument: “But the laboratory is accredited.” Accreditation confirms competence within a defined scope and may support notification. It is not notification itself.

An accreditation certificate does not replace verification that the organisation was authorised to perform the specific conformity assessment procedure required by the Regulation.

A genuine organisation can issue a document outside its notified role

An organisation may provide many services. Acting as a notified body in one field does not mean that every document it issues was produced in that capacity.

This is why the Commission’s warning on unregulated certificates also matters where the issuer did not act as a notified body within the appropriate scope. The buyer recognises the name. The seller omits the fact that the attestation does not document the required procedure.

If that omission is deliberate, the organisation’s credibility is being used to mislead the buyer. The document need not be forged. It is enough to attribute to it statutory authority that the issuer was not exercising when the document was produced.

Ask the issuer directly: “Was this document issued within the scope of your notification for this product category and this procedure?”

The body is on the list. You still need to establish whether its listed powers cover what the seller promises.

5. “We have a company in Europe.” Fine—what role does it perform?

Imagine a buyer receiving documents for machinery from a Chinese manufacturer. An organisation in Türkiye issued an attestation, while a company with an address in Cyprus is listed as the contact for conformity matters. The supplier concludes: “Everything has been handled in Europe.”

Reassuring words. Still no clear allocation of responsibility.

Who is the manufacturer? Who acts under its mandate? Did the issuer of the attestation perform a required procedure? What is the Cypriot company actually responsible for?

This arrangement is not, by itself, evidence of non-compliance. But three addresses in different countries do not combine automatically into a valid conformity assessment. The seller has supplied geography. You still need responsibility.

The EU, the EEA and Europe are not the same thing

The European Economic Area comprises the EU Member States together with Norway, Iceland and Liechtenstein. Those three countries participate in the internal market under the EEA Agreement. That also matters for product legislation.

References to the Union must be read in the light of the Agreement and the incorporation of the relevant act. For new legislation, verify its incorporation status and applicable dates.

It is therefore wrong to reject a Norwegian entity simply because it is outside the EU. It is equally wrong to extend EEA treatment to any country a supplier chooses to describe as European.

The Machinery Regulation requires an authorised representative to have the appropriate establishment and to hold a written mandate from the manufacturer. When assessing establishment, consider the relevant legislation and agreements. When assessing authority, verify the actual mandate.

Writing “European Representative” on a website does not create a legal mandate. A service can be renamed in English; authority cannot be added by typography.

Türkiye: a customs union is not EU membership

Türkiye is not a member of the EU or the EEA. It does, however, have separate arrangements with the Union concerning the customs union, alignment of technical legislation, notification of bodies and recognition of specified conformity assessment results.

Do not reject a document solely because a Turkish body issued it. Check the basis for recognition, the applicable act, the procedure and the issuer’s authorised scope.

Do not accept the opposite shortcut either: “Türkiye has an agreement with the Union, so all our certificates are EU certificates.” An agreement does not authorise every laboratory to perform EU type-examination. It does not turn every voluntary attestation into a document required by the Regulation. Nor does it automatically determine whether a particular company can perform another legal role, such as authorised representative.

Authority is verified for a specific entity and task. It is not granted to an entire country.

Cyprus is in the EU, but the word “Cyprus” is still not enough

The Republic of Cyprus is an EU Member State. However, application of EU law is suspended in the areas where the Government of the Republic of Cyprus does not exercise effective control.

Verification cannot stop at the phrase “company in Cyprus”. Establish where the entity is registered, where it is established and which role it claims to perform. Do not draw conclusions from the English country name printed on a document.

Even a correctly registered company established where EU law applies does not thereby become a notified body or the authorised representative of any manufacturer that names it. It may be a commercial agent, organise transport or provide administrative services. Each activity may be legitimate. None proves authority to act on conformity matters for this machine.

“We have an office in Cyprus” tells you where correspondence can be sent. It does not tell you who signs the declaration or under what authority.

Verify the entity and its role, not the prestige of its address

Request the full company name, registration number, registered office and an unambiguous description of its role. Check those details in the appropriate register and then verify the claimed role.

If the company acts for the manufacturer, establish the mandate. If it relies on notification, check the scope. If it is the importer, do not treat its presence as evidence that testing was performed.

The organisations do not all need to come from the same country. Each one does need to perform the task attributed to it.

If a supplier knowingly presents an ordinary contact address as “the European entity responsible for conformity”, even though the company performs no such role, that is not harmless simplification. The address is being used to manufacture a false sense that responsibility has already been settled.

Company registration is not notification. An address in the Union is not a mandate. “We have someone in Europe” is not an answer about machinery conformity.

6. “I am only the importer.” The obligations do not end there

Suppose a domestic supplier imports a machine from outside the Union. Before purchase, it promises full conformity and complete documentation. The buyer later demonstrates that the certificate covers a different model. The answer changes immediately: “We are not the manufacturer. Take it up with the factory.”

A moment ago, the supplier was confirming everything. Now its role apparently extends only to forwarding the invoice.

An importer is not always the manufacturer. It does, however, have its own obligations. Those obligations cannot be discharged by redirecting the buyer to China.

Forwarding an email from the factory is not enough

Before placing machinery on the market, the importer must ensure that the manufacturer has carried out the appropriate conformity assessment procedure, prepared the technical documentation, applied the required marking and supplied the required documents. It must also ensure that the instructions and relevant information accompany the machine.

This does not require the importer to repeat every manufacturer test personally. Nor does it allow the importer to treat any attachment headed “Conformity” as proof that the obligation was performed.

If the importer considers, or has reason to believe, that machinery does not conform to the Regulation, it must not place it on the market until conformity has been brought about. If the problem emerges after placing on the market, appropriate corrective action is required and, where relevant, withdrawal or recall. Where a risk exists, duties to inform the competent authorities may also arise.

“The manufacturer says it is fine” does not eliminate a discrepancy the importer already knows about. If the importer deliberately conceals that discrepancy and continues to assure the buyer that the documentation is complete and correct, it is no longer merely receiving somebody else’s false information. It is passing that assurance on as reliable.

The importer must also ensure the availability of the technical documentation as required.

The “Forward” button is not a conformity verification procedure.

A copy of the declaration is not the complete technical documentation

The importer must keep a copy of the EU Declaration of Conformity for at least ten years after the machinery has been placed on the market. Separately, it must ensure that the technical documentation can be made available to market surveillance authorities on request.

These are two duties. A folder full of declarations does not automatically fulfil the second.

This does not mean every buyer is entitled to receive the complete design file. Refusal to hand over all drawings is not, by itself, proof that technical documentation does not exist. But the importer should have ensured that the documentation can be supplied to the competent authority.

“The manufacturer holds the documentation” may be a correct statement. “We do not know whether the manufacturer will give it to us” is not a method of ensuring availability.

An authorised representative does not take over responsibility for the design

Another explanation is: “Our authorised representative is responsible for conformity.” Check what its written mandate actually covers.

The Machinery Regulation expressly excludes from that mandate the manufacturer’s obligation to ensure compliant design and manufacture and the obligation to draw up the technical documentation. Those duties remain with the manufacturer.

A manufacturer may use specialists to prepare documentation. It does not transfer its legal obligations to an authorised representative merely by appointing one.

The authorised representative does have specific tasks. These include keeping the documentation and declaration available to market surveillance authorities, supplying required information and cooperating to eliminate risks. It may perform further acts within the relevant procedure and the limits of its mandate.

It is neither a decorative address on the declaration nor a substitute manufacturer responsible for everything. Its appointment does not remove the importer’s own obligations.

Manufacturer in the catalogue, intermediary whenever conformity is questioned

There are situations in which an importer becomes subject to the manufacturer’s obligations. Suppose it commissions machinery in China and places it on the market under its own name or trade mark. It markets the equipment as its own product but, when asked for documentation, hides behind the overseas factory.

The Regulation does not make manufacturer obligations depend on who personally welded the frame. Article 17 treats an importer or distributor as the manufacturer where it places a product on the market under its own name or trade mark. It also covers modification of a product already placed on the market where the change may affect conformity.

That second case is not limited solely to a substantial modification, which is a separate issue also addressed in Article 18.

Simply adding the importer information required by law does not mean the machine has been placed on the market under the importer’s own brand. Identification as “importer” and presenting a product as one’s own are different situations.

When verifying the declaration, compare the supplier’s claimed role with the offer, instructions and machine marking. It should be clear who the manufacturer is, who acts under its mandate and which obligations the importer performs.

A private label does not end with the sticker. Manufacturer obligations do not require ownership of a factory.

7. “The machine cleared customs.” That is not a conformity assessment result

Suppose a buyer identifies a specific discrepancy: the presented certificate applies to another model. The buyer asks for an explanation and receives a customs release document.

“If the documents were wrong, customs would not have released the machine.”

The question concerned the certificate’s scope. The answer concerns the movement of goods across a border. The discrepancy remains unexplained. The seller is trying to cover it with the authority of a public body.

The legislation says it directly: customs release is not evidence of conformity

Article 27 of Regulation (EU) 2019/1020 is explicit: release for free circulation is not to be deemed proof of compliance with Union law.

This is release under a customs procedure. It is not approval of the machine’s design, confirmation of safeguard effectiveness or verification that the manufacturer genuinely issued the supplied declaration.

That does not mean border controls concern only duties and taxes. The Regulation provides for risk-based controls on products. Missing required documentation or reasonable doubt about authenticity, accuracy or completeness may justify suspension of release for free circulation.

But border control is not a complete conformity assessment performed on behalf of the manufacturer for every imported machine. The absence of a customs hold does not allow anybody to add “checked and approved by customs” to the declaration.

Customs can release the shipment. That does not mean customs approved the machine.

Even an earlier customs hold does not turn release into certification

The Regulation also covers cases where a product is released after suspension because market surveillance authorities have not requested continued suspension within four working days, provided the other release requirements and formalities have been completed.

Release may therefore follow from the operation of the procedure rather than confirmation of every characteristic of the machinery. It does not legalise any underlying non-compliance.

Accordingly, “They stopped it first and then released it, so everything was checked” still requires an answer to two questions: what was actually examined, and what decision was made?

Four working days on a calendar are not four working days of machinery testing.

A customs document does not answer a question about a missing guard

Return to the buyer who discovered a model mismatch. The release document does not explain the discrepancy. It does not prove that the signatory was authorised or that the supplied configuration was included in the relevant assessment.

If the seller knows about the problem but deliberately presents customs release as proof that no problem exists, the seller is misrepresenting the significance of an official procedure. This is not an additional technical argument. It is an attempt to end an uncomfortable conversation.

Answer precisely: “The customs release does not explain the discrepancy between the document and the machinery being supplied. Please identify the document covering the correct model and configuration and arrange confirmation of its scope by the issuer.”

The same principle applies to physical safety defects. If a person can reach dangerous movement, the protective arrangement must be assessed. Customs documentation does not replace stopping-time measurement or verification of an interlock.

Authenticating a declaration and assessing the safety of the machine are different tasks. You may identify the genuine issuer and still find a design that fails to meet the requirements.

Customs release also does not remove the importer’s obligations when non-compliance is identified after placing on the market. Equipment already installed in the factory may still require corrective action.

The authority released the goods. It did not release the manufacturer or importer from their obligations.

8. Practical verification—and what to do with the result

Document verification should leave behind something more useful than: “The supplier explained everything.”

What exactly was explained? Which discrepancy? What evidence supported the answer?

If you still do not know whether a certificate covers the supplied machine, the issue has not been resolved. It has been discussed. That distinction matters, especially when both outcomes become the same “OK” in an acceptance report.

Five findings that should remain after verification

The following structure organises the review. It does not replace the machine’s technical assessment and cannot guarantee detection of every forgery.

The objective is not to collect five assurances. It is to establish five findings that another competent person can reconstruct.

When contacting the manufacturer, make the question document-specific:

“Do you confirm that the attached declaration was issued by you or under your authority and that it covers the machine with the stated model, identification number and described configuration? Please also confirm the role in which your company is named.”

Send a separate question to the notified body or other issuer about the authenticity and scope of its own document. Do not expect that organisation to confirm the manufacturer’s declaration on the manufacturer’s behalf.

Not every problem can be repaired with a new PDF

The result must be described according to what was actually established.

A confirmed clerical error requires correction by the proper entity and verification of the corrected version. Do not edit somebody else’s signed declaration yourself merely to make it match the machine plate.

An incorrectly drawn-up declaration is a formal non-compliance requiring correction. It is not automatically proof of forgery.

An unexplained discrepancy remains unexplained. If the certificate’s scope has not been confirmed, record exactly that. A lack of response does not automatically prove fraud, but it does not establish conformity either. A commissioning deadline does not manufacture missing evidence.

Confirmed use of another company’s details or confirmed alteration of a document requires investigation of its origin, the real economic operator roles and the actual basis for claimed conformity. Do not accept another version without asking why the earlier one contained false information.

“We sent the wrong file.” Perhaps. You must still determine whether the file was wrong or whether the assurance used to sell the machine was wrong.

If the problem concerns the design, safeguarding or performance of the required conformity assessment procedure, correcting the declaration does not remove it. Depending on the findings, technical measures, further assessment, corrective action or notification of the authorities may be required.

A corrected declaration can fix an error in the declaration. It cannot repair a guard that was never installed.

Keep the document the supplier told you to delete

Retain every version of the declarations and certificates received during the purchase, photographs of the marking, correspondence and confirmations from issuers. For each finding, record who confirmed it, when it was confirmed and which machine version it covered.

This is not about producing another binder for the shelf. It is about knowing what changed and why after a file is replaced.

A useful review result might read: “Manufacturer and origin of the declaration confirmed. Coverage of the delivered configuration by the certificate not confirmed. Clarification from the issuer required.”

That is far more valuable than “documents checked”. It identifies the work completed and the issue still open.

A replacement document should not erase the audit trail of its verification, particularly where the earlier version was used to justify conformity before the contract was signed.

You are not buying a document; you are buying a machine

An EU Declaration of Conformity should identify real responsibility for a specific product. Verification is not a contest to find the most persuasive logo, the longest standards list or the most European-looking address.

Not every defect means fraud. But knowingly presenting an attestation as mandatory certification, using somebody else’s company details, or claiming a scope that a document does not cover does not become an innocent mistake merely because the machine reached the factory.

The review must establish who declares conformity, for which machine and on what basis. Where confirmed information ends, leave an open question. Do not write the supplier’s missing answer yourself.

You are not buying a declaration file. You are buying machinery. The documents must support its conformity—not distract you from the machine itself.

Sources and legal basis

Machinery Regulation (EU) 2023/1230—consolidated text on EUR-Lex. The legal basis for sections 1–6 and 8 includes Articles 3, 10, 12–13 and 17–18 on roles and obligations; Articles 21–22 and Annex V on declarations; Article 25 and Annexes VII–VIII on EU type-examination and conformity to type; Articles 32–36 on subcontracting, accreditation and notification scope; Article 46 on formal non-compliance; and Articles 52 and 54 on transitional provisions and application dates. Annex IV addresses technical documentation.

The discussion concerns the regime generally applicable from 20 January 2027. It does not imply that a declaration under the earlier machinery regime can be converted merely by replacing its heading.

Regulation (EU) 2019/1020—text on EUR-Lex. The basis for the introduction and section 7 includes Article 25(3) on risk-based controls, Article 26 on suspension of release for free circulation, and Article 27 on release conditions, the four-working-day period and the rule that customs release is not evidence of compliance with Union law.

European Commission—the 2022 “Blue Guide”. Relevant explanations include section 3.1 on the manufacturer and outsourced production, section 2.9.2 on the EEA and section 2.9.4 on the separate arrangements with Türkiye. The Guide does not replace the legislation applicable to a specific machine.

European Commission—“Machinery”, section “Unregulated certificates warning”. This warning supports the introduction and sections 1 and 4: voluntary attestations must not be confused with certification required by law and performed by a notified body within the proper scope.

European Commission—“Notified bodies” and the NANDO system within the Single Market Compliance Space. These sources support verification of a body and its tasks for the relevant legislation, product and procedure. Checking notification is separate from confirming the authenticity of a particular document with its issuer.

Ente Certificazione Macchine—“Official communication: false EC Declaration of Conformity”, 16 February 2023. This is the public case referenced in section 2 concerning the TCM-XB315 hydraulic metal baling press and the organisation’s denial that it acted as “Technical File Representative”. It is a historical case involving an EC Declaration of Conformity and is distinct from the author’s account concerning use of an Italian manufacturer’s identity.

TÜV Rheinland—“Warning List”. The case in section 3 concerns the “Air Compressor” entry, document AK 50352718 001, and alteration of the company name. The issuer describes the perpetrator as unknown. The appearance of a company name in an altered document does not establish that the named company performed the alteration.

EFTA—“EEA & Relations with the EU” and the EEA-Lex record for Regulation 2023/1230. These sources support section 5 on the composition of the EEA, incorporation of legal acts into the EEA Agreement and verification of the status of a particular act.

European Commission—“Green Line Regulation”. This supports the explanation of Cyprus and the suspension of EU law in areas where the Government of the Republic of Cyprus does not exercise effective control.

Nature of the examples. The case involving use of an Italian manufacturer’s details and the observations concerning documents presented during machinery purchases and customs release come from the author’s practice. The analysis concerns the content of attestations and the way they were presented to buyers, not independent authentication of every copy. Other scenarios are illustrative unless a public issuer warning is identified. The suggested questions, tables and recording method organise the verification process; they are not statutory forms.