Used machine from abroad: what it must meet before start-up in Slovakia
A machine bought at a good price in China or from a German used-machinery dealer can become expensive once you put it into service. We explain when a new conformity assessment is needed, what the labour inspectorate checks and which modifications are most common.
A used machine from abroad is a sensible way for many manufacturers to increase production capacity. A new machine from a European manufacturer may have a longer delivery time and a higher price than a used machine or one imported from Asia. The problem often shows up only after unloading from the truck: the machine has no CE marking, the instructions are only in English or Chinese, the electrical cabinet is built for 480 V and 60 Hz, and the guards can be opened while the machine is running.
Such a machine may work technically, but the employer must not put it into use until it meets Slovak and European safety regulations. In case of an accident or a labour inspection, the operator is responsible, not the seller.
In this article we go through which regulations apply depending on where the machine comes from, what changes from 20 January 2027, which modifications are most common and how to include them in the budget before you buy.
What matters: where the machine comes from and whether it is new
The legislation distinguishes two situations: placing a machine on the EU market and using a machine in operation. Each is covered by different regulations and different obligations.
Machine from outside the EU — new or used
A machine imported into the EU for the first time is assessed as a new product placed on the market — even if it has been in use for years in its country of origin. It must meet the essential safety requirements of Slovak Government Regulation No. 436/2008 Coll. (Directive 2006/42/EC) and have technical documentation, an EU declaration of conformity and the CE marking. If the manufacturer does not provide this, the obligations pass to whoever places the machine on the market or puts it into service — often the buyer.
Used machine from the EU
A machine already placed on the EU market is not assessed again when it is sold to another user. The employer must, however, ensure that it meets the minimum safety requirements of Slovak Government Regulation No. 392/2006 Coll. If instructions, guards or a working emergency stop are missing, they must be added regardless of whether the machine has the CE marking or an EU declaration of conformity.
Older machine built before CE
Older machines built before mandatory CE marking do not carry it and do not need it retrospectively, as long as they are not modified. They must, however, meet the minimum requirements for work equipment. Regulation 392/2006 accepts that measures for used equipment do not always have to be the same as for new equipment — what matters is that the risk is reduced to an acceptable level.
What changes from 20 January 2027
From 20 January 2027, Regulation (EU) 2023/1230 on machinery applies, replacing Directive 2006/42/EC. It applies directly in all member states, without national transposition. The decisive date is when the machine is placed on the market, not when the order is signed — a machine from a non-EU country delivered in February 2027 will already be assessed under the new rules.
For companies buying machines abroad, three changes matter most:
- Substantial modification is defined directly in the regulation for the first time. Whoever modifies a machine in a way the manufacturer did not foresee, creating a new hazard or increasing an existing risk, becomes the manufacturer with all its obligations.
- Cybersecurity and software — changes to control or safety software must not compromise safe operation. Even a program change can be a substantial modification.
- Digital instructions are allowed, but on request the supplier must provide a printed version free of charge.
For imports from non-EU countries, the importer’s obligations also grow: checking that the manufacturer carried out the conformity assessment, prepared the documentation and affixed the CE marking, putting its own contact details on the machine and keeping the declaration of conformity for ten years.
The most common non-conformities on imported machines
The same shortcomings come up again and again during machine inspections. An experienced engineer will find most of them in a single visit.
- Guards without interlocking — doors to the working area can be opened during operation, or there are gaps in the guards through which hazardous parts can be reached.
- Emergency stop does not stop all hazardous movements, or is wired through a standard rather than a safety circuit.
- Electrical equipment for a different voltage and frequency, components with UL certification only, no lockable main switch, insufficient protection against direct contact.
- Controls — safety functions handled by the program in a standard PLC instead of a safety relay or safety PLC.
- Language — HMI, warning labels and instructions only in a foreign language. The instructions for use must be in the official language of the country.
- Missing documentation — electrical diagrams, spare parts list, declaration of conformity.
How a machine upgrade works
An upgrade does not start with buying guards but with a risk assessment to EN ISO 12100. Without it, it is not clear what is really necessary and what is just nice to have.
- Site visit — the machine, its documentation and how you plan to use it in your production.
- Risk assessment and a list of non-conformities with regulations and harmonised standards.
- Proposed measures — design, protective and informative, in that order of priority.
- Implementation — guards and interlocks to EN ISO 14120 and 14119, safety circuits to EN ISO 13849-1, electrical equipment to EN 60204-1, program changes.
- Verification — validation of safety functions, inspection and testing of the electrical equipment.
- Documentation — instructions in Slovak, technical documentation, reports and, where a conformity assessment is carried out, the EU declaration of conformity.
If the machine is classed as designated technical equipment in Slovakia — for example certain pressure, lifting or electrical equipment — official tests and authorised persons are added. Plan for this in the schedule and the budget.
What it costs and when an upgrade does not pay off
The cost of an upgrade depends on the condition of the machine, not on its price. A cheap machine with missing guards and built for the American grid may need modifications costing as much as the machine itself. A newer machine from a European manufacturer, on the other hand, often needs only instructions, labels and an inspection.
The largest items are usually rebuilding the electrical cabinet, a new safety circuit and guarding of the working area. If the machine needs all three, the investment pays back much more slowly than expected at the time of purchase. That is why we recommend a site visit before signing the purchase contract — the difference can be used in price negotiations with the seller.
In the contract with a supplier from a non-EU country, it is worth including requirements for CE, a declaration of conformity, instructions in Slovak and electrical equipment for the European grid. Whatever the supplier does not deliver, you will pay for later.
Upgrades when linking machines into a line
A special case arises when you connect an imported machine to an existing conveyor, add a robot or link it with other machines. This creates an assembly of machinery, which as a whole needs its own risk assessment and its own conformity assessment — even if each machine has CE on its own.
In practice this means a common emergency stop, safeguarding of the transitions between machines and a safe control interface. These are cheapest to solve at the line design stage, not afterwards. When integrating machine tool loading and unloading or robotic cells, we include them in the project from the start.
Frequently asked questions
Is a CE sticker on a machine from China enough?
No. The CE marking alone does not confirm that the machine actually meets the requirements. Ask for the EU declaration of conformity, check whether the manufacturer lists the standards applied, and have the machine assessed before putting it into service.
The machine has an EU declaration of conformity. Can we simply put it into production?
No. Paper is patient, and a declaration does not mean the machine is in order. In case of an accident, the operator is primarily responsible. The operator can then sue the manufacturer because the EU declaration of conformity did not reflect reality, but with Chinese manufacturers enforcing it is practically impossible.
Who is responsible if an accident happens on a machine that has not been upgraded?
The employer is responsible for the safety of work equipment under Slovak Act No. 124/2006 Coll. If the employer imported the machine from a non-EU country or substantially modified it, it may also bear the obligations of a manufacturer.
Do we have to upgrade the machine even if we buy it from a company in Germany?
A used machine from the EU does not need a new CE marking, but it must meet the minimum safety requirements and come with instructions in Slovak. A site visit will show whether technical modifications are needed.
How long does an upgrade take?
Adding documentation and labels takes days. Rebuilding the electrical cabinet and a new safety circuit take weeks, mainly because of component delivery times.