What is changing?
Physical guard only, access method, machine control, operating mode, speed, automation or intended use?
Product conformity and modifications
CE, UKCA & Machinery Modifications
Adding guarding can be a maintenance improvement, a safety upgrade or part of a wider modification. The conformity implications depend on what changes, who controls the work and whether machinery is being supplied or treated as new.
Guidance statusMarket rules checked 6 Aug 2026
- GB
- England, Scotland, Wales
- NI
- Separate arrangements
- Decision
- Project-specific
Direct answer
Does every guarding modification require a new conformity mark?
No. The answer depends on the nature and extent of the change, its effect on risk and operation, whether machinery is being assembled or supplied, and the applicable product legislation.
HSE guidance distinguishes ordinary refurbishment from substantial modification that can make machinery effectively “new” for product-supply purposes. Obtain competent advice where the boundary is uncertain.
Modification triage
Questions to answer before work begins.
This is an early scoping tool, not a legal determination.
Does risk change?
Are new hazards introduced, existing risk increased or the original protective strategy materially altered?
Who controls the project?
Machine owner, OEM, integrator, contractor or an organisation assembling several machines?
Is equipment being supplied?
Is a new machine, assembly or substantially modified product being placed on the market or put into service?
Great Britain market
Current UKCA and CE guidance must be checked by sector.
Current GOV.UK guidance provides routes for placing many products on the GB market using UKCA or recognised CE requirements. Product-sector rules, economic-operator duties, standards route and documentation still need to be checked for the specific machinery.
England, Scotland and Wales
Consult current UK product regulations and the UKCA/CE market guidance for the applicable sector.
Northern Ireland
Separate CE and CE/UKNI arrangements apply. Use the dedicated Northern Ireland guidance.
European Union
EU product rules and CE requirements apply when placing machinery on the EU market.
Official references
Primary guidance used for this page.
GOV.UK: placing UKCA or CE products on the GB marketCurrent market overview and responsibilities ↗GOV.UK: UKCA and CE regimes collectionMarket and technical guides ↗HSE: refurbished and modified machineryPUWER and substantial-modification context ↗HSE: equipment and machinerySupply, use and modification guidance ↗
Source review date: 225 August 2026. This page is general information and not legal or conformity-assessment advice.
