EU Machinery Regulation Autonomous Mobile and Collaborative Machinery

The Regulation defines autonomous mobile machinery as mobile machinery with an autonomous mode where all essential safety functions for travel and work are ensured without permanent operator interaction. It also defines a supervisor and a supervisory function for remote, non-permanent surveillance that can receive information or alerts and give limited orders.

For an autonomous mobile platform, the compliance record should therefore describe the intended travel area, working area, danger zones, supervised and unsupervised states, remote start or stop commands, safe-position or safe-state commands, and the limits of any remote supervisory function.

For collaborative robots and shared-workspace machinery, Annex III section 1.3.7 requires protection against hazardous contact and adaptation to human-machine coexistence and interaction, including the psychological stress interaction can cause. Assess impact, crushing, collision, visibility, unexpected movement, maintenance access, and entry into a danger zone for the actual application.

For collaborative or shared-workspace operation, the risk assessment should state when a person may be near the machine, whether contact is foreseeable, what protective measures are built into the design, what warning or signalling devices are used, and how residual risks are communicated in instructions and markings.

The Regulation treats safety software as a machinery issue when software performs a safety function or when software updates and evolving behaviour can affect risk. It also includes EHSRs for protection against corruption and safety and reliability of control systems.

For autonomous or collaborative machinery, the technical file should connect safety functions to the implemented control architecture, software version, update assumptions, validation records, cybersecurity controls that protect safety, and test evidence for failures or foreseeable misuse. Where a competent authority has a reasoned need to check EHSR compliance, the Regulation can require source code or programming logic for safety-related software.

ISO 12100, ISO/TR 22100-4 and control-system standards are technical support, not legislation. A harmonised standard creates a presumption of conformity only for the Annex III requirements covered by the cited standard or parts when its reference is published in the Official Journal. The manufacturer remains responsible for uncovered hazards and for showing that the chosen edition and clauses fit the actual machinery.

The technical documentation must make it possible to assess conformity with the relevant EHSRs and include an adequate analysis and assessment of risks. For autonomous mobile or collaborative machinery, that means the file cannot stop at a generic CE checklist; it needs the hazard analysis, design rationale, standards or technical specifications, tests, calculations, control-system evidence, software evidence, instructions, markings, and residual-risk information tied to the actual machine configuration.

Instructions should be specific enough for the way the machine is used. For autonomous mobile machinery, the Regulation expressly calls for the intended travel, working areas, and danger zones. For human-proximity operation, instructions should also cover training, protective measures, residual risks, maintenance access, warning devices, and operating limits needed for safe use.

Autonomous or collaborative capability does not by itself prove that a notified body is required. The conformity route depends on whether the machinery or related product is listed in Annex I and, for Annex I Part B, whether applicable harmonised standards or common specifications cover all relevant EHSRs for that category and have been applied.

The route record should therefore separate three questions: whether the product is in Annex I Part A, whether it is in Annex I Part B, and whether all relevant EHSRs are covered by applied harmonised standards or common specifications. Substantial digital or physical modifications that create a new hazard or increase an existing risk can make the modifier a manufacturer and require a new conformity assessment for the affected machinery.