Every few weeks a European machine builder sends us the same email: please supply the CE certificate for this motor. We could send back a nice-looking PDF from a Shenzhen test house — plenty of our competitors do — and it would be worth nothing in your technical file. The honest answer is more useful, and more complicated: for a 48 V brushless motor, three of the four directives you are probably thinking of do not apply at all, one does, and the one that catches most people out is not on the list. Here is the whole map, with the article and annex numbers, so you can check us.
Quick Answer
- No LVD, and therefore no LVD CE mark. Directive 2014/35/EU Article 1 covers 50–1,000 V AC and 75–1,500 V DC. A 12/24/48/72 V DC motor is below the DC floor and outside LVD entirely.
- RoHS is the one that bites. Annex I category 11 of Directive 2011/65/EU is an open catch-all; previously out-of-scope EEE had to comply from 22 July 2019. That is the legitimate CE mark on a motor.
- The Machinery Regulation’s motor exclusion is conditional. Article 2(2)(p) excludes electric motors only “insofar as they fall within the scope of” the LVD or the Radio Equipment Directive. Below 75 V DC, it does not reach you.
- Ecodesign 2019/1781 does not apply. Its scope is induction motors rated for direct-on-line sinusoidal operation. A BLDC fails the first condition — so there is no legal IE4 class for it.
- EMC lands on your machine, not our motor. Directive 2014/30/EU Article 3(1)(2) defines apparatus as a finished unit intended for the end-user. A motor shipped to you for incorporation is not apparatus — until you resell it as a spare part.
- The date is 20 January 2027, not the 14th printed in the original Official Journal. See the corrigendum trap below.
The “CE Certificate” in Your Supplier Folder Probably Certifies Nothing
Start with the thing that causes most of the confusion: CE marking is a manufacturer’s self-declaration under a named piece of legislation. It is not a certificate issued by a laboratory. For an ordinary low-voltage motor there is no notified body involved and nothing for one to issue.
So when a Chinese supplier emails a one-page “CE Certificate of Conformity” with a test-house logo and the Low Voltage Directive named at the bottom, two things are wrong at once. The document type does not exist in EU law, and the directive it cites does not apply to a 48 V motor. A market surveillance authority reading your technical file will not treat it as evidence of anything. Worse, citing a directive that does not apply is itself a defect in the file.
What a component supplier can legitimately give you is a short list: a declaration of conformity for the legislation that genuinely applies, test reports as evidence, material declarations, and — for assemblies that go far enough — a declaration of incorporation. We will get to the exact list. First, the map.
Five EU Rules, One Motor — Which Ones Actually Bite
This is the table we now attach to quotations for European customers. The same motor gets completely different answers depending on its supply voltage and on who it is sold to.
| Legislation | Scope test | 48 V DC BLDC gearmotor | 230 V AC motor |
|---|---|---|---|
| LVD 2014/35/EU Low Voltage | Art. 1: 50–1,000 V AC or 75–1,500 V DC | Out of scope — 48 V is below the 75 V DC floor | In scope — CE mark + DoC |
| Machinery Reg. (EU) 2023/1230 | Art. 2(2)(p)(vi): motors excluded only insofar as they fall under LVD or RED | Exclusion does not apply — treat as component or partly completed machinery | Excluded — because it is in LVD |
| RoHS 2011/65/EU | Annex I cat. 11 open scope; in force for previously excluded EEE from 22 Jul 2019 | In scope — CE mark + DoC. This is the real one. | In scope |
| Ecodesign (EU) 2019/1781 | Art. 2(1)(a): induction motors, sinusoidal 50/60 Hz, direct-on-line, 0.12–1,000 kW, >50 V | Out of scope — not induction, not direct-on-line. No legal IE class. | In scope if ≥0.12 kW and DOL |
| EMC 2014/30/EU | Art. 3(1)(2): apparatus = finished unit intended for the end-user | Not apparatus when shipped to you for incorporation — obligation sits on your machine | Same logic |
| REACH (EC) 1907/2006 | Article supplier duties; SVHC >0.1% w/w | Applies — SVHC statement, SCIP where relevant | Applies |
Scope tests quoted from the consolidated texts on EUR-Lex. This table is our engineering reading, not legal advice — your notified body or compliance counsel signs off on your machine, not us.
Building the technical file for a new machine and not sure which documents to ask us for? Send the drive specification and target market and we will return the document pack with the quotation — tell us your application →
The 75 Volt Line: Why a 48 V Motor Has More Machinery-Law Exposure Than a 230 V One
This is the part that surprises experienced engineers, and it comes from reading one clause slowly.
Regulation (EU) 2023/1230 Article 2(2) lists what is outside the Regulation. Point (p) reads: “the following electrical and electronic products, insofar as they fall within the scope of Directive 2014/35/EU or of Directive 2014/53/EU” — and then lists household appliances, audio and video equipment, IT equipment, ordinary office machinery, low-voltage switchgear and control gear, and at point (vi), electric motors.
Almost every summary you will read online stops at “electric motors are excluded.” But the exclusion is conditional. It only operates insofar as the motor falls within LVD or RED scope. And LVD Article 1 is explicit: the Directive “shall apply to electrical equipment designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current.”
Two limits, one crossover. Below 75 V DC there is no LVD, so there is nothing for the exclusion to hang on:
| Motor supply | Inside LVD scope? | Machinery Reg. Art. 2(2)(p) exclusion? | Practical consequence |
|---|---|---|---|
| 12 V DC | No | Does not apply | Component or partly completed machinery. Assess against Annex III EHSRs; a declaration of incorporation may be appropriate for assemblies. |
| 24 V DC | No | Does not apply | |
| 48 V DC | No | Does not apply | |
| 72 V DC | No — still below 75 V | Does not apply | |
| 96 V DC | Yes | Applies | Excluded from the Machinery Regulation; handled under LVD with its own CE mark and DoC. |
| 110 V AC | Yes | Applies | |
| 230 / 400 V AC | Yes | Applies |
72 V is the interesting edge: it is the highest nominal DC bus we build in volume and it sits three volts under the LVD floor. A 72 V pack that floats to 84 V on full charge still has a rated voltage of 72 V, which is the figure LVD Article 1 refers to.
The practical inversion is worth stating plainly: the low-voltage DC motor that feels like the simpler compliance case is the one the Machinery Regulation can still reach. If you are choosing between a 72 V and a 96 V architecture for an AGV, that choice moves your motor between two different legal regimes — something no motor datasheet mentions. Our 24 V vs 48 V selection guide covers the engineering side of that decision; this is the paperwork side of it.
Is a Geared Motor “Partly Completed Machinery”? Where We Draw the Line
Article 3(10) defines partly completed machinery as “an assembly which is not yet machinery as it cannot in itself perform a specific application and which is only intended to be incorporated into or assembled with machinery or other partly completed machinery or equipment, thereby forming machinery.”
A bare motor has traditionally been treated as a component rather than partly completed machinery — it is closer to a bearing than to a robot arm. But the further an assembly moves toward being a functional sub-system, the weaker that argument gets. This is a genuine grey zone, and we would rather tell you that than pretend there is a bright line. Here is where we land, and what we will sign in each case:
| What you buy | Our classification | What we issue |
|---|---|---|
| Bare BLDC motor, leads out | Component | RoHS DoC, REACH SVHC, IEC 60034-1 type test report, datasheet |
| Geared motor (planetary or worm) | Component | As above + gearbox rating data, backlash and shaft load limits |
| Motor + controller kit, pre-parameterised | Borderline | As above + controller RoHS DoC, EN IEC 61800-3 test evidence for the pair |
| Drive wheel module: motor, gearbox, wheel, brake, mounting plate | Partly completed machinery | EU declaration of incorporation (Annex V Part B) + assembly instructions (Annex XI) + Annex IV Part B file |
| Complete tug or AGV chassis | Machinery | Not our scope — that is your DoC and your CE mark |
If we do issue a declaration of incorporation, the Regulation is specific about what comes with it. Article 16(2) requires the technical documentation set out in Annex IV Part B. Article 22(2) requires the declaration to follow the model structure in Annex V Part B, to be “continually updated”, and to be translated into the language required by the Member State where the product is placed on the market. Article 16(7) requires Annex XI assembly instructions. Article 16(3) requires both to be kept available to market surveillance authorities for at least 10 years.
That last one is the clause buyers should press hardest on. A declaration of incorporation from a supplier who will not exist in ten years, or who cannot produce the Annex IV file on request, is decoration. Ask who holds the file and in which language before you ask for the signature. The same logic drives the change-notification clauses we describe in our supplier quality agreement guide.
What Actually Changes on 20 January 2027
Article 54 of Regulation (EU) 2023/1230 states that it “shall apply from 20 January 2027”, and Article 51(2) repeals Directive 2006/42/EC “with effect from” the same date. There is no dual-running period for new products: on that Wednesday, the Machinery Directive stops being an option.
The corrigendum trap. If you download the Regulation as originally published in OJ L 165 of 29 June 2023, Article 54 reads 14 January 2027, and Article 51(2) likewise. A Corrigendum of 4 July 2023 moved that date and several related ones to the 20th — the consolidated text marks each with a ►C1◄ flag. The six-day shift in the headline date is harmless. What is not harmless is that the same corrigendum touched other deadlines in Articles 6, 47 and 50–54, including the Article 50(1) penalties notification date, now 20 October 2026. If your compliance calendar was built by reading the original PDF, rebuild it from the consolidated text.
Your installed base is safe. Article 52(1) provides that Member States “shall not impede the making available on the market of products which were placed on the market in conformity with Directive 2006/42/EC before” the application date. You do not re-certify machines already sold.
One genuine improvement for component supply chains: Articles 16(7) and 16(8) allow assembly instructions and the declaration of incorporation to be supplied in digital format, provided the product or its packaging carries a way to access them and the digital declaration stays online for at least 10 years. For a drive module shipped 2,000 units a year, that replaces a paper pack per carton with a durable QR label.
Counting backwards from the deadline, here is the schedule we are working to with EU customers:
| By when | Action | Why this date |
|---|---|---|
| Now – Oct 2026 | Audit which of your purchased drive assemblies are components vs partly completed machinery | Determines whether you need a DoI at all; drives every step below |
| Nov 2026 | Send suppliers the document list; get written confirmation of who holds the Annex IV file and in what language | Chinese factories need a full quarter to produce documentation they have never been asked for |
| Dec 2026 | Reissue declarations of incorporation against Annex V Part B structure | A DoI written to the 2006/42/EC Annex II 1B model is the wrong instrument after the switch |
| Before Chinese New Year (17 Feb 2027) | Close out any supplier document gaps | Chinese factories close 2–4 weeks; a document chased in February returns in March |
| 20 Jan 2027 | New machinery placed on the market must conform to 2023/1230 | Art. 54; 2006/42/EC repealed same day per Art. 51(2) |
Chinese New Year 2027 falls on 17 February. The 2027 State Council holiday schedule had not been published as of September 2026, so treat that as the astronomical date and get your supplier’s written shutdown and restart dates in the PO rather than assuming a duration.
The Document Pack: What We Can Sign, and What We Can’t
The most useful thing a component supplier can hand a machine builder is an accurate list of what it cannot provide. It stops you from writing impossible clauses into a purchase order and then discovering the gap during your own conformity assessment.
| Document | Can a motor factory issue it? | Notes |
|---|---|---|
| RoHS EU Declaration of Conformity | Yes | The legitimate CE mark on the motor. Names Directive 2011/65/EU. |
| REACH SVHC statement | Yes | Candidate list version and date must be stated; it is revised twice a year |
| Material / RoHS test reports per homogeneous material | Yes | Magnets, windings, housing, leads, connectors, PCB if fitted |
| IEC 60034-1 type test report | Yes | Hipot, insulation, temperature rise, no-load and locked-rotor data |
| EU Declaration of Incorporation | Yes — for drive assemblies | Annex V Part B structure; Annex IV Part B file held 10 years |
| Annex XI assembly instructions | Yes | May be digital per Art. 16(7) |
| EN IEC 61800-3 EMC test report for motor + controller | Yes — as evidence | Valid only for the tested cable type and length; see next section |
| LVD Declaration of Conformity for a 48 V motor | No | Out of LVD scope. Anyone issuing one is describing an obligation that does not exist. |
| Machinery DoC for the motor | No | A motor is not machinery. The DoC belongs to your finished machine. |
| Ecodesign / IE4 declaration | No | 2019/1781 covers induction DOL motors only. Ask for measured efficiency at your duty point instead. |
| EMC DoC for the bare motor | No | Not apparatus when supplied for incorporation — unless you resell it as a spare |
EMC: The One Obligation No Motor Certificate Can Cover
EMC Directive 2014/30/EU Article 3(1)(2) defines apparatus as “any finished appliance or combination thereof made available on the market as a single functional unit, intended for the end-user and liable to generate electromagnetic disturbance.” Recital 9 adds that components or sub-assemblies count as apparatus “if they are made available to the end-user.”
Read those together and the allocation is clear. A motor shipped to your factory to be built into an AGV is not apparatus; your AGV is. The EMC obligation lands on you, and no piece of paper from us can discharge it.
Two practical consequences we see go wrong:
- The cable is the antenna, and the test report is cable-specific. A power drive system is tested under EN IEC 61800-3 with a defined motor cable type and length. Our bench results are obtained with a short shielded cable and a 360° shield bond at both ends. If your machine runs five metres of unshielded cable in a drag chain, the emissions profile is not the one in the report and your pre-compliance scan will show it. Ask for the tested configuration, not just the pass/fail page.
- The spare-parts trap. The moment you list that same motor in a web shop for end users to buy as a replacement, it is being made available to the end-user and it becomes apparatus in its own right — needing its own EMC assessment, CE mark and declaration. Distributors get caught by this constantly, because nothing about the product changed; only the customer did.
If you are still choosing a controller, the filtering and switching-frequency decisions that dominate your EMC result are covered in our BLDC controller selection guide, and the AC-versus-BLDC architecture trade-off for tugs in AGV tug motors: BLDC vs AC induction.
Write It Into the Purchase Order
Compliance documents arrive on time when they are contract deliverables and late when they are a favour. Six clauses we are happy to sign, and that you should be asking every drive supplier for:
- Name the legislation, not the marking. Write “EU Declaration of Conformity to Directive 2011/65/EU (RoHS)” rather than “CE certificate”. You will get a real document instead of a decorative one.
- Require the REACH candidate list version and date on the SVHC statement, and a duty to reissue within 30 days of each update.
- For assemblies, specify Annex V Part B and the target Member State language, with the Annex IV Part B file held and producible for 10 years.
- Require the EMC tested configuration — cable type, length, shield termination, switching frequency — not just the verdict.
- Add a change-notification clause covering magnet grade, winding, insulation class, bearing supplier, controller firmware and any material substitution, with written notice before shipment.
- State who the EU importer is. Under the Regulation the importer carries its own obligations; if you buy FOB Ningbo, that is you. Decide it on paper before the first container, not after.
For the commercial side of that first order — supplier vetting, payment terms and shipping — see our guide to importing BLDC motors from China, and for what to check when the pallet lands, the incoming inspection checklist.
Our Own Position, Stated Plainly
We are a motor and drive manufacturer in Ningbo, not a notified body and not your authorised representative. We hold ISO 9001. We issue RoHS declarations, REACH SVHC statements, IEC 60034-1 type test reports and, for planetary geared drive assemblies and drive wheel modules, EU declarations of incorporation with Annex XI assembly instructions. We do not issue LVD declarations for sub-75 V products, Machinery declarations of conformity, or Ecodesign IE-class declarations, because none of those instruments exist for what we make.
If a competing supplier offers you all three, that is not a stronger compliance package. It is a signal that nobody at that company has read Article 2(2)(p).
Frequently Asked Questions
Does a 48V BLDC motor need a CE mark?
Yes, but only for RoHS. LVD 2014/35/EU Article 1 covers 50–1,000 V AC and 75–1,500 V DC, so a 12/24/48/72 V DC motor sits below the DC floor and is outside LVD — there is no LVD CE marking or declaration for it. RoHS 2011/65/EU is different: Annex I category 11 is an open catch-all and previously out-of-scope EEE had to comply from 22 July 2019. RoHS conformity is declared with a CE mark and an EU DoC, so that mark on the motor is legitimate. It certifies restricted substances — nothing about electrical or machinery safety.
Why will a motor supplier not give me a CE certificate for the motor?
Because for most of the directives buyers have in mind, no such document exists. CE marking is a manufacturer’s self-declaration under named legislation, not a certificate issued by a test house, and no notified body issues one for an ordinary low-voltage motor. A glossy “CE certificate” for a 48 V motor citing the LVD describes an obligation that does not apply and will not support your technical file. What does support it: a RoHS DoC, a REACH SVHC statement, an IEC 60034-1 type test report, and for a drive assembly an EU declaration of incorporation.
Are electric motors excluded from the EU Machinery Regulation 2023/1230?
Only conditionally. Article 2(2)(p) excludes a list including electric motors, but only insofar as they fall within the scope of Directive 2014/35/EU (LVD) or 2014/53/EU (RED). A 230 V AC motor is inside LVD and is excluded. A 48 V DC motor is below the 75 V DC floor, so the exclusion has nothing to attach to. The counterintuitive result: a low-voltage DC motor has more machinery-law exposure than a mains-voltage one, not less.
Do I need a Declaration of Incorporation from my motor supplier?
Only if what you buy is partly completed machinery. Article 3(10) defines that as an assembly that cannot in itself perform a specific application and is only intended to be incorporated into machinery. A bare motor is usually a component and falls short. A drive wheel module with gearbox, wheel, brake and mounting interface is much closer, and we issue a DoI for those. Where one is issued it must follow Annex V Part B, rest on the Annex IV Part B file, ship with Annex XI assembly instructions, and be translated into the language of the Member State of placing on the market.
Is a BLDC motor covered by Ecodesign 2019/1781, and can it be IE4?
No to both. Article 2(1)(a) limits scope to induction motors without brushes, commutators or slip rings, rated for 50/60 Hz sinusoidal operation, 2–8 poles, above 50 V up to 1,000 V, 0.12–1,000 kW, continuous duty and direct-on-line. A BLDC is a permanent magnet machine that is electronically commutated and cannot run direct-on-line, so it fails the first condition. There is no legal IE obligation and no Ecodesign declaration to issue. Asking for “IE4 certified” on a BLDC requests a label that does not exist — ask for measured efficiency at your duty point instead.
What changes on 20 January 2027, and must I re-certify machines already sold?
Regulation 2023/1230 applies from 20 January 2027 (Art. 54) and Directive 2006/42/EC is repealed with effect from the same date (Art. 51(2)), with no dual-running period for new products. Your installed base is protected: Art. 52(1) prevents Member States impeding products placed on the market in conformity with the old Directive before that date, so no re-certification. Watch one trap: the original OJ L 165 text says 14 January; a Corrigendum of 4 July 2023 moved that and related dates to the 20th. Rebuild any calendar derived from the original PDF.
Request a Quote With the Document Pack Included
Tell us the drive specification and your target market and we will quote with the compliance documents listed line by line — RoHS DoC, REACH SVHC, IEC 60034-1 type test report, and an EU declaration of incorporation where the assembly warrants one. MOQ 50 pcs, samples in 7–10 days.