CE marking of automatic doors — step by step
A power-operated door counts as a machine under the EU Machinery Directive, and whoever completes the door — often the installer — is responsible for its CE marking. Here is who carries the responsibility, the five steps to a correct CE marking, what applies when replacing the operator on an existing door, and what the new Machinery Regulation changes in 2027.
Is an automatic door a machine? Yes.
A power-operated pedestrian doorset is a machine within the meaning of the Machinery Directive (2006/42/EC) and must be CE marked before it is put into service. National authorities carry out market surveillance, and instructions and the declaration of conformity must be provided in the language of the country where the door is supplied.
The safety requirements are met in practice by following the harmonised standard EN 16005 — doing so gives presumption of conformity with the directive.
Who is responsible for the CE marking — the manufacturer or the installer?
Door operators are normally supplied as partly completed machinery with a declaration of incorporation — not as a finished, CE-marked machine. The machine only comes into existence when door leaf, operator and sensors are assembled into a working doorset on site.
Whoever does that — usually the installer — thereby becomes the manufacturer of the finished doorset in the directive's sense and takes over the manufacturer's obligations: risk assessment, technical file, declaration of conformity and the CE mark. If a complete factory-built doorset is supplied and installed strictly per the maker's instructions, that maker remains responsible instead. One legal entity must always stand behind the CE marking.
CE marking step by step
For an installed door operator, the route to the CE mark looks like this:
- 1. Carry out a documented risk assessment of the installation per EN 16005, based on the door's environment and users.
- 2. Meet the standard's protective requirements: safety distances, sensors, force limitation and the right performance level for the control system.
- 3. Compile the technical file: description, drawings, the risk assessment, standards applied, test results, and the operator's declaration of incorporation with its assembly instructions. The file must be available to authorities for at least ten years.
- 4. Draw up and sign the EC declaration of conformity — including the manufacturer's details, the door's identification, the reference to the directive and the standards applied — in the language of the country of supply.
- 5. Affix the CE mark to the door and hand over the user instructions, operation and maintenance instructions, and a started logbook to the owner.
No notified body is needed: automatic pedestrian doorsets are not listed in the directive's Annex IV, so the manufacturer self-certifies conformity through internal production control. Note that the door's protective sensors are themselves safety components with requirements of their own — but that responsibility sits with the sensor manufacturer, not with you as the installer.
Replacing the operator on an existing door — is a new CE marking required?
A pure like-for-like replacement — same safety, function and classification as before — is maintenance and requires no new CE marking.
If, however, the door's safety, function, classification or intended use changes, the door must be CE marked anew: for example when an existing door is moved, when automatic closing is added, when components are replaced in a way that affects the declared characteristics, or when the door is upgraded to serve an escape route. That requires a new risk assessment, technical file and a new declaration of conformity.
The new Machinery Regulation additionally introduces a clear definition of substantial modification: whoever makes such a change to a door in service is considered its manufacturer, with full CE obligations for what was changed.
The new Machinery Regulation 2027: documentation goes digital
On 20 January 2027 the Machinery Directive is replaced by the Machinery Regulation (EU) 2023/1230, with no transition period — machinery placed on the market from that date must comply with the regulation.
The biggest practical change for the door industry is that documentation may expressly be digital. Instructions may be supplied digitally in a printable format and must remain available online for the machine's expected lifetime, and at least ten years — paper only if the customer requests it at purchase. The declaration of conformity may be provided via an internet address or machine-readable code instead of a paper copy.
That is, in practice, the model Digilog is already built on: a QR label or CE sign on the door leading to current documentation, the declaration and the logbook — available to installer, building owner and authorities throughout the door's life.
Frequently asked questions about CE marking of doors
Do automatic doors need CE marking?
Yes. A power-operated pedestrian door is a machine under the Machinery Directive and must be CE marked before being put into service. The safety requirements are met in practice through the harmonised standard EN 16005.
Who is responsible for the CE marking — the manufacturer or the installer?
Both, but for different things. The CE mark often found on the door operator itself covers the operator as a component from its manufacturer — not the finished door. The machine in the directive's sense only comes into existence when door leaf, operator and sensors are assembled on site, and whoever does that — usually the installer — is responsible for the finished door's risk assessment, documentation, declaration of conformity and CE marking. A sticker on the drive unit therefore does not mean the installed door is CE marked.
Is a notified body required to CE mark an automatic door?
No. Automatic pedestrian doorsets are not listed in the Machinery Directive's Annex IV, so the manufacturer self-certifies conformity through internal production control — no third-party certification is required.
Is a new CE marking required when the operator on an existing door is replaced?
For a like-for-like replacement that preserves the door's declared characteristics: no. If safety, function, classification, location or intended use changes: yes — a new risk assessment, technical file and declaration of conformity are required from whoever makes the change.
What changes with the new Machinery Regulation in 2027?
Regulation (EU) 2023/1230 replaces the Machinery Directive on 20 January 2027 with no transition period. Documentation may be supplied digitally, substantial modification is defined — whoever substantially modifies a door becomes its manufacturer — and cybersecurity and software enter the risk assessment.