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Documentation Index

Fetch the complete documentation index at: https://docs.roboticks.io/llms.txt

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EU MR 2023/1230 Conformity Assessment

This is the meta-pattern that wraps every product-specific pattern when shipping into the EU. It covers the full conformity assessment workflow under the EU Machinery Regulation 2023/1230 (applies January 20, 2027), with emphasis on self-propelled machinery — AMRs, mobile manipulators, autonomous service robots — where the substantial-modification, AI-component, and cybersecurity provisions land hardest. Read alongside the product-specific pattern for your machinery class (industrial robot, cobot, AMR).
Roboticks is audit-readiness tooling, not a certified toolchain. We assemble the evidence your notified body, certification body, or QA process ingests. We do not replace tool qualification (DO-178C, ISO 26262-8 TCL) and we do not issue conformity assessments. Verify the regulatory interpretations on this page against the standard text and your accredited assessor.

Scenario

You ship machinery into the EU after January 20, 2027. You need to claim conformity under EU MR 2023/1230 and (for Annex I high-risk machinery) involve a notified body. The conformity assessment culminates in a Declaration of Conformity (DoC) that you issue and CE-marking you affix.

The conformity-assessment workflow

Prerequisites

ElementOwnerRoboticks role
Risk assessment per ISO 12100Safety engineerIngests hazard list as hazards.yaml; links requirements to hazards
Harmonised standards selectionCompliance lead + safety engineerPinned in Roboticks; tracked by the publication feed
Requirement derivationEngineering + complianceNative Roboticks function
VerificationEngineeringNative Roboticks function
Design drawings and engineering documentationMechanical / electrical engineeringAttach to pack as supplementary; not authored by Roboticks
Instructions for useTechnical writingOff-platform; reference from pack
Supplier certifications for safety componentsComponent suppliersReference in architecture.yaml
Quality management system documentationQuality function (ISO 9001)Off-platform
Notified body engagement (Annex I machinery)ComplianceThey ingest the evidence pack as part of the technical file
Declaration of ConformityCompliance / company officerOff-platform; pack provides verification evidence
CE markingComplianceOff-platform

The harmonised standards stack

The exact stack depends on machinery class. For most robotics applications:
StandardCoverage
ISO 12100Risk assessment methodology
EN ISO 13849-1PL determination, Categories
IEC 62061SIL CL determination (alternative to ISO 13849)
ISO 10218-1:2025Industrial robots (manufacturer side)
ISO 10218-2:2025Industrial robot systems (integrator side)
ISO/TS 15066Cobot PFL
ISO 3691-4Driverless industrial trucks / AMRs
IEC 61496Protective equipment (scanners, light curtains)
EN 60204-1Electrical equipment of machinery
EU AI Act (Reg 2024/1689)AI safety components (from 2 August 2027)
Conformance to harmonised standards confers a presumption of conformity to the corresponding EHSRs of EU MR 2023/1230. The presumption is rebuttable; the notified body assessment is the rebuttal opportunity.

Project setup

1

Pin EU MR 2023/1230 and the harmonised stack

rbtk standard template apply industrial-robot-eu  # or cobot-eu, amr-eu
rbtk standard pin eu-mr-2023-1230 --project acme/firmware
2

Ingest the risk assessment

Hazard list → roboticks/hazards.yaml. See ISO 12100.
3

Author requirements derived from EHSRs

For machinery-specific obligations not fully covered by the harmonised stack, derive requirements directly from EU MR 2023/1230 Annex III EHSRs. See EU MR 2023/1230.
4

Author cybersecurity and AI requirements

EU MR 2023/1230’s cybersecurity provisions (EHSR 1.1.9) and AI provisions (EHSR 1.1.6, 1.2.1) require explicit requirement-and-test coverage. The harmonised stack does not fully cover them; derive directly from the Regulation.

Technical file structure

Annex IV of EU MR 2023/1230 prescribes what the technical file must contain. The mapping to Roboticks:
Annex IV requirementRoboticks contribution
Risk assessmenthazards.yaml, rendered in the evidence pack PDF
List of EHSRs and harmonised standards appliedPinned-standards section of the pack
Design and manufacturing drawingsAttach as supplementary artefacts; not authored
Description of safety functionsarchitecture.yaml, rendered in the pack
Calculations and test resultsTest-results section, coverage section, MCAPs (referenced)
Software safety analysisCoverage, SARIF, requirement-test traceability
Quality management system documentationOff-platform; reference in DoC
Components used (with certifications)architecture.yaml; referenced supplier certs
Instructions for useOff-platform; reference in DoC
Cybersecurity analysis (new under 2023/1230)SBOM, SARIF, fuzz-test evidence
AI safety analysis (new under 2023/1230)AI-related requirements with their test evidence; MCAPs of AI behaviour
The evidence pack is the verification evidence portion of the technical file — typically the most voluminous portion, and the one notified bodies most scrutinise. The non-verification portions are off-platform; you assemble them around the pack.

Conformity-assessment routes

For Annex I high-risk machinery (the list includes safety components, machinery embodying machine-learning, etc.), the notified body involvement is mandatory. The routes:
  • Annex IX — EU-type examination + production-conformity surveillance — notified body examines the type, then audits production-monitoring evidence annually.
  • Annex X — Full quality assurance — notified body audits the quality management system and design dossier.
Roboticks evidence packs feed both routes. For Annex IX, the pack supports both the EU-type examination (the design dossier) and the surveillance audits (post-release production-conformity evidence). For Annex X, the pack supports the design-dossier examination. For machinery not in Annex I, self-assessment is the route. The pack is your internal evidence; you issue the DoC on your own determination.

Cutting the conformity release

When you are ready to declare conformity:
1

Cut the conformity release

rbtk release cut --tag conformity-2027-01-20 --commits …. Use a tagging convention that makes conformity releases identifiable.
2

Run full verification

Every required test, against the pinned commit set. Resolve every gap. Acknowledged gaps must have documented rationale.
3

Generate the evidence pack

All three formats; include screenshots if available.
4

Assemble the technical file around it

Off-platform. Drawings, instructions, supplier certs, risk-assessment narrative.
5

Engage the notified body (if Annex I)

Hand over the pack via the customer-handoff procedure.
6

On notified-body sign-off, issue the DoC and affix CE

Off-platform; the pack is the verification-evidence record.
7

Mark the release shipped

rbtk release ship conformity-2027-01-20. The 10-year retention clock starts.

Surveillance and re-conformity

Under Annex IX, annual production-conformity surveillance is the norm. Roboticks supports this by:
  • Producing evidence packs for every release shipped during the surveillance period.
  • Maintaining the hash chain so the assessor can verify the historical integrity in a single command.
  • Surfacing standard amendments that occurred during the surveillance period and the re-conformity actions taken.
When a pinned standard amends, follow Re-conformity on amendment.

Next steps

EU MR 2023/1230 standard

The Regulation reference.

Industrial robot pattern

Product-specific layer for industrial robots.

AMR pattern

Product-specific layer for AMRs.

Re-conformity workflow

Handling amendments after the conformity release.