CE Certification for Amusement Machines: What to Ask For

CE Certification for Amusement Machines: What to Ask For

Buying amusement equipment for the European market means dealing with CE marking, and most buyers get it wrong in one of two directions. Some treat CE as a quality certificate that a laboratory issues and expires, which is not what it is. Others hear "CE certified" and assume it covers the category they are importing.

Neither reading survives contact with the facts. CE marking is a legal declaration made by the manufacturer, supported by a technical file they must produce on demand. Understanding what sits behind it separates a smooth customs clearance from a container held at the border.

What CE marking actually is

CE marking is not a certificate. No body in Brussels issues a "CE certificate" for amusement machines, and there is no register of certified machines you can look up.

What exists is a three-part legal structure:

1. The CE mark itself - a conformity mark the manufacturer affixes to the product, indicating that the manufacturer has determined the product complies with the applicable EU legislation.
2. The EU Declaration of Conformity (DoC) - a signed document stating which directives apply and referencing the standards used to demonstrate conformity. It must accompany the product and be reproducible for every model in the shipment.
3. The technical file - the underlying evidence: risk assessments, test reports, design drawings, component specifications, the manual, and production-control records. The manufacturer must produce it to a market surveillance authority on request, for ten years after the last product is placed on the market.

The practical consequence: you are buying a manufacturer's compliance process, not a piece of paper. A supplier who can explain what is in the technical file for a specific model, and who keeps it current, is worth more than one who sends a generic "CE certificate" with a logo on it.

Which regulations apply to which machines

The applicable set depends on the machine's function, not its price or catalogue category.

Regulation	Reference	When it applies
Low Voltage Directive (LVD)	2014/35/EU	Any machine with electrical equipment rated 50-1000 V AC or 75-1500 V DC. In practice, every powered machine
Electromagnetic Compatibility (EMC)	2014/30/EU	Every machine with electronics: emissions and immunity. Non-negotiable for screens, amplifiers, motor drives, LED systems
Machinery Directive	2006/42/EC	Machines with moving parts, guarding and mechanical hazard exposure. Replaced by Machinery Regulation (EU) 2023/1230 from 20 January 2027
Radio Equipment Directive (RED)	2014/53/EU	Any machine with wireless control or radio communication, such as remote-controlled kiddie rides
RoHS	2011/65/EU	Restriction of hazardous substances, applicable to essentially all electrical machines
Toy Safety Directive	2009/48/EC	Only if the product is a toy. Coin-operated amusement machines for use in public places are excluded
General Product Safety	2005/103/EC	Consumer products where no sector legislation applies, including traceability obligations

The toy directive question

The one point that catches most people is the toy directive. A machine at child height in a family entertainment centre will attract scrutiny, but if it is sold as coin-operated amusement equipment rather than as a toy, the Toy Safety Directive and EN 71 do not automatically apply. The manufacturer determines this classification, and it must be documented in the technical file. If a supplier claims EN 71 certification for an amusement machine, ask why the product was treated as a toy, because it changes the conformity route.

Note also that standards such as the EN 60 series for amusement machinery are used to demonstrate conformity, but the legal obligation comes from the directive or regulation, not the standard. Harmonised standards referenced in the Official Journal give presumption of conformity, not law.

When a notified body is involved, and when it is not

This is the single most expensive misunderstanding in the industry, because buyers routinely pay for notified body involvement they do not need.

A notified body (NB) is a third-party organisation designated by an EU member state to assess conformity in specific cases. Its involvement is required only where the legislation explicitly says so, not as a general requirement for CE marking.

Situation	Notified body required?	Why
Most amusement machines: LVD, EMC, RoHS, self-declared	No	The manufacturer performs internal production control (Module A), tests to harmonised standards, issues the DoC and affixes the CE mark
Machinery where the risk assessment shows the safety objectives are fully met by harmonised standards	No	Assessment is internal unless the product falls into an Annex IV category, or safety is only partially achieved through standards
Machinery where safety is only partially achieved by harmonised standards, or a safety component is involved	Yes	EU-type examination (Module B) plus internal production control (Module C)
Radio equipment under RED without applicable harmonised standards	Yes	The NB issues an EU-type examination certificate
LVD where harmonised standards were not applied or not fully met	Yes	EC-type examination under Module B + Module C
Toys under the Toy Safety Directive	Yes	EU-type examination is mandatory for toys - the exception, not the rule

For a standard catalogue of arcade, redemption, claw and kiddie ride machines, the normal route is self-declaration. The manufacturer tests the product, keeps the technical file, signs the DoC and applies the mark. It does not mean the testing was skipped - it means the tests were done and documented by the manufacturer or by a laboratory acting on its instructions, with legal responsibility sitting with the manufacturer.

So if a supplier quotes you for an "NB CE certificate", there are only two explanations. Either the product genuinely falls into a category requiring notified body involvement, or you are being sold a service you do not need. Ask which it is, and ask for the certificate number if it is the first case. There is no generic "CE certificate" covering a catalogue - conformity is assessed per model, per configuration.

The CE process, step by step

Step	What happens	Output
1. Determine applicable legislation	Classify the machine by function, voltage, motion, radio capability and intended use	Scope statement listing every applicable directive
2. Risk assessment	Identify hazards, estimate risk, decide which are eliminated by design and which need guarding	Risk assessment report, referencing EN ISO 12100 principles
3. Technical documentation	Design drawings, wiring diagrams, component list, bill of materials, flammability data, test reports, manual	Assembled technical file
4. Testing	Sample units tested to the harmonised standards referenced in step 1	Lab test reports from an accredited laboratory
5. Production control	Documented incoming inspection, in-process checks, final test and calibration records	Quality plan and records
6. EU Declaration of Conformity	Signed statement listing every directive, the standards used, and the model identification	DoC, one per model or model family
7. Marking and labelling	CE mark affixed, rating plate with model, voltage, power, warnings, instructions in the destination market language	Marked product and manual
8. Market placement	DoC issued with the consignment, file retained for ten years	Traceable file

Steps 1 to 7 are the manufacturer's work; step 8 is the importer's obligation as well. When the container clears customs, the party placing the goods on the EU market - usually you as the importer - must be able to produce the DoC and the technical file.

What to request from your supplier

Send this list to a prospective supplier and compare the answers. A serious manufacturer responds with documents for the specific models.

1. EU Declaration of Conformity for the exact model, listing the directives and standards used, dated and signed.
2. Risk assessment report covering electrical, mechanical, thermal, noise and ergonomic hazards, with residual risks stated.
3. Test reports for safety, EMC and any other applicable assessment, from an ISO/IEC 17025 accredited laboratory, with the model number matching your machine.
4. Electrical schematics and wiring diagrams, plus the component list with rated voltages and safety-critical parts identified.
5. Materials and flammability data for cabinet, panel and decorative materials.
6. Instructions for use in the destination market language, with power rating, fuse ratings, and warnings for each hazard.
7. Label and rating plate artwork, showing model, batch reference, supply voltage, frequency, and manufacturer or importer identification.
8. Quality control records and the production control plan, including final test procedure.
9. Any notified body EU-type examination certificate, with the NB number, if one exists.
10. A statement of which standards were applied, so you can check the current harmonised list yourself.

Two details deserve attention. First, the model number on the test reports must match the machine you are buying - a file for a 22-inch cabinet does not cover a 32-inch cabinet, and a file for a 350 W variant does not cover a 1000 W motion simulator. Second, a DoC without a regional configuration will not cover a different plug, transformer or coin acceptor setup. Also ask for market-specific variants already produced for the EU, Gulf or North America.

Common misconceptions

Misconception	What is actually true
"We need a CE certificate from the supplier"	CE marking is a manufacturer's self-declaration. The legal document is the EU Declaration of Conformity; there is no certificate to buy for a standard machine
"A notified body certificate is required for all amusement machines"	NB involvement is required only where legislation mandates it. Most arcade, redemption, claw and kiddie machines are self-declared
"CE means the machine is certified to a European quality standard"	CE is not a quality mark. It says nothing about build quality, durability or machine life
"The CE certificate expires and needs renewing"	There is no expiry. The DoC and technical file apply to the model as placed on the market and must be kept for ten years after the last placement
"CE is the same everywhere"	CE covers the EU and EEA. The UK, North America, Gulf, Australia and the Eurasian Economic Union have their own regimes
"A single CE certificate covers the whole catalogue"	Conformity is assessed per model and per configuration. A catalogue-wide certificate is not a real document

Compliance for other target markets

Market	Mark or scheme	What is generally required
European Union / EEA	CE	Manufacturer self-declaration against applicable directives, supported by a technical file and DoC
United Kingdom (Great Britain)	UKCA, with CE accepted	CE marking is recognised indefinitely in GB for 21 product regulations including machinery, LVD, EMC, RED, toys and RoHS. UKCA remains an alternative. Northern Ireland follows EU rules
United States / Canada	UL, ETL or another NRTL listing	NRTL safety listing, FCC Part 15 for emissions, often ASTM F24 for amusement devices. Venue insurers frequently require a listing
Gulf Cooperation Council	G-Mark	Mandatory for low-voltage electrical equipment and children's toys in the GCC. Saudi SABER, UAE ECAS and Kuwait KUCAS are national layers on top
Eurasian Economic Union	EAC	Certification or declaration depending on the applicable EAEU technical regulation, with an EAEU applicant and Russian documentation
Australia / New Zealand	RCM	Supplier registration plus conformity evidence for applicable electrical and EMC regulations

If your shipment covers more than one market, treat it as separate compliance work per destination. A machine built for the EU with an EU plug and a European-language manual does not satisfy Gulf or Australian requirements, and the label and manual work is real, not a sticker.

Getting a real quotation

Tell us the destination market, the models you are considering, your quantity and whether you need market-specific configuration, and we will confirm what compliance documentation is available so you can build your import file before the goods ship. Our machines are manufactured in our own factory to CE requirements for the European market, and we can provide the conformity documentation with the quotation so your broker can review it in advance. Standard production lead time is 5-25 days for all models.

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