To guarantee machinery safety it is first of all necessary to assess whether the retrofit represents a significant change to machinery. Normally the machine is optimised and modernised in terms of its productivity, availability and safety. In this case we cannot speak of a significant change to machinery. So CE marking for the machine is not mandatory.
Is machinery safety guaranteed when performance is increased?
However, the statement that a retrofit does not represent a significant change to machinery cannot be generalised. If productivity is increased, then this almost always involves a (considerable) increase in the machine's performance, for example. In this case, when performance is increased it is necessary to assess whether machinery safety is guaranteed by existing protective measures. If this is not the case then it may represent a significant change to machinery.
Minimum machinery safety requirements
Even if the retrofit does not represent a significant change to an old machine, it is still necessary to comply with minimum, state-of-the-art machinery safety requirements. This circumstance arises from the requirements of Annex 1 of the German industrial safety regulations (BetrSichV), which are binding for each machine operator. Bear this in mind when carrying out a retrofit.