Partly Completed Machinery (PCM)

Partly Completed Machinery (PCM) refers to an assembly that is "almost" a machine but cannot function independently without being integrated into a larger system. For North American manufacturers, this classification is critical when shipping "skids" or modules—such as a pump system without its final wiring or a robotic arm without its safety cell—to an integrator in the EU.

Unlike finished equipment, PCM must not bear the CE Mark under the Machinery Directive. Instead of a Declaration of Conformity (DoC), it requires a "Declaration of Incorporation" (DoI) and specific assembly instructions. These documents explicitly state that the unit must not be put into service until the final machinery into which it is incorporated has been declared compliant.

Misclassifying PCM is a frequent error. If you sign a full DoC for a machine that relies on the customer’s guarding to be safe, you are making a false legal claim. You must identify which Essential Health & Safety Requirements (EHSRs) you have met and pass the remaining responsibility to the final integrator.