Placing on the Market
"Placing on the Market" is the pivotal legal concept that determines exactly when your machinery must comply with EU regulations. It is defined as the first time an individual product is made available on the EU market for distribution or use. For North American manufacturers, this moment typically occurs when the machine clears customs or is handed over to an Importer or end-user.
Crucially, this concept applies to every individual unit, not just the product line. If the Machinery Directive changes tomorrow, a machine placed on the market today is judged by today’s rules, while the identical unit shipped next week must meet the new ones. This "snapshot" approach protects you from retroactive laws but demands strict vigilance.
Once a product is placed on the market, it must already bear the CE Mark and be accompanied by a valid Declaration of Conformity (DoC). You cannot import non-compliant machinery with the intention of fixing it later; it must be compliant the moment it arrives.
Frequently Asked Questions
When exactly does placing on the market occur for US exports?
Does this concept apply to the model type or individual units?
Is it legal to import non-compliant machinery and fix it later?
