Integrated machinery lines · Concept
When a packaging line becomes one machine
Six machines with six CE markings do not add up to a CE-marked line. This page explains when linked machines become an assembly of machinery, who takes on the role of manufacturer, and which documents the line needs in addition to the machine documentation.
Page context
- Line
- Reference line RL-1: end-of-line packaging (RL-1)
- Stations
- Infeed and accumulation conveyor → Filler and capper → Labeler → Inspection and reject → Case packer → Palletizer and stretch wrapper
- Lifecycle phase
- Planning and specification
- For
- System integrators, Safety engineers, Technical writers
- Page type
- Concept — Explains what something is and why it matters
Z1 · Filling
- Infeed and accumulation conveyorSystem integrator
- Filler and capperSupplier A
Z2 · Labeling and inspection
- LabelerSupplier B
- Inspection and rejectSupplier B
Z3 · Case packing
- Case packerSupplier C
Z4 · Palletizing
- Palletizer and stretch wrapperSupplier D
In short
- Linked machines form an assembly of machinery when they are arranged and controlled to work as an integral whole — shared control and shared safety functions are the typical signs.
- The assembly as a whole is treated as machinery. Whoever creates it — usually the system integrator — takes on the obligations of its manufacturer.
- The line needs its own risk assessment, technical file, declaration of conformity and instructions for use. The machine documents are input, not a substitute.
- The Machinery Directive 2006/42/EC applies until January 19, 2027; the Machinery Regulation (EU) 2023/1230 applies from January 20, 2027. Both know the concept.
What makes RL-1 an integral whole
Standing side by side is not enough. What turns the six machines of RL-1 into one assembly of machinery is how they are linked:
- Common control: the line controller starts, stops and paces all machines through their PackML state models.
- Shared safety functions: one emergency stop circuit covers the whole line, and the zone boundaries run across machine boundaries — the labeler and the inspection share zone Z2.
- Interacting hazards: a restart of the infeed can push bottles into the filler while someone is working there. Hazards like this don’t exist for either machine alone; they are interaction hazards of the line.
The coupling analysis documents these links. It is the evidence for the decision that RL-1 is one assembly — and the starting point of the line’s risk assessment.
Who is the manufacturer of the line
The party that creates the assembly takes on the obligations of its manufacturer. For RL-1 that is the system integrator, who designed the line control and the safety concept. If the operating company links the machines itself, it becomes the manufacturer.
The machine suppliers remain responsible for their machines. Their technical files, declarations and instructions stay valid for what they cover — but they don’t cover the line. A later change to the line, for example a faster palletizer, can be a substantial modification and must be assessed as such.
What this means for the documentation
The line gets a documentation layer of its own, which these pages model:
- a line-level risk assessment that covers the interaction hazards and the zone concept;
- a technical file for the assembly, referencing the machine files;
- one declaration of conformity for the line;
- line-level instructions for use: operating the line, stopping and restarting zones, clearing jams at interfaces, the interfaces and signals between the machines.
The machine manuals stay the source for everything inside a machine. Line pages link down to them instead of copying them.
| Question | Machines side by side | Assembly of machinery (RL-1) |
|---|---|---|
| Control | Each machine runs on its own | A line controller starts, stops and paces all machines |
| Safety functions | Each machine has its own | Emergency stop and zones span several machines |
| Risk assessment | Per machine | Per machine plus one for the line, including interaction hazards |
| Manufacturer | Each supplier for its machine | The integrator for the line; suppliers for their machines |
| Declaration of conformity | One per machine | One per machine plus one for the line |
| Instructions for use | Machine manuals | Machine manuals plus line-level instructions |