CE Marking and Safety When Buying a Used Die Casting Machine

Three Typical Situations

Already on the EU Market: Operator Obligations Apply

EU harmonisation legislation such as the Machinery Directive applies when a product is placed on the Union market for the first time. A die casting machine that was placed on the market as a new machine in the EU does not have to undergo a new conformity assessment just because it changes owners.

However, the operator must ensure that the machine can be used safely at its workplace. The basis is Directive 2009/104/EC on the use of work equipment, implemented in national law – in Germany, for example, by the Ordinance on Industrial Safety and Health (BetrSichV). In practice, this means a risk assessment for the specific workplace, functioning safety devices and trained personnel.

Buyers should ask the seller for the original declaration of conformity, the operating manual and the circuit diagrams. If they are missing, it becomes much more difficult to assess the original safety concept.

Imported from Outside the EU: Treated Like a New Machine

The European Commission’s Blue Guide on the implementation of EU product rules (2022) states that Union harmonisation legislation also applies to used and second-hand products imported from a third country when they enter the Union market for the first time – even if they were manufactured before the legislation became applicable.

For a die casting machine from Asia or America, for example, this means: before it is placed on the market in the EU, it must meet the essential health and safety requirements of the applicable machinery legislation. This requires a risk assessment, technical documentation, an EU declaration of conformity, CE marking and instructions in the language of the country of use.

From 20 January 2027: Regulation (EU) 2023/1230

The Machinery Directive 2006/42/EC will be replaced by the Machinery Regulation (EU) 2023/1230, which applies from 20 January 2027. As a regulation, it applies directly in all member states. Machines placed on the market or put into service from that date must meet its requirements; machines lawfully placed on the market before that date do not have to be recertified.

For buyers of used machines, the explicit rule on substantial modifications is particularly relevant: a physical or digital modification that was not foreseen by the manufacturer and that creates a new hazard or increases an existing risk in such a way that new protective measures are required. Under Article 18, whoever carries out such a modification is considered a manufacturer with the corresponding obligations. Changes to control software can also be a substantial modification.

This matters for retrofits of controls and safety functions. How overhaul and retrofit differ technically is described in Overhaul or Retrofit?

EN 869 Has Been Replaced by EN ISO 23063

For decades, EN 869 was the European safety standard for pressure metal die casting units. The version EN 869:2006+A1:2009 was withdrawn in 2025 and replaced by EN ISO 23063:2025 “Foundry machinery – Safety requirements for high pressure die casting machines” (ISO 23063:2024).

EN 869 covered the die casting machine and its interfaces with die, furnaces, metal feeding, part removal, spraying equipment and die temperature control units – but not the ancillary equipment itself – and excluded low-pressure and gravity die casting machines. Its hazard areas give buyers a good orientation:

• Die area: guards, interlocks and protection against closing movements
• Molten metal: protection against metal splashes and metal escaping at the parting line
• Hydraulics: accumulators, hoses, pressure relief and fire-resistant fluids
• Interfaces: safeguarding of robots, spraying units, extraction and furnaces in the cell
• Control: safety functions, emergency stop and operating modes for setting up and maintenance

Whether and from when a standard gives a presumption of conformity depends on its citation in the Official Journal of the EU. This status should be checked for the specific project.

What Buyers Should Clarify Before Signing

• Origin of the machine: placed on the market in the EU, or import from a third country?
• Declaration of conformity, type plate with CE marking, operating manual in a suitable language
• Hydraulic and electrical diagrams, risk assessment of the manufacturer if available
• History of modifications, retrofits and control changes
• Condition of guards, interlocks, light curtains and emergency stop circuits
• Planned changes at the new site and whether they could be substantial
• Responsibilities between seller, buyer, integrator and operator – in writing

General technical points for the inspection are covered in Buying a Used Die Casting Machine: The Technical Checklist. FISS also supports buyers with consulting and safe commissioning.

Clarify Origin and Changes Early

With used die casting machines, the question of CE marking is decided less by age than by origin and changes. Machines from the EU market mainly require a safety review by the operator. Imports from third countries and substantial modifications can trigger a full conformity procedure – with the Machinery Regulation from 20 January 2027 as the new legal basis. Clarifying these questions before purchase avoids surprises in cost and schedule.

Questions About CE Marking and Used Die Casting Machines