Products for military and national security applications are generally excluded from the CE marking directives but product safety still has a role to play in many defence applications. In fact, the exclusions for military applications are not as widely drawn as many people think, and 'dual use' equipment (i.e. products which have both military and civilian applications) must be CE marked even when supplied into the defence sector. Many countries demand that the same risk assessment process and standards are applied to military equipment even if the CE mark itself is not used.
The defence industry demands the highest levels of performance and reliability, and the scrutiny applied to its suppliers calls for impeccable manufacturing standards and procedural traceability.
Conformance can help ensure your products and systems meet all the robust requirements and obligations of defence procurement. We can offer security cleared staff if required.
- Initial consultation to assess your requirements and decide how we can help.
- Identify the directives and standards which apply to your product.
- Clarify additional requirements specific to military applications
- Conduct a design review to verify compliance with the applicable requirements.
- Provide you with a report outlining areas of non-compliance and advice to help you rectify them.
- Help to compile a technical file which contains the information required by the directives.
- Provide a draft Declaration of Conformity and help you complete it.
- Offer follow up advice when you need it.
Our recent industry experience includes:
- Parachute training equipment
- Machinery for ejector seat maintenance
- Dummy airframe rigs for training technicians
- Flight training simulators
Frequently Asked Questions
What are the CE marking requirements for items intended for military use or items that will be used by military organisations?
The situation for 'military equipment' is complex and varies from one EU country to the next. Certain directives have specific exclusions for military equipment, although not every member state has actually included such provisions in their national legislation. There is also a blanket exclusion under the Treaty of Rome which Member States may claim where they believe their national security interests are at risk but this is something the Member State government would have to apply and cannot simply be claimed by a manufacturer of 'military equipment'.
It's important to understand that the equipment actually has to be specifically military in nature to be eligible for exclusion where such an exclusion is given in the directives. Accordingly it must have only a military (or police) application (e.g. it must be an offensive weapon of some description). Just because it is being sold to the armed forces does not make it automatically exempt from the CE mark requirements and in most cases the regulations implementing the CE directives specifically say that dual use equipment (i.e. equipment which is sold for both military and civilian purposes) must be CE marked.
What exclusions are there for military equipment in the various directives?
LVD
- No exemptions in the Directive
EMC
- No exemption in the Directive
Machinery
- Weapons and firearms are excluded, as are "machinery specially designed and constructed for military or police purposes"
Pressure Equipment
- General exclusion for military equipment drawn from article 346 of the TFEU.
ATEX
- General exclusion for military equipment drawn from article 346 of the TFEU.
You can find the answers to many more CE marking questions in our knowledgebase.
Other relevant products and services we offer
Online shop
Our shop allows you to purchase a range of useful resources such as self-certification packs, checklists and declaration formats.
Prepaid Consultancy Time
You can purchase consultancy from our online shop in blocks of 30 or 60 minutes to provide quick help when you need it.
Training
Our machinery training covers the requirements of the Machinery Directive and how to ensure your machinery complies. We also do more basic 'introduction to CE marking' courses.
Design assistance
We can assist with interpreting the requirements of the directives and standards and applying them to your products. We can also draft instruction manuals, check the content of product labels, data plates, and packaging.
Technical files
If you are unsure what technical documentation you need to show compliance with the Directives we can provide contents lists and formats for compiling and storing the information.
Self-assessment materials
You will find checklists and formats for risk assessment in our online shop. We have many other checklists and report formats which are not in the shop - please contact us if you are looking for something specific and can't find it.
On-site inspection/assessment
We will visit your works to inspect and assess your machinery and identify any areas which do not comply with the applicable directives and standards.
Self certification guides
We provide guides which identify the applicable directives and standards for your product and all the other information you will need to do your own assessments. Every guide is tailored to your specific requirements and includes detailed information on how to do the assessment, checklists and formats for recording the results and a draft of the Declaration of Conformity you will need to sign when the process is complete.
Control system analysis
Analysis of the reliability of controls (e.g. emergency stops and guard interlocks) can be complex and difficult, particularly where there are significant numbers of safety-related control functions. Our machinery experts are experienced in conducting functional analysis of machines and systems and can help you navigate complex standards such as EN ISO 13849 and EN 62061 which apply to machinery.