Equipment (especially an Assembly Unit) be sent to Germany without CE certification?

 

Equipment (especially an Assembly Unit) be sent to Germany without CE certification?

This depends on the status and purpose of the equipment.
The key factor is whether the equipment is considered “placed on the market” under EU law.
Based on that, the cases are as follows:

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✅ When CE certification is not required

If any of the following conditions apply, the equipment can be classified as non-CE prototype and temporarily imported.

1. Equipment for development or feasibility testing

If the equipment is intended purely for feasibility or verification purposes and not yet commercially sold, it is regarded as “not yet placed on the market” under the Machinery Regulation (EU) 2023/1230.

• The equipment should have an external label such as:
  “Not for commercial use – For testing only.”

• Internally, a Risk Assessment and Declaration for R&D use should be kept on file.

• Customs authorities can accept the equipment under temporary import if such documentation is provided.

2. Equipment for setup or testing at a partner site

If the equipment is sent for technical cooperation, setup, or local feasibility testing, and not for sale or transfer, CE certification is not required.

• Provide internal documentation (e.g., a cover letter stating “for assembly feasibility study only”).

• Obtain a Statement of Non-commercial Use from the receiving partner in Germany to support customs clearance.

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⚠️ When CE certification is required

CE certification becomes necessary if:

• The equipment will be integrated into a production line and used for regular operation in Germany.

• The equipment is being sold or transferred to another entity.

• The equipment, even as a partly completed machinery, is being supplied for commercial purposes.

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✍️ Practical documentation examples

Cover letter:

“This assembly unit is provided for feasibility study purposes only and is not intended for commercial operation in the EU market.”

Technical note:

“The equipment is a non-CE prototype supplied for internal evaluation only.”

Import declaration (German side):

“Temporary import for R&D – will be re-exported or scrapped after testing.”

Label to be attached on the equipment:

⚠ Prototype Equipment – Not for commercial use / Non-CE – For feasibility test only