Service Robot Manufacturer: Who Carries the Duty?

A hotel buying from outside the EU should identify the service robot manufacturer before paying a deposit. It must also decide whether the item is complete machinery or partly completed machinery. The answers determine who must design for safety, which technical file applies, whether a CE mark and EU declaration of conformity belong on the delivered product, and who must finish the assessment before the robot enters hotel service.

This is a classification exercise, not a branding exercise. A Chinese factory can remain the manufacturer while a Greek company is the importer. For an integrator, Article 3 identifies the own-name and own-use routes: it has the product made and markets it under its own name, or it manufactures machinery for its own use. Creating or taking responsibility for a finished assembly is a separate final-machinery duty. A substantial modification is governed separately by Article 18. The contract label alone does not settle the legal role.

Make the classification before accepting the quote

The European Commission states that Regulation (EU) 2023/1230 applies on a mandatory basis from 20 January 2027. Machinery placed on the EU market before that date must comply with Directive 2006/42/EC. A manufacturer may also state in the EU declaration of conformity that the machinery conforms with Regulation (EU) 2023/1230 where applicable. The procurement team therefore needs the expected placing-on-the-market date, not only the hotel installation date. A delayed shipment can change the mandatory regime.

The first decision is whether the quoted object can perform the specific application for which it is sold. Under Article 3 of the current consolidated Machinery Regulation, machinery includes an assembly with moving linked parts joined for a specific application. It also includes an assembly missing only its on-site connections, its energy or motion connection, its installation on a building or transport structure, or the upload of software intended for the application foreseen by the manufacturer.

That last point matters for service robots. A vendor cannot turn an otherwise finished delivery robot into partly completed machinery merely because the hotel must connect Wi-Fi, map the floors, configure lift calls, load a site profile or upload the intended application software. Those facts may create integration work, but the statutory definition of machinery expressly covers several forms of final installation and software completion.

Partly completed machinery is narrower. Article 3 says it cannot in itself perform a specific application. It must also be intended only for incorporation into or assembly with machinery, other partly completed machinery or equipment so that machinery is formed. The words “cannot in itself” and “only intended” deserve evidence. They should not be inferred from a sales description such as “robot base”, “platform” or “integration kit”.

Use a functional test, not the vendor’s label

Ask the supplier to state the intended application in one sentence. Then compare that statement with the delivered configuration. A mobile chassis with drives, batteries and controllers may be partly completed if it lacks the systems needed to perform any defined service task and is sold only for incorporation. A room-service robot sold to carry trays between reception and guest floors may already be machinery even though a local technician must map routes, connect doors or lifts, and configure charging.

The classification should be tied to a bill of materials, software list, interface specification and acceptance test. Record what the product can do at delivery, what the hotel or integrator must add, who designed each safety function, and who defines the final intended use. The relevant question is not whether work remains. Most machinery requires installation. The question is whether the supplied assembly can perform its specific application, subject to the forms of connection, mounting and software completion that Article 3 already treats as machinery.

A useful procurement memo should answer five points:

• What exact operation is the supplied assembly designed to perform?
• Can it perform that operation after ordinary connection, mounting, mapping or intended software upload?
• Is it sold only for incorporation into a larger machine whose final safety functions are designed elsewhere?
• Who controls the final design, risk assessment, software version and release decision?
• Which entity’s name and address will appear as manufacturer on the product and declaration?

If the answers conflict with the declaration supplied by the vendor, hold acceptance. A CE logo, invoice description or voluntary certificate does not resolve a classification conflict. Your Europe warns that there is no central EU body issuing permission or a general CE certificate; the responsible manufacturer must follow the conformity route required by the applicable legislation.

Identify the service robot manufacturer and the other roles

The Machinery Regulation’s Article 3 definition covers a person that manufactures a product or has it designed or manufactured and markets it under its name or trademark. It also covers a person that manufactures the product and puts it into service for its own use. The service robot manufacturer can therefore be an EU private-label buyer or integrator, even when another factory performs the physical production.

An importer is the EU-established person that places a product from a third country on the Union market. Import status carries its own duties. Under Articles 13 and 14, the importer must place only compliant products on the market, verify the required manufacturer documentation and accompanying documents, add importer identification, preserve specified records, and cooperate with authorities. For partly completed machinery, that includes checking the Annex IV Part B documentation, declaration of incorporation and assembly instructions.

Importing does not automatically transfer the original manufacturer’s design duty to the importer. It does, however, create a gatekeeping duty. The importer cannot treat missing documentation as a task to be postponed until after the robot reaches the hotel floor. Regulation (EU) 2019/1020 supplies the wider market-surveillance framework, including authority powers and procedural rights. A commercial promise to obtain documents later does not remove the product-law exposure.

An authorised representative is different again. The manufacturer appoints it through a written mandate for specified tasks. Article 12 is explicit that the duty to design and construct in accordance with the relevant safety requirements and the duty to draw up the Annex IV technical documentation cannot form part of that mandate. The representative may keep the file, answer reasoned authority requests and cooperate on corrective action. It does not become the author of a file that the manufacturer never created.

The Commission’s CE guidance for manufacturers assigns conformity assessment, technical documentation, the EU declaration of conformity and CE marking to the manufacturer. The 2022 Blue Guide is useful for the horizontal distinction between manufacturer, authorised representative, importer and distributor, but it also says that only the applicable Union act has legal force. For a 2027 service robot, the machinery-specific text controls where it differs.

Complete and partly completed products require different evidence

Question	Machinery or related product	Partly completed machinery
Core technical file	Annex IV Part A	Annex IV Part B
Manufacturer statement	EU declaration of conformity under Article 21 and Annex V Part A	EU declaration of incorporation under Article 22 and Annex V Part B
CE marking under the Machinery Regulation	Affixed after the applicable conformity assessment	Not treated as the final machinery’s CE-marked declaration package
User information	Instructions for use and required safety information	Assembly instructions under Annex XI
Who completes the final machine assessment?	The manufacturer named for the machinery	The manufacturer of the final machinery that incorporates the partly completed unit

For complete machinery, Article 10 requires the manufacturer to design and construct against Annex III, draw up Annex IV Part A technical documentation, perform the applicable conformity assessment, issue the EU declaration of conformity and affix CE marking. The documentation and declaration must remain available for at least ten years. The exact file contents are covered in Ergasa’s Annex IV technical-file review.

For partly completed machinery, Article 11 requires compliance with the relevant Annex III requirements, Annex IV Part B technical documentation, an EU declaration of incorporation and Annex XI assembly instructions. The consolidated Machinery Regulation confirms this different document route. The declaration of incorporation is not a declaration that the hotel may use the assembly as finished machinery. It is an input into the final machinery manufacturer’s work.

Annex XI requires the assembly instructions to describe the conditions for correct incorporation and to supply information needed for the final machinery’s instructions. That includes relevant drawings, installation and connection information, warnings, applicable safety requirements, maintenance information and the version of the instructions. If an OEM claims partly completed status but supplies only a generic user manual and a CE certificate, the evidence package does not match the claimed route.

Run a hotel procurement decision checklist

1. Freeze identity. Record model, serial-number scheme, hardware revision, software version, battery and charger, sensors, accessories and the exact quoted configuration.
2. Define the application. State whether the robot transports items, cleans, guides guests, patrols or performs another operation. Include operating areas, payload, speed, lift and door interfaces, charging and recovery.
3. Map economic operators. Obtain the legal name and contact details of the manufacturer, authorised representative if any, importer and distributor. Do not merge them into a single “supplier” field.
4. Challenge the classification. Ask why the product is machinery or partly completed machinery. Require the supplier to map the answer to Article 3 and the delivered configuration.
5. Match the documents. For machinery, request the EU declaration of conformity, instructions and access to the relevant conformity evidence. For partly completed machinery, request the declaration of incorporation, assembly instructions and the Part B evidence needed by the final machinery manufacturer.
6. Name the final manufacturer. If a local integrator will create the finished assembly, the contract must say who performs the final risk assessment, controls changes, creates the Part A file, signs the declaration and affixes the CE mark.
7. Control release. Make document acceptance and functional safety acceptance conditions for final payment and commissioning. Do not release the robot into guest or staff areas while the classification or responsible manufacturer remains unresolved.

The broader New Legislative Framework in Decision No 768/2008/EC explains the common structure behind economic-operator duties. Import teams can also use the Commission’s Access2Markets machinery page to identify product requirements alongside customs work. Neither source replaces the product-specific review.

Price the integration duty instead of hiding it

The classification changes cost. A quote for complete machinery should include the manufacturer’s conformity work in the product price, even if the buyer still pays for site installation. A quote for partly completed machinery transfers a defined incorporation job to the final machinery project. That job can require engineering drawings, interface validation, a final risk assessment, software and safety-control verification, instructions, technical documentation and a signed declaration.

Use a simple cost schedule rather than an invented ROI claim:

Cost line	Supplier quote	Local integrator	Hotel	Evidence required
Product design and risk reduction	Assign	Assign	Normally review only	Risk assessment and design records
Lift, door and charging integration	Assign	Assign	Provide site constraints	Interface drawings and tests
Final conformity assessment	Assign	Assign	Do not leave blank	Named responsible entity and procedure
Greek instructions and staff controls	Assign	Assign	Operational implementation	Accepted documents and training record
Change control after commissioning	Support terms	Integration terms	Approval and records	Version and modification log

Do not populate the schedule with guessed savings, legal fees or testing prices. Obtain written quotes against the identified scope. The lowest equipment price can be the most expensive offer if it omits the entity and work needed to turn partly completed machinery into lawful finished machinery.

Record uncertainty and stop at the right boundary

This analysis is not legal advice and does not classify a specific robot. Classification depends on the delivered configuration, intended application, contracts, markings, software state and integration work. A competent machinery-safety professional and, where needed, legal counsel should review disputed or high-consequence cases.

Several facts should trigger a hold. Stop if the declaration names a different model or the supplier refuses to identify the manufacturer. Stop if a claimed authorised representative is expected to create the technical file, partly completed machinery has no assembly instructions, or the local integrator will change safety functions without accepting final-manufacturer responsibility.

The practical outcome is simple. Do not ask only whether the robot has CE. Ask what the product is, who the manufacturer is, which Annex IV file applies, and who signs for the finished configuration that will operate in the hotel. Ergasa’s Machinery Regulation readiness guide for Greek hotels provides the wider procurement sequence. This classification memo should sit at the front of that file, before document review and before final payment.

Frequently asked questions

Does importing a Chinese service robot make the Greek importer the manufacturer?

Not automatically. The importer has separate verification, identification, recordkeeping and cooperation duties. It falls within the Article 3 manufacturer definition if it has the product made and markets it under its own name or trademark, or manufactures for its own use. Responsibility for a finished assembly arises from the separate final-machinery role, while substantial modification is addressed by Article 18. Review the facts and contract, not only the invoice label.

Is a robot partly completed because it still needs mapping and Wi-Fi setup?

Usually those facts alone are not enough. Article 3 includes machinery missing ordinary on-site connections and machinery missing only the upload of software intended for the manufacturer’s specific application. The full delivered function and remaining engineering work still need review.

Can an authorised representative draw up the technical file?

Article 12 says the obligation to draw up the Annex IV technical documentation cannot form part of the authorised representative’s mandate. The representative may keep the file and provide it to authorities under the written mandate.

Should partly completed machinery carry the final machinery CE package?

The Machinery Regulation gives it a different route: Annex IV Part B technical documentation, an EU declaration of incorporation and Annex XI assembly instructions. The manufacturer of the finished machinery completes the final assessment and declaration for that final assembly.

What should a hotel do when the supplier’s documents conflict?

Hold acceptance and payment tied to compliance evidence. Freeze the product identity, list the conflict, obtain a written classification mapped to Article 3, and require the responsible manufacturer or importer to correct the package before commissioning.