Anyone who uses an autonomous robot in their business is not just buying a device—they are also taking on responsibilities. Robot CE marking, machinery regulations, occupational safety, and the EU AI Act affect all commercial operators. This article provides an objective overview of what applies and what you should pay attention to when purchasing and operating such a robot. It does not replace legal advice.
What the CE marking means for robots
The CE marking is not a seal of approval, but a declaration of conformity. With it, the manufacturer declares that their product complies with the applicable EU directives and regulations. For autonomous robots, these are typically:
- Machinery Directive 2006/42/EC (or from 2027 onwards, the new Machinery Directive 2023/1230)
- Low Voltage Directive 2014/35/EU
- EMC Directive 2014/30/EU
- Radio Equipment Directive 2014/53/EU (for WiFi/BT-enabled devices)
The CE marking must be visibly affixed to the device. The marking must be accompanied by complete technical documentation, the manufacturer's declaration of conformity, and the corresponding operating manual in the language of the country of use.
As an operator, you may only put CE-marked devices into operation. Purchase through an integrator such as... SEBOTICSThe manufacturer's documentation is available — you can and should request it.
Machinery Directive and new Machinery Regulation
The Machinery Directive 2006/42/EC has been the framework for safety requirements for machinery in the EU for over 15 years. It is particularly relevant for autonomous robots because it defines fundamental safety and health requirements (HSH): from protective devices and emergency stops to operating instructions.
What's changing: The Machinery Regulation 2023/1230 (EU) replaces the previous directive. It will become legally binding on January 20, 2027. Compared to the old directive, it explicitly addresses collaborative robot systems, mobile machinery, and cybersecurity aspects. Manufacturers and integrators must prepare for this in good time.
For you as an operator, day-to-day operations will initially change little – the obligation to procure CE-compliant products remains. It is important to note that robots placed on the market after January 2027 must be certified according to the new regulation.
Risk assessment: mandatory before commissioning
The Machinery Directive stipulates that every machine must undergo a risk assessment before being placed on the market. This is primarily the manufacturer's responsibility. However, as the operator, you are not absolved of responsibility.
The Occupational Health and Safety Act (ArbSchG) and the Industrial Safety Ordinance (BetrSichV) require a separate Risk assessment For specific use in the workplace. The questions you need to answer are:
- Which people are moving within the robot's work area?
- How is the robot integrated into the workflow?
- What protective measures are required at the scene of the incident?
- Are employees adequately trained?
Autonomous service robots like the J40 cleaning robot or the Juno AX6113 transport robot are designed to operate safely in human-dominated environments—equipped with laser scanners, ultrasound, and camera recognition. Nevertheless, the device's technical safety features do not replace the company's risk assessment; they complement it.
For example: An office building is introducing an MT1 robot for cleaning the hallways. The risk assessment stipulates that the robot will only operate in publicly accessible areas outside of core working hours and specifies which employees are responsible for daily functional checks.
A reputable integrator will provide support during the rollout process, including documenting the use case. SEBOTICS is part of the Consultation and integration process.
Occupational safety during ongoing operations
In addition to the one-time risk assessment, the following ongoing requirements apply:
Duty to instruct: All employees who work with the robot or in its vicinity must have demonstrably received training. This training must be repeated regularly and documented.
Marking of the driving area: Depending on the location (warehouse, hospital, office), the robot's routes or activity areas must be marked — either physically or through clear operating instructions.
Maintenance and testing: The German Ordinance on Industrial Safety and Health (BetrSichV) requires that work equipment be kept in a safe condition. Regular maintenance intervals and inspection records are part of this. Service level agreements (SLAs) with defined maintenance cycles are practically directly applicable here.
Emergency stop and reaction time: Every robot must be able to be switched off immediately in an emergency. Check whether this is guaranteed at the deployment site.
For example: A logistics hall uses a Scrubber 75 for floor cleaning. The operating instructions specify the shifts in which the robot operates, how the operating area is marked with floor markings, and who should be contacted first in case of an unexpected stop.
Data protection: Cameras, sensors and personal identification
Modern autonomous robots navigate using LiDAR, ultrasound, and often camera systems. For data protection under the GDPR, the crucial question is: Are personal data processed in the process?
LiDAR data Point clouds used for obstacle detection are generally not considered personal data as long as no reverse identification is possible. Camera data that could capture faces or license plates, however, is classified as personal data.
Typical measures:
- Document camera use in the workplace and include it in the processing register.
- Inform employees and the works council (if one exists).
- Check if recordings are being saved and where.
- Consider conducting a Data Protection Impact Assessment (DPIA) if camera data is processed systematically.
Many cleaning robots from the SEBOTICS-Portfolio These cameras are primarily used for real-time obstacle detection without permanent storage. The exact configuration must be clarified with the manufacturer/integrator.
EU AI Act: What rules apply to robotics?
The EU AI Act (Regulation 2024/1689) has been in force since August 2024 and is being phased in. It classifies AI systems according to risk categories. For commercial robots, the following applies:
Not every robot is an “AI system” as defined by the AI Act. A robot that navigates based on simple sensor logic may not fall within the scope of application. The crucial factor is whether the system is based on machine learning or statistical models that make autonomous decisions.
Risk classes (simplified):
| Class | Example | obligations |
|---|---|---|
| Minimal risk | Simple, rule-based automation | No additional obligations |
| Limited risk | Chatbots, voice interaction | Transparency obligation towards users |
| high risk | Safety-critical infrastructure, medical diagnostics | Registration, conformity assessment, human supervision |
| Unacceptable risk | Social scoring, biometric real-time monitoring | Verboten |
Autonomous cleaning, goods transport, or hospitality robotics typically fall under this category. not into the high-risk category. Security robots with facial recognition, on the other hand, would need to be thoroughly examined.
The following applies to operators: When you deploy an AI system, you, as the deployer, have specific obligations—including monitoring, documentation, and, where applicable, reporting requirements. Most AI Act obligations will become fully applicable from August 2026.
Since this area is still under legal development: Have the classification of your specific solution reviewed by a legal advisor with EU AI Act expertise.
The role of the integrator in conformity
An integrator like SEBOTICS We do not assume manufacturer liability — CE conformity is the responsibility of the device manufacturer (Pudu, Gausium, AutoXing, Nexaro, etc.). However, what a good integrator does offer is:
- Caveat: Only CE-marked devices with complete technical documentation will be supplied.
- During the rollout: Inform operators about relevant operator obligations (risk assessment, instruction, maintenance intervals)
- Ongoing: Offer SLAs with defined maintenance and inspection cycles that support the requirements of the German Ordinance on Industrial Safety and Health (BetrSichV).
- Upon request: Support in documenting the deployment scenario for internal compliance purposes
What an integrator does not provide and is not permitted to provide: legal advice in the legal sense. For binding assessments of CE conformity, individual risk assessments, or AI Act classification, you need external experts (lawyer, certified occupational safety consultant, data protection officer).
FAQ
As the operator, am I required to perform CE testing myself?
No — CE marking is the manufacturer's responsibility. As the operator, you must ensure that the device is CE marked, that the declaration of conformity is available, and that the device is used as intended. Furthermore, you are responsible for conducting a workplace risk assessment.
What changes will the new Machinery Directive 2023/1230 bring?
The new regulation will replace the existing Machinery Directive from January 2027. It focuses more strongly on collaborative and mobile systems as well as cybersecurity. Devices placed on the market before this date will remain subject to the old legislation. Your integrator should inform you about the status of your devices.
Does the EU AI Act apply to my cleaning robot?
That depends on the specific technical implementation. Many autonomous cleaning robots use rule-based navigation and may not fall under the AI Act. Robots with learning systems or safety-critical AI decisions, however, could be affected. If in doubt, have this legally reviewed.
Do employees have to agree to the use of robots?
Employment law does not require individual consent. However, works councils have the right of co-determination under Section 87 of the Works Constitution Act (monitoring the behavior and performance of employees) if the robot collects relevant data. Inform the works council at an early stage.
What should be considered when using cameras in operation?
Camera data is considered personal data if individuals can be identified. Document its use in the processing register, inform employees, and check whether a data protection impact assessment is necessary. Many cleaning robots do not permanently store camera data—your integrator will clarify the exact configuration.
Next Step
If you are planning a specific robotics solution and would like to know which operator obligations are relevant in your deployment scenario: In Initial consultation with SEBOTICS Together we will clarify which documentation is part of the delivery and where you should involve external experts.
An overview of the available robot models can be found in the SEBOTICS Service robot overview.
This article provides general information and does not replace legal, data protection or occupational safety advice in individual cases.