CE marking

CE marking – definition

CE marking is a conformity marking used for products placed on the European Economic Area (EEA) market when they fall within the scope of applicable EU harmonisation legislation. It indicates that the manufacturer declares that the product meets the relevant legal requirements for safety, health, electromagnetic compatibility, radio equipment, environmental protection, or other regulated characteristics.

For a mobile robot or unmanned ground vehicle (UGV), CE marking is not a performance rating and does not confirm autonomous-navigation capability. It is also not a general quality certificate issued by the European Commission. The responsible economic operator must identify applicable legislation, perform or arrange the required conformity assessment, prepare technical documentation, issue an EU Declaration of Conformity, and affix the CE mark where required.

In the context of mobile robotics, the conformity boundary is important. A bare mobile platform, a completed UGV with sensors and radio modules, and a research prototype modified by a system integrator can be different products from a legal and technical perspective.

Why CE marking matters for UGV platforms

A UGV combines mechanical motion, embedded electronics, batteries, wireless communication, software, and potentially autonomous behaviour. Each subsystem can introduce hazards or regulatory obligations. The final assessment must consider the assembled product, intended use, reasonably foreseeable misuse, and operating environment.

For a Leo Rover or Raph Rover deployment, the applicable legal acts depend on the supplied configuration and the final system design. Commonly relevant areas include the following.

Machinery safety – Directive 2006/42/EC applies to machinery placed on the EU market until 19 January 2027. Regulation (EU) 2023/1230 on machinery becomes applicable from 20 January 2027.
Electromagnetic compatibility – Directive 2014/30/EU applies to equipment that may generate electromagnetic disturbance or be affected by it. For radio equipment within the scope of Directive 2014/53/EU, electromagnetic-compatibility requirements are assessed under that directive.
Radio equipment – Directive 2014/53/EU, the Radio Equipment Directive (RED), may apply when the rover or an integrated payload contains Wi-Fi, Bluetooth, LTE, GNSS radio interfaces, or other radio transmitters or receivers.
Restriction of hazardous substances – Directive 2011/65/EU (RoHS) restricts specified hazardous substances in electrical and electronic equipment.
Battery requirements – Regulation (EU) 2023/1542 establishes requirements for batteries and waste batteries, with obligations introduced in stages.

The applicable directives and regulations must be selected for the actual product. A sensor, battery, compute unit, or radio module having its own CE marking does not automatically establish conformity of the integrated robot.

Conformity assessment for a mobile robot

Conformity assessment begins before the CE mark is applied. For a mobile UGV, the manufacturer normally defines the product boundary and intended use, identifies hazards, determines applicable legislation, and gathers evidence that the relevant essential requirements are met.

A practical technical file for a ROS 2-based rover commonly includes the following records.

Product description, configurations, wiring diagrams, bills of materials, and mechanical drawings.
Risk assessment using a documented method, often aligned with ISO 12100:2010 principles for hazard identification and risk reduction.
Evidence for emergency stop functions, motion inhibition, braking behaviour, stability, pinch-point protection, battery safety, and accessible moving parts.
EMC test reports or engineering evidence for the final electrical configuration, including added LiDARs, depth cameras, DC-DC converters, compute units, and motor controllers.
Radio documentation for integrated wireless devices, antenna configurations, firmware, and intended frequency bands where RED applies.
Software version records, ROS 2 package manifests, parameter files, safety-relevant configuration values, and release traceability.
An EU Declaration of Conformity, instructions, safety information, and required labels in the languages required by the target market.

The technical documentation must describe the product as placed on the market. A generic ROS 2 workspace is not sufficient evidence because behaviour can change with parameter values, hardware interfaces, firmware versions, and installed payloads.

CE marking and ROS 2 software

ROS 2 is middleware and does not itself carry CE marking. Packages such as nav2, robot_localization, SLAM implementations, camera drivers, and LiDAR drivers are software components. Their use can affect the behaviour of a CE-marked robot, but installing a ROS 2 package does not create regulatory conformity.

For example, an autonomous navigation stack may publish velocity commands on /cmd_vel, using geometry_msgs/msg/Twist or geometry_msgs/msg/TwistStamped, depending on the ROS 2 and Nav2 version. The system integrator must define how these commands are constrained before they reach the motor controller. Relevant controls can include maximum linear velocity, maximum angular velocity, acceleration limits, command timeout handling, obstacle-stop logic, and a hardware-level emergency stop path.

velocity_smoother:
  ros__parameters:
    velocity_timeout: 0.5
    max_velocity: [0.4, 0.0, 1.0]
    max_accel: [0.5, 0.0, 1.0]

This example is a configuration pattern, not a compliance value. Safe limits must be derived from the rover mass, payload, surface, stopping distance, visibility, operating area, and risk assessment. A parameter file should be version-controlled and associated with the tested hardware configuration.

Leo Rover and Raph Rover integration context

Leo Rover is a four-wheel, differential-drive mobile platform with an IP55 rating and native ROS 2 support on Raspberry Pi-based compute hardware. It is not an autonomous vehicle out of the box. Adding Nav2, a LiDAR, a depth camera, or a GNSS/RTK receiver creates a system whose safety and regulatory assessment must cover the integrated configuration.

Raph Rover is intended for configurations requiring higher payload capacity. A larger payload can change centre of gravity, braking distance, cable routing, battery loading, and electromagnetic emissions. These changes can affect the assumptions used in the original risk assessment. The responsible party should therefore assess the rover with the installed sensor mast, compute enclosure, power distribution hardware, and intended payload.

Research and educational use does not automatically remove CE obligations. A prototype used only internally may be treated differently from a product supplied to another organisation, but supplying a completed rover, kit, or substantially modified system can create manufacturer responsibilities. The legal status should be evaluated for the specific supply model and jurisdiction.

Key limitations of CE marking

CE marking is limited to the scope of applicable EU legislation. It does not prove that a rover is suitable for every site, weather condition, terrain type, or autonomous mission. It does not replace a site-specific operational risk assessment.

For field inspection, agriculture, construction, or research deployments, operators should also define practical operating controls.

Maximum speed and separation distance from people.
Permitted terrain slope, surface condition, and payload position.
Geofencing or supervised operating zones.
Manual takeover, emergency stop access, and loss-of-communication behaviour.
Maintenance intervals for tyres, drive components, battery connectors, and sensor mounts.

Normative references and standards

The following official sources are useful when determining CE-marking obligations for a mobile robotic system. Harmonised standards should be checked in the Official Journal of the European Union because citations and presumption-of-conformity status can change.