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# CE Marking for Collaborative Robots (Cobots)

Cobots combine standard industrial robot CE requirements with additional obligations specific to human-robot contact scenarios. The four collaborative operation modes — SSM, HGP, SLS, and PFL — each have distinct technical requirements, and the risk assessment must address human biomechanical limits, not just hazard elimination.

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At a glance

Applicable legislation

3

Collaborative operation modes

4

Key standards

6

## Applicable legislation

Machinery

### Machinery Regulation 2023/1230 / Directive 2006/42/EC

Primary legislation for cobots as machinery. Regulation 2023/1230 applies from January 2027; Directive 2006/42/EC applies until then. Cobots are machinery; the collaborative workspace is part of the risk assessment.

EMC

### EMC Directive 2014/30/EU

All electrically powered cobots — drive systems, control electronics, sensors. EMC is particularly important for cobots with safety-critical sensor inputs that must not be degraded by emissions.

LVD

### Low Voltage Directive 2014/35/EU

Mains-powered cobot systems and control panels. Applies to the electrical safety of power supplies, drives, and control enclosures.

## The four collaborative operation modes (ISO/TS 15066)

SSM

### Safety-rated monitored stop

The robot stops before a human enters the collaborative workspace. When the human leaves, the robot resumes without manual restart. Requires safety-rated position monitoring of both human and robot.

HGP

### Hand guiding

The operator physically guides the robot arm directly. Requires a hand guiding device with enable switch and emergency stop. Robot speed is limited while hand guidance is active.

SLS

### Speed and separation monitoring

The robot slows as a human approaches and stops before contact occurs. Requires real-time distance calculation between human body parts and robot, with speed reduction proportional to proximity.

PFL

### Power and force limiting

The robot is designed so that contact between human and robot — whether expected or not — does not cause injury. Force, pressure, and energy are limited to values within pain and injury thresholds from ISO/TS 15066 Annex A.

## Key harmonised and technical standards

EN ISO 10218-1

Robots and robotic devices — safety requirements for industrial robots — robot design

EN ISO 10218-2

Robots and robotic devices — safety requirements for robot systems and integration

ISO/TS 15066

Robots and robotic devices — collaborative robots — biomechanical limits and operation modes

IEC 62061

Safety of machinery — functional safety of safety-related control systems (SIL assessment)

EN ISO 13849-1

Safety of machinery — safety-related parts of control systems (PL assessment)

EN ISO 12100

Safety of machinery — general principles for design — risk assessment and risk reduction

## Frequently asked questions

### Is a cobot the same as an industrial robot for CE marking purposes?

Cobots are a subset of industrial robots — they are specifically designed to work in direct contact or close proximity with humans. EN ISO 10218-1 and 10218-2 apply to both cobots and traditional industrial robots. ISO/TS 15066 adds cobot-specific requirements for collaborative operation modes and biomechanical limits. For CE marking, cobots fall under the Machinery Regulation/Directive, the same as industrial robots — there is no separate cobot-specific CE framework.

### What biomechanical limits apply to PFL (Power and Force Limiting) cobots?

ISO/TS 15066 Annex A provides detailed biomechanical limit values for maximum quasi-static and transient contact force and pressure at different body regions (head, neck, chest, hands, etc.). For example, the hand/finger region has a quasi-static limit of 140 N force and 270 N/cm² pressure. These limits must be verified through measurement during risk assessment — not just calculated. The specific values depend on contact body part and type of contact.

### Does a complete cobot installation require a new CE marking?

It depends. A cobot robot arm supplied by a manufacturer comes with its own CE mark for the base robot. When an integrator installs the cobot into a complete system with tooling, conveyors, safety fencing (or no fencing), and a control system, the integrator creates a new machine. The integrated system needs its own CE assessment under EN ISO 10218-2 — the robot arm's CE mark does not automatically transfer to the complete installation.

### What functional safety level is required for cobot safety functions?

The required safety integrity level depends on the risk assessment. PFL collaborative applications typically require safety functions at PLd/SIL2 or PLe/SIL3 depending on speed, force, and the body regions at risk. Speed monitoring and position monitoring for SSM and SLS applications require safety-rated sensors and control systems at equivalent SIL/PL levels. IEC 62061 and EN ISO 13849-1 are the two harmonised standards for this assessment.

**Disclaimer:** Educational resource only. Cobot safety involves life-safety engineering decisions. Always engage a qualified functional safety engineer and follow current versions of EN ISO 10218 and ISO/TS 15066 for your specific application.

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