A topic that is frequently talked about among manufacturers and designers of equipment is whether individual parts or components of machinery and equipment need to hold a CE mark. This is often caused by the assumption that every single component within a piece of equipment or machine must carry its own CE mark.
In reality, CE marking is only applicable to specific categories of products as defined by legislation. Many everyday components, although they are essential to the function of a machine, actually sit outside of these requirements.
One example, that we came across recently with a client, was regarding a furnace with gas burner that they were using within their operations. The gas burner includes several small nozzles; these form an inconspicuous part of the machine yet they play a very central role in the combustion process. The question we were asked is whether or not this nozzle requires CE marking.
Understanding whether you need to CE mark individual components is crucial for maintaining design and product compliance; it’s also a great example of how the regulatory system actually works and how to apply it.
Understanding What Directive 2016/426 Covers
To answer this question we of course have to turn to the appropriate legislation, in this case Gas Appliances Regulation 2016/426, previously known as the gas appliances directive (GAD).
The directive sets out rules for design conformity of gas appliances across the European market.
The definitions within this directive continue to be important because the regulatory principles have remained largely the same.
Under the Directive, only two types of products require CE marking:
- Gas appliances – complete items designed to burn gaseous fuel, such as boilers, heaters, cookers and burners.
- Fittings – specific components described in Article 1(2) as “safety devices, controlling devices or regulating devices, and subassemblies thereof, placed on the market separately for use by gas appliances.”
Where Gas Burner Nozzles Fit Into the Picture
The gas burner nozzle fits onto the burner equipment, and shapes and directs the flow of gas into the combustion zone- however it does not regulate pressure, or monitor flame stability, or shut off the gas supply, or deliver any form of safety intervention.
Therefore, it does not meet the directive’s definition of a fitting and is thus classed simply as an internal functional component of a burner, and is not a safety device in its own right.
It will be a relief for the designers to know at this stage therefore, that because the gas appliances directive applies only to appliances and their fittings, a burner nozzle within this context does not need CE marking. Instead, the overall appliance or burner assembly must undergo a conformity assessment and carry the CE mark as a finished product. The performance and safety of all of the internal components, which include the nozzle, are assessed as part of this overall certification.
Why This Distinction Matters
This burner nozzle example reflects many components of machines that do not require CE marking. CE marking requirements normally apply at the product level, not to every component that makes up the product (unless it’s a safety component). In that regard, even if an assembly utilises CE marked components, once these components are mounted together into a complete assembly the whole assembly then needs to be CE marked as a whole.
Misunderstanding these nuances can of course lead to unnecessary compliance activity, incorrect procurement expectations, and a lot of avoidable concern during equipment selection or inspection.
Final Thoughts
Understanding how CE marking applies to gas burner nozzles exposes the underlying logic of the various directives that apply to machinery design. Rather than marking every part or requiring every part to be marked, the directive ensures that the overall assembly is safe and compliant.
This approach provides additional clarity, reduces regulatory burden, and focuses attention on what actually matters- the safety critical functions.
You can find guidance on Gas Appliances Regulation 2016/426 published by European Commission here. If you have any additional or specific questions about CE marking of your machinery or components used on your machinery, Knox Thomas is here to help.
