CE marking of automatic doors — step by step

An automatic door counts as a machine

A power-operated pedestrian doorset is a machine within the meaning of the Machinery Directive (2006/42/EC) and must be CE marked before it is put into service. In Sweden, the directive is implemented through the Swedish Work Environment Authority's machinery regulations (AFS 2023:4, which replaced AFS 2008:3 on 1 January 2025), and that authority is responsible for market surveillance. User instructions and the declaration of conformity must be in Swedish for doors supplied in Sweden.

The harmonised standard SS-EN 16005 helps you meet the safety requirements. Following it gives a presumption of conformity with the directive's requirements covered by the standard, but does not replace a risk assessment of the individual installation.

Who is responsible for the CE marking — the manufacturer or the installer?

Door operators are normally supplied as partly completed machinery with a declaration of incorporation — not as a finished, CE-marked machine. The machine only comes into existence when door leaf, operator and sensors are assembled into a working doorset on site.

Whoever completes the door, usually the installer, normally takes on the manufacturer's responsibilities for the whole doorset: risk assessment, technical documentation, declaration of conformity and CE marking. For a complete factory-built doorset installed according to the manufacturer's instructions, those responsibilities normally remain with that manufacturer. It must be clear who is responsible for the finished door's CE marking.

CE marking step by step

For an installed door operator, the route to the CE mark looks like this:

• 1. Carry out a documented risk assessment of the installation per EN 16005, based on the door's environment and users.
• 2. Meet the standard's protective requirements: safety distances, sensors, force limitation and the right performance level for the control system.
• 3. Compile the technical file: description, drawings, the risk assessment, standards applied, test results, and the operator's declaration of incorporation with its assembly instructions. The file must be available to authorities for at least ten years.
• 4. Draw up and sign the EC declaration of conformity — including the manufacturer's details, the door's identification, the reference to the directive and the standards applied — in the language of the country of supply.
• 5. Affix the CE mark to the door and hand over the user instructions, operation and maintenance instructions, and a started logbook to the owner.

Automatic pedestrian doorsets normally do not require a notified body under the Machinery Directive. They are not listed in Annex IV, so the manufacturer declares conformity through internal production control. Protective sensors are safety components with their own requirements, which are the sensor manufacturer's responsibility. As the installer, you are still responsible for selecting, fitting and checking them for the door in question.

Replacing the operator on an existing door — is a new CE marking required?

A like-for-like replacement that preserves the door's safety, function and classification normally counts as maintenance and does not then require new CE marking.

If safety, function, classification or intended use changes, assess whether the change is substantial enough to require new CE marking. This may apply when a door is moved, automatic closing is added, replacement components affect declared characteristics, or the door is adapted for an escape route. Assess and document the risks of the change. If new CE marking is required, you also need new technical documentation and a new declaration of conformity.

Frequently asked questions about CE marking of doors