Procurement Contracts as a Safety Tool
22 September 2026 
When end-user or machine integrator order a new machine from the UK or abroad, there is often an implicit assumption that CE marking (or UKCA marking) is a guarantee of safety. After all the marks are intended to indicate that the machine meets the essential health and safety requirements of the Machinery Directive (soon to be replaced by the Machinery Regulations). Many safety professionals and engineers know from experience that this assumption can be dangerous.
CE marking is a well-established legal requirement; however, it rests on a foundation of self-certification. Manufacturers can declare their machines compliant without independent scrutiny, unless the machinery falls into a very narrow category requiring third-party assessment. For end-users in the UK, this lack of transparency creates risks that are frequently left unaddressed.
The reality is that the system relies heavily on trust. Many suppliers perform thorough assessments and apply standards diligently. Others adopt a more superficial approach. The process allows them to self-declare conformity without disclosing the depth or quality of their work. End-users often receive a CE mark and a single page declaration, but no visibility of the underlying risk assessment, no evidence of how standards have been applied, and no guarantee that critical hazards have been addressed.
This opaqueness creates a real risk that new machinery might enter a workplace with inadequate guarding, unsafe control systems, poorly designed electrical installations, or hidden hazards not identified during design. At worst, these shortcomings result in dangerous machinery being put into service, with the often expensive and time-consuming burden of corrective action falling on the end-user. The lack of transparency in self-certification means such problems may not become apparent until integration, commissioning, or even after incidents have occurred.
If CE (and UKCA) marking leaves gaps, how can companies protect themselves? One of the most effective solutions is to build safety directly into the procurement process. Contracts don’t have to be purely commercial documents; they can be a powerful tool for ensuring compliance and accountability. By embedding safety requirements into legally binding procurement contracts, end-users can ensure the safety of their employees and achieve greater transparency with their suppliers.
A well-structured procurement contract should clearly set out expectations for safety and compliance. This means requiring suppliers to follow key standards such as BS EN ISO 12100 for risk assessment, BS EN ISO 13849 for functional safety, BS EN 60204-1 for electrical systems, and relevant type C standards. Crucially, the contract should require the supplier to provide supporting documentation that demonstrates compliance. For example; a full risk assessment, a list of safety functions, functional safety verification, circuit diagrams.
Transparency can also be strengthened by granting the end-user the right to carry out audits, either directly or through an appointed expert. This contractual right enables end-users to inspect the technical file, review safety justifications, and confirm that standards are applied correctly. The contract should make clear that safety documentation is not optional or hidden, but an integral deliverable.
Every engineer and health and safety professional who has received a new machine only to discover hidden hazards knows the frustration, cost, and risk that this entails. Too often these problems are treated as unavoidable. However, by strengthening procurement contracts, specifying key standards, requiring transparency, and retaining the right to audit and verify, end-users can protect their workers, and make operating and maintaining their machines safer.
Review your recent procurement experiences. Think of the issues you have faced, from incomplete documentation to safety flaws that emerged too late. Then consider how these could have been prevented if your contracts had contained the right clauses. Consult with machinery safety experts when needed, and put in place robust contract templates.
Want to learn more?
Email: sales@euchner.co.uk or
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