Does Your Service Robot Need a Notified Body?

A service robot notified body is not required merely because a sales brochure says “AI”, “autonomous” or “machine learning”. The decision turns on the product category and the function performed. Under the current consolidated Machinery Regulation (EU) 2023/1230, dated 27 July 2026, Annex I Part A captures specific higher-risk categories. Its points 5 and 6 address fully or partially self-evolving behaviour that uses machine-learning approaches to ensure safety functions. Article 25 then removes the internal-control route for those Part A categories.

That distinction matters before a Greek hotel pays a deposit. If the robot falls within Part A, the manufacturer must use an EU type-examination followed by conformity to type, full quality assurance, or unit verification. Each route involves a notified body. If the robot is in Part B, internal production control is possible only under the conditions in Article 25(3). If it is not listed in Annex I, Article 25(4) points to internal production control. Software may still create demanding safety obligations even where it does not change the conformity route.

Start with the function, not the vendor’s AI label

The procurement team needs a functional description of the control system. Ask which outputs can initiate, permit, limit or stop movement. Ask which sensors feed those outputs, whether the decision logic changes after deployment, and what happens when a model, map or software package is updated. A robot that learns guest preferences is not automatically in Annex I Part A. A system that changes a safety-related stopping decision through a machine-learning approach is a different case.

Recitals 54 and 55 of the Machinery Regulation explain the boundary. The third-party rule concerns systems with fully or partially self-evolving behaviour that use machine-learning approaches and ensure safety functions. Software that cannot learn or evolve and is programmed only to execute automated functions is outside that particular machine-learning trigger. This does not make fixed software safe by declaration. Annex III still governs essential health and safety requirements, including control-system reliability and protection against corruption.

Do not classify from a product name. “Autonomous mobile robot” describes a market category, not an Annex I finding. The manufacturer should map the actual product against every Part A and Part B entry. A hotel robot may also contain a separately supplied safety component or logic unit. The classification must say whether the item assessed is the complete robot, an embedded system, or a component placed on the market independently.

When a notified body is mandatory under Part A

Article 25(2) gives three routes for machinery and related products in Annex I Part A. The first is EU type-examination under module B followed by conformity to type based on internal production control under module C. The second is full quality assurance under module H. The third is unit verification under module G. There is no stand-alone module A option for a Part A product.

Annex I Part A point 5 covers safety components with fully or partially self-evolving behaviour using machine-learning approaches that ensure safety functions. Point 6 covers machinery that embeds such systems, where the systems have not been placed independently on the market, but only with respect to those systems. The wording is narrower than “robot with AI” and wider than a detachable software product. It asks what the system does for safety and whether its behaviour evolves through machine learning.

The practical evidence is a notified-body record tied to the correct scope. The NANDO system lists organisations notified by Member States and the tasks for which each is notified. The Commission’s notified-body guidance says the manufacturer may choose a body legally designated for the required procedure. A current NANDO list for Regulation 2023/1230 shows product scopes and modules. A certificate from a testing company is not enough if the company is not notified for the relevant regulation, product category and module.

Part B and unlisted machinery follow different routes

Part B is not the same as Part A. Article 25(3) lists module A, B followed by C, H and G. Internal production control under module A is available only when the manufacturer designs and constructs the product in accordance with harmonised standards or common specifications specific to that category and those specifications cover all relevant essential health and safety requirements. If that coverage is missing, incomplete or not followed, the manufacturer must use B plus C, H or G.

Part B includes, among other categories, logic units that ensure safety functions. That entry deserves a separate check when a robot supplier relies on a safety controller, perception unit or control package. It does not mean that every complete service robot becomes Part B merely because it contains control logic. The manufacturer should identify the product category, the boundaries of the assessed item and the standards used to claim complete coverage.

For machinery not listed in Annex I, Article 25(4) provides module A. The manufacturer still carries out the conformity assessment, prepares Annex IV technical documentation, meets the Annex III requirements, signs the EU declaration of conformity and affixes CE marking. The EU’s conformity-assessment guidance makes the general point clearly: harmonised standards are voluntary, but the applicable legal requirements are mandatory. Choosing another technical solution does not remove the burden of proof.

Ask for a classification pack before final payment

A CE logo on the housing does not answer the Article 25 question. Ask the supplier for one controlled package that connects the robot’s identity to its classification, assessment route and technical evidence. The package should use the exact model, variant, software baseline and serial or batch identifiers in the commercial documents.

Evidence item	Question it must answer	Reason to hold payment
Annex I classification memo	Is the product in Part A, Part B or unlisted, and why?	No reasoned product-category decision
Safety-function architecture	Which sensors, logic and outputs ensure safety?	AI marketing terms replace a functional description
Learning-behaviour statement	Can safety behaviour evolve after design or deployment?	Updates or learning boundaries are undefined
Conformity-route record	Which Article 25 module applies?	Module A is claimed without the required basis
Notified-body evidence	Does the body and scope match the category and module?	The certificate is voluntary, expired or out of scope
Standards coverage matrix	Which Annex III requirements are covered and where are the gaps?	Part B module A rests on partial coverage
EU declaration and CE data	Do model, manufacturer, legislation and body details agree?	Identifiers conflict across documents

The EU technical-documentation guidance explains that evidence must support the declaration and remain available to authorities. The CE-marking guidance also warns that the manufacturer, not an EU office, is responsible for compliance. Where a notified body participates in the production-control phase, its identification number appears next to the CE marking under the applicable rules.

Use a procurement sequence that exposes gaps early

1. Freeze the exact robot model, options, payload, speed, sensors, docking system, lift interface and software release in the request for quotation.
2. Ask the manufacturer to identify every safety function and state whether any function uses fully or partially self-evolving machine-learning behaviour.
3. Require a written Annex I classification for the complete robot and for independently marketed safety components or logic units.
4. Match the selected Article 25 module to Part A, Part B or unlisted status.
5. For Part B module A, obtain the standards and common-specification matrix showing complete coverage of relevant Annex III requirements.
6. For a third-party route, verify the body’s live NANDO notification, product scope and module before relying on its certificate.
7. Reconcile model names, software versions, certificate references, declaration data and CE marking before shipment.
8. Put document delivery, update control and material configuration changes into acceptance clauses, with payment retained until the pack is consistent.

This sequence complements a full Annex IV technical-file review. It also depends on identifying the correct service robot manufacturer. A hotel cannot fix a missing manufacturer assessment by collecting disconnected laboratory reports after delivery.

Budget for the route, but do not invent a certification price

The conformity route affects engineering work, evidence review, testing, audit time and change control. Module B plus C separates type examination from production conformity. Module H assesses a full quality system. Module G assesses a unit. Those differences can change commercial timing, but there is no reliable universal price or lead time for a hotel robot. Product complexity, technical-file quality, test needs, notified-body scope and the maturity of the manufacturer’s system all matter.

A useful commercial model has four separate lines: manufacturer remediation, laboratory or specialist testing, notified-body assessment where required, and internal integration work. Keep a fifth contingency line for rework after a material software or hardware change. The Commission’s Blue Guide explains the conformity modules at a horizontal level, but the sector-specific rule in Article 25 controls the available route.

Uncertainty and legal boundary: Whether a particular perception, navigation or control system “ensures a safety function” is a technical and legal classification based on the actual design. Procurement staff should not infer it from a brochure. This article is analysis, not legal advice or a product certification.

The decision to record

Before final payment, record the product’s Annex I category and assessment route. Part A needs a verified notified-body route. Part B needs either complete standards coverage for module A or a verified notified-body route. Unlisted machinery needs module A and a complete manufacturer assessment. If the supplier cannot identify the safety functions, learning behaviour and Article 25 route, the file is not ready for acceptance.

The Commission states that the Regulation applies on a mandatory basis from 20 January 2027. Machinery placed on the EU market before that date remains under Directive 2006/42/EC, subject to the Commission’s stated transition guidance. The expected placing-on-the-market date therefore belongs in the procurement record.

Frequently asked questions

Does every autonomous service robot need a notified body?

No. Autonomy is not enough by itself. Check whether the product falls in Annex I Part A or Part B and apply Article 25. Part A requires a notified-body route. Unlisted machinery uses module A under the Regulation.

Does machine learning automatically trigger Annex I Part A?

No. Points 5 and 6 concern fully or partially self-evolving behaviour using machine-learning approaches that ensures safety functions. The function and behaviour must be established from the design evidence.

Can a Part B product use internal production control?

Yes, but only when the Article 25(3) conditions are met. Harmonised standards or common specifications specific to the category must cover all relevant essential health and safety requirements and be applied in design and construction.

How do we check a notified body?

Search NANDO by Regulation (EU) 2023/1230. Match the body’s identification number, product category and conformity module to the certificate and the supplier’s classification memo.

Is a voluntary certificate proof of CE compliance?

No. NANDO and Commission guidance warn against confusing voluntary certificates with conformity assessment by a notified body acting within its notified scope. The manufacturer remains responsible for the complete legal assessment.

What should a hotel do if the supplier cannot explain the route?

Hold acceptance and the related payment milestone. Ask for the classification memo, safety-function architecture, standards matrix and matching conformity records. Use technical or legal advice for unresolved classification questions.