ATEX Directive requirements for non-EU makers
10 min read
ATEX Directive requirements for non-EU makers: equipment category, notified body, Ex marking, what IECEx reports can do and who must be in the EU.
You build pumps, motors, sensors, luminaires or fans outside the EU for chemical plants, refineries or grain silos, and your range may already hold IECEx certificates. In the EU, these products must meet the ATEX Directive 2014/34/EU on equipment for potentially explosive atmospheres. Here are the ATEX Directive requirements in order: scope, category, conformity route, marking and the business you need in the EU.
What the ATEX Directive covers
Directive 2014/34/EU (opens in a new tab), the ATEX product directive, covers equipment and protective systems for potentially explosive atmospheres, safety and control devices outside them that contribute to their safe functioning, and components built into them (Article 1(1)). An explosive atmosphere is a mixture of air, under atmospheric conditions, with flammable gases, vapors, mists or dusts in which combustion spreads to the entire unburned mixture after ignition (Article 2(4)).
The key words are own potential source of ignition. Hot surfaces and mechanical sparks count as much as electrical sparks, so pumps, fans, compressors, mixers and gears can be ATEX equipment without any electrics (Commission's ATEX Guidelines, § 42). A slow mechanism that, by your assessment, cannot ignite an atmosphere even in rare malfunction is not.
Article 1(2) excludes, among others, medical devices for medical environments, seagoing vessels and means of transport by road, rail, air or water; vehicles intended for use in a potentially explosive atmosphere remain covered.
Group, category and zones
Article 2(6) and (7) divide equipment into group I (mines endangered by firedamp or combustible dust) and group II (other places endangered by explosive atmospheres); Annex I sets the categories. Within group II you assign one of three categories; the marking adds G for gases, vapors or mists and/or D for dust (Annex II, 1.0.5).
| Category | Level of protection | Explosive atmosphere | Zones |
|---|---|---|---|
| 1 | Very high: safe even if one means of protection fails or two independent faults occur | Continuously, for long periods or frequently | 0, 1, 2 or 20, 21, 22 |
| 2 | High: safe even with frequent disturbances or faults normally to be expected | Likely occasionally | 1, 2 or 21, 22 |
| 3 | Normal: safe in normal operation | Unlikely, or infrequently and briefly | 2 or 22 |
Zones are not part of the product directive. Under Directive 1999/92/EC, the employer running the plant classifies hazardous places into zones (Article 7(1)) and selects equipment by category unless its explosion protection document states otherwise (Annex II, Part B). You assign the category and state in the instructions what users need to decide on safe use (Annex II, 1.0.6).
ATEX conformity assessment by category
Article 13 links each category to a procedure. Notified bodies are assessment bodies notified by member states (Article 17) and listed in the Commission's NANDO database.
| Product | Procedure | Notified body |
|---|---|---|
| Category 1 or M1 | EU-type examination (Annex III) plus production quality assurance (Annex IV) or product verification (Annex V) | Type examination, then production audits or product checks |
| Category 2 or M2: electrical equipment, internal combustion engines | EU-type examination plus supervised product testing (Annex VI) or product quality assurance (Annex VII) | Type examination, then supervised tests or quality audits |
| Category 2 or M2: other equipment | Internal production control (Annex VIII), technical documentation communicated to a notified body | Acknowledges receipt, keeps the file |
| Category 3 | Internal production control (Annex VIII) | None |
| Protective systems | As category 1 | Always |
| Any of the above, alternatively | Unit verification (Annex IX) | Tests the individual product |
Components follow the same procedures but carry no CE marking; a written attestation of conformity replaces the declaration (Article 13(3)). Quality system audits cover the actual manufacturer, not your EU representative (§ 56).
What your IECEx file can do
Neither the Directive nor the Commission's ATEX Guidelines (6th edition, January 2026) mention IECEx. Test reports are part of the technical documentation (Annex III, point 3(c), and Annex VIII, point 2). According to the guide, a notified body may accept a manufacturer's test results under conditions based on EN ISO/IEC 17025 and remains fully responsible for its certificate (§ 111); tests it accepts from other laboratories must be justified in its assessment report (§ 112). Ask early which of your reports it can use.
ATEX marking, declaration and instructions
Annex II, 1.0.5 requires equipment and protective systems to be marked legibly and indelibly with at least:
- name, registered trade name or trade mark and address of the manufacturer;
- the CE marking, with the notified body's number where Article 16(3) requires it;
- series or type, any batch or serial number, and year of construction;
- the Ex symbol in a hexagon, followed by group and category and, for group II, G and/or D (for example II 2 G);
- any further information essential to safe use.
Instructions cover at least Annex II, 1.0.6, including electrical and pressure parameters and maximum surface temperatures, in the language each member state sets (Article 6(8)). Each product comes with a copy of the EU Declaration of Conformity on the Annex X model, translated as the member state requires, or for components the attestation; a batch delivered to a single user may share one copy (Articles 6(2) and 14(2)). One declaration covers all EU acts that require one (Article 14(3)).
ATEX and machinery: two sets of rules
Motor-driven pumps and fans are often also machinery (§ 42). Both the Machinery Directive 2006/42/EC (Annex I, 1.5.7) and, from 20 January 2027, Regulation (EU) 2023/1230 (Annex III, 1.5.7) refer explosion risks in potentially explosive atmospheres to the specific EU rules. According to the Commission's guide, ATEX takes precedence for explosion protection and the machinery rules cover the other risks (§ 233). A machine with an explosive atmosphere only inside, without interface to the outside, is not ATEX equipment as a whole, but equipment used in that atmosphere falls under ATEX where atmospheric conditions are present (§ 34).
Our Machinery Regulation 2027 checklist covers the machinery side; typical product mixes are on our process industry and industrial machinery pages.
Who must be in the EU, and for how long
Directive 2014/34/EU is listed in Article 4(5) of Regulation (EU) 2019/1020 (opens in a new tab). Your products may only be placed on the EU market if an economic operator established in the EU performs the tasks in Article 4(3) for them: manufacturer, importer, Authorized Representative with a written mandate or, only if none of these is in the EU, a fulfilment service provider (Article 4(1) and (2)). Its name and postal address go on the product, packaging, parcel or an accompanying document (Article 4(4)).
The ATEX mandate must at least allow keeping the declaration and technical documentation for 10 years after placing on the market, answering reasoned requests and cooperating with authorities (Article 7(2)); ensuring compliant design and manufacture and drawing up the technical documentation cannot be part of it (Article 7(1)). An EU customer that imports your products is an importer (Article 2(14)) with its own duties (Article 8) and can be the economic operator; see Authorized Representative or importer.
Practical example: an IECEx-certified range goes to the EU
A Korean maker of process equipment holds IECEx certificates and plans EU sales with an EU Authorized Representative:
| Product | Marking | Route | Notified body |
|---|---|---|---|
| Pump without motor | II 2 G, non-electrical | Annex VIII, file communicated to a notified body | Keeps the file; no number |
| Pump unit with a bought-in, CE-marked motor that has its own EU-type examination | II 2 G, assembly | Pump as above, plus ignition risk assessment of the combination | Keeps the pump file; none for the assembly if the combination adds no ignition hazard (§ 44) |
| Level sensor in a tank wall between zone 0 and zone 1 | II 1/2 G, electrical | EU-type examination plus Annex IV or V | Type examination, then production audits or product verification; number on the label |
For the sensor, the notified body may consider existing test reports (§§ 111 and 112). All three need instructions in the target countries' languages and a declaration naming the Authorized Representative (Annex X).
Common mistakes with ATEX certification
- Treating an IECEx certificate as EU certification. Article 13 sets EU procedures.
- Marking a zone instead of a category. Zones are the plant employer's classification.
- Adding a notified body number by default. Only where the body is involved in production control (Article 16(3)).
- Showing prototypes at an EU trade fair without a sign. Article 3(3) allows non-compliant products on show only with a visible sign that they do not comply and are not for sale.
- Leaving the EU address off. Customs suspend release when checks find the economic operator's details missing (Article 26(1)(d) of Regulation (EU) 2019/1020).
Conclusion: classify first, then choose the route
The category drives everything else. Start from your IECEx file, but plan for an EU procedure and an economic operator in the EU.
Representa is not a notified body and does not certify products. Our CE marking service helps you identify the applicable directives and harmonized standards, coordinate testing and review your technical documentation. As your EU Authorized Representative, we act within the agreed scope and mandate: we provide our name and address for packaging and the Declaration of Conformity, keep your technical documentation for 10 years and handle authority inquiries. Design, technical documentation and declaration remain your responsibility.
Frequently asked questions
Is an IECEx certificate valid under the EU ATEX Directive?
Not on its own. Directive 2014/34/EU does not mention IECEx and sets its own procedures in Article 13. For category 1 and electrical category 2 equipment, a notified body may take existing test reports into account under conditions, but it issues its own certificate (Commission ATEX Guidelines, §§ 111 and 112).
Does a non-electrical pump need ATEX certification?
ATEX applies if it has its own potential source of ignition, such as hot surfaces or mechanical sparks (Article 2(1) of Directive 2014/34/EU). Category 1 needs a notified body's EU-type examination or unit verification; category 2, internal production control with the technical documentation communicated to a notified body (Article 13(1)(b)(ii)); category 3, internal production control only.
Who decides whether equipment is used in zone 0, 1 or 2?
The employer running the plant. Under Directive 1999/92/EC it classifies hazardous places into zones (Article 7(1)) and selects equipment by category unless its explosion protection document states otherwise (Annex II, Part B). As manufacturer, you assign group and category and give the information needed to decide on safe use in your instructions.
Do I need an EU Authorized Representative for ATEX equipment?
You need an economic operator established in the EU, because Directive 2014/34/EU is listed in Article 4(5) of Regulation (EU) 2019/1020. That can be your EU importer. If no EU business imports the products, an Authorized Representative with a written mandate is the usual route.
Is ATEX CE marking accepted in the UK?
In Great Britain, the Equipment and Protective Systems Intended for Use in Potentially Explosive Atmospheres Regulations 2016 apply, and legislation in force since 1 October 2024 lets businesses use UKCA or CE marking (gov.uk). In Northern Ireland, EU rules apply under the Windsor Framework: CE marking, or CE together with UKNI.
