CE marking of PtX and CCUS facilities

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Get an overview of the requirements and ensure that your Power-to-X or Carbon Capture, Utilisation and Storage plant is correctly CE marked, documented, and ready for lawful commissioning.

Power-to-X (PtX) og Carbon Capture, Utilisation and Storage (CCUS) plants are among the most complex process plants to CE mark. The plants combine technologies from multiple technical fields, e.g., electrolysis, gas treatment, compression, storage, and chemical synthesis, and they are often composed of components and subsystems from many different suppliers.

This means that a single plant is typically covered by several EU legal acts simultaneously: the Machinery Regulation, the Pressure Equipment Directive, the ATEX Directives, the Low Voltage Directive, and the EMC Directive, among others. Responsibility for CE marking of the overall plant can be difficult to assign, especially when no single party has the complete overview.

Danish Technological Institute helps plant owners, system integrators, and manufacturers navigate the requirements and ensure that the plant is correctly CE marked before it is put into service.

Learn more about CE marking in the video below

When multiple directives and regulations meet one plant

CE marking of PtX and CCUS plants is complicated because the plants do not fit neatly under a single directive. The typical challenges we encounter are:

Multiple directives in play simultaneously. A PtX plant may be covered by the Machinery Regulation (as an assembly of machinery), the Pressure Equipment Directive (for pressure vessels and piping), the ATEX Directives (explosive atmospheres), and potentially others. It is rarely straightforward how the requirements from the different directives interact.
Responsibility for the complete plant is unclear. When the plant consists of subsystems from multiple suppliers, the question arises: Who bears the CE marking responsibility for the whole? Who prepares the risk assessment for the complete plant? And who issues the declaration of conformity?
The standard landscape is immature. For many PtX and CCUS technologies, fully comprehensive harmonized standards do not yet exist. This places greater demands on the manufacturer's own risk assessment and documentation.
Time pressure and parallel processes. The plants are often built at a pace where the CE marking process must run parallel to design, procurement, and assembly. This requires early planning to avoid delays.
Interfaces between subsystems. Safety in the overall plant depends not only on the compliance of individual components, but also on how they are integrated. The interfaces between subsystems are often where risks arise.
Regulatory requirements and commissioning permits. In addition to CE marking, national requirements for commissioning PtX and CCUS plants may apply, e.g., from the Danish Working Environment Authority, the Danish Environmental Protection Agency, the Danish Business Authority, and other authorities.

Danish Technological Institute's role in your CE marking process

Danish Technological Institute helps you create clarity and momentum in the CE marking process for PtX and CCUS plants. Our assistance can be adapted to your role, whether you are a plant owner, system integrator, or component supplier:

Mapping the regulatory landscape. We identify which EU legislation and essential requirements apply to your specific plant, and how the requirements from the various directives and regulations interact.
Clarifying the division of responsibility. We help determine who holds the CE marking responsibility for the complete plant and for individual subsystems, and we ensure that the division of responsibility is documented.
Risk assessment of the overall plant. We assist with or review the risk assessment, including evaluation of interfaces between subsystems and the risks arising from integration.
Technical documentation. We help structure and prepare the technical documentation so that it covers the requirements from all relevant directives.
ATEX advisory services. For plants with explosive atmospheres, we assist with zone classification, ATEX APV (explosion protection document), and selection of correctly classified equipment.
Pressure equipment. We can help you obtain certification for pressure equipment in the plant through our notified body, Dancert.
Sparring on standards. We help identify relevant standards and evaluate how they can be applied, even in cases where fully comprehensive harmonized standards do not yet exist.
Planning the CE marking process. We help lay out a schedule that accounts for parallel processes in design, procurement, and assembly.

What you are left with afterwards

A collaboration with Danish Technological Institute on CE marking of PtX or CCUS plants provides you with:

Overview of requirements. You know exactly which directives and standards apply and what must be documented to achieve CE marking.
Documented division of responsibility. It is clear who is responsible for what, and the documentation supports it. This reduces the risk of disputes between project parties.
A risk assessment covering the whole. The risk assessment accounts for the overall plant, including interfaces and integration risks, not just individual components.
A stronger foundation during regulatory inspections. With coherent technical documentation and correct CE marking, you are better equipped when authorities ask questions.
Fewer delays. Early inclusion of CE marking requirements in project planning reduces the risk of missing documentation or approvals delaying commissioning.
Access to specialists across directives. Danish Technological Institute covers the Machinery Regulation, the Pressure Equipment Directive, and the ATEX Directive with in-house specialists, enabling us to handle the cross-cutting requirements posed by PtX and CCUS plants.

Relevant directives for PtX and CCUS plants

PtX and CCUS plants are typically covered by several EU directives. The most relevant are:

Machinery Regulation ((EU) 2023/1230). Applies to individual and assembled machinery in the plant.
Pressure Equipment Directive (PED, 2014/68/EU). Applies to pressure vessels, piping, boilers, and safety accessories in the plant.
ATEX Equipment Directive (2014/34/EU). Applies to equipment intended for use in potentially explosive atmospheres, e.g., in zones with hydrogen or flammable gases.
ATEX Workplace Directive (1999/92/EC). Sets requirements for employers regarding zone classification, risk assessment, and explosion protection documentation for workplaces with potentially explosive atmospheres.
Low Voltage Directive (2014/35/EU) and EMC Directive (2014/30/EU). May apply to electrical components and control systems in the plant.

Which directives specifically apply depends on the plant's specific design, components, and operating conditions. Danish Technological Institute helps you map the regulatory requirements.

Contact us

Are you planning a PtX or CCUS plant and need clarification on CE marking requirements? Contact Danish Technological Institute's specialist and center director, Maja Rose Wieland, for an initial discussion about your project.

FAQ

What is required to CE mark a PtX plant?

CE marking of a PtX plant requires that all relevant EU legal acts are identified and met, typically including the Machinery Regulation, Pressure Equipment Directive, and ATEX Equipment Directive. An overall risk assessment, technical documentation, and declaration of conformity must be prepared for the plant as a whole.

Who is responsible for the CE marking of an assembled plant?

Responsibility for the CE marking of the overall plant lies, as a starting point, with the party assembling and commissioning the plant. This may be the plant owner, system integrator, or EPC contractor. Danish Technological Institute helps clarify and document the division of responsibility.

Which directives apply to CCUS plants?

CCUS plants are typically covered by several EU legal acts, including the Pressure Equipment Directive (for pressure vessels and piping), the Machinery Regulation (for the overall plant), the ATEX Directive (if potentially explosive atmospheres are present), and the Low Voltage Directive and EMC Directive. The specific regulatory landscape depends on the plant design.

Are there harmonized standards for PtX plants?

Standards for PtX technologies are still under development, and fully comprehensive harmonized standards are not always available. This places greater demands on the manufacturer's own risk assessment and documentation. Danish Technological Institute helps identify relevant standards and assess how they can be applied.

Can Danish Technological Institute also act as a notified body for parts of the plant?

If parts of the plant require certification according to the ATEX Equipment Directive or the Pressure Equipment Directive, Dancert can act as a notified body for the task.

When in the project process should the CE marking process start?

The CE marking process should start as early as possible in the project process, ideally during the design phase. Early involvement reduces the risk of missing documentation or unmet requirements delaying commissioning.