Autonomous pallet truck regulations: CACES, EN ISO 3691-4 and liability in 2026

An autonomous pallet truck does not fall under CACES R489, which is reserved for ride-on handling trucks, but its introduction remains strictly regulated: the EN ISO 3691-4 standard on the manufacturer's side, and a DUERP risk assessment plus operator training on the employer's side. No official text settles the whole subject in black and white today, which is why this overview is useful — validate it with your Carsat before any deployment.

Autonomous pallet truck regulations: why the topic is still evolving

French regulation was built around the ride-on truck: an operator at the controls, whose medical fitness, training and driving authorization are all regulated. The autonomous pallet truck, on the other hand, moves with no one on board — it doesn't fit into any existing box, which explains the frequent confusion among customers and prospects.

In practice, two sets of rules apply in parallel: technical standards governing the robot's design (EN ISO 3691-4), and general occupational-safety obligations that fall on the company operating it (DUERP, training, informing staff). Neither set was written specifically for the pallet AMR — they apply to it by extension, not through a dedicated text.

It's this grey area that makes the topic of « autonomous pallet truck regulations » a sensitive one: neither a legal void nor a fully settled framework. Prudence calls for checking every point with your regional Carsat and the INRS before any deployment.

Autonomous pallet truck regulations: the CACES and EN ISO 3691-4 framework

CACES R489 governs self-propelled, ride-on handling trucks, split into nine categories. Its central criterion is the physical presence of an operator at the controls. An autonomous pallet truck, which carries out missions with no operator on board, therefore falls outside its scope: as of August 2026, there is no CACES category dedicated to driverless trucks.

The NF EN ISO 3691-4 standard ("industrial trucks — safety requirements and verification, part 4: driverless trucks and their systems") is the key technical reference text. Its 2023 version, revised under French leadership with manufacturers such as Balyo, Alstef and KION/Fenwick-Linde as well as the Ministry of Labour, governs operating zones, person detection, speeds and the robot's signage (source: UNM). It is awaiting full harmonisation with the Machinery Regulation (EU) 2023/1230 in the Official Journal of the European Union — a status to recheck at the time of your project, since it determines the robot's presumption of conformity.

What is still missing: no official text, order, CNAM recommendation or published INRS position explicitly states "no CACES for an autonomous pallet truck, here is what's needed instead." The reading set out here is inferred from the scope of R489 and the EN ISO 3691-4 standard — it is not a doctrine validated by a dedicated regulatory text. This is the single most important point in this entire article: never present the absence of CACES as an absence of training.

DUERP and risk assessment: the obligation that never goes away

The single occupational risk assessment document (DUERP) is mandatory from the first employee, updated at least once a year for companies with 11 or more employees, and whenever the company undergoes a significant change. Introducing an autonomous pallet truck is one such change: it's a change to how work and traffic are organised, not simply an equipment purchase.

In practice, the update must cover: the new mixed human-robot traffic zones, interactions with forklift operators and pedestrians, manual-takeover and emergency-stop procedures, and any supervision positions created or changed. Under the 2022 Occupational Health Act, the DUERP must be kept for 40 years.

An up-to-date DUERP is not just a formality: it is also a condition for accessing Carsat grants for handling equipment that reduces MSD risks, which can fund up to 70% of certain investments depending on the regional fund and the terms of the application.

Who is liable in the event of an accident involving a robot?

No industry data currently documents case law specific to autonomous pallet trucks in France — the topic is too recent. The general principle remains that of labour law: the employer must ensure the safety of its employees, which includes risk assessment (DUERP), training for operators and exposed staff, and compliance with the manufacturer's maintenance recommendations.

In the event of an accident involving a robot, the investigation will likely look at several factors: did the DUERP properly account for the robot and its traffic zones? Were operators and nearby staff trained and informed? Was the robot compliant (CE marking, maintenance) and used within the manufacturer's intended scope? For temporary workers assigned to at-risk positions, enhanced safety training is a legal requirement (Art. L4154-2 of the Labour Code); failing that, the employer risks a presumption of inexcusable fault.

Shared liability between the operator and the manufacturer cannot be ruled out depending on the circumstances, but nothing replaces a thorough, well-documented upfront risk assessment on the company's part. This point deserves to be validated with your insurer and, where appropriate, legal counsel — this article is not a substitute for that.

Marking and signage: what the robot must display

The EN ISO 3691-4 standard requires the robot to carry visible safety features: light and/or sound signals while moving, accessible emergency-stop controls, and person detection that triggers slowing down or stopping depending on distance. These requirements are aimed first at the manufacturer and the integrator, who must demonstrate them in their technical documentation.

On the warehouse side, the principles already known for conventional trucks also apply to the zones the robot travels through: floor marking (order of 4 November 1993, white/yellow/red/green/blue codes depending on function), aisle width suited to the vehicle's footprint, and separating pedestrian and vehicle flows where possible. INRS guide ED 6002 remains the methodological reference for sizing these traffic routes, even though no single legal width is imposed: each site's own risk assessment determines it.

Autonomous pallet truck regulations: what to check before buying an AMR

Before signing a quote, a few checks limit your regulatory and contractual risk.

• CE marking and the EU declaration of conformity. Like any equipment covered by the Machinery Regulation, an autonomous pallet truck must in principle carry these, along with instructions in French.
• The manufacturer's technical file. It must demonstrate compliance with EN ISO 3691-4: person detection, speeds, operating zones, stop procedures.
• The standard's harmonisation status with the Machinery Regulation (EU) 2023/1230 at the time of your purchase — a point that is evolving and should be confirmed directly with the supplier.
• The training programme offered for your supervising operators and, ideally, support in updating your DUERP.
• Maintenance recommendations and their traceability, which will carry weight in the event of an inspection or an incident.

These checks don't replace your own risk assessment, but they secure the starting point: a compliant, documented robot, and a supplier able to support you on the regulatory side, not just on delivering the machine.

Summary table of obligations

FAQ

Who is liable in the event of an accident involving an autonomous pallet truck?

The employer remains bound by its general safety obligation: an up-to-date DUERP, training for operators and exposed staff, and compliance with the manufacturer's recommendations. No case law specific to AMRs has yet been documented in France; shared liability with the manufacturer is not ruled out depending on the circumstances. Have this point validated with your insurer.

Must an autonomous pallet truck carry CE marking?

In principle, yes: like any equipment covered by the Machinery Regulation, it must carry CE marking, an EU declaration of conformity and instructions in French. The harmonisation status of the EN ISO 3691-4:2023 standard is evolving: check it directly with the supplier at the time of your purchase.

Must the DUERP be updated before deploying an autonomous robot?

Yes, always: introducing an autonomous pallet truck constitutes a significant change to the organisation of work and traffic, which must be incorporated into the risk assessment document. This update is also a condition for accessing Carsat grants for handling equipment that reduces MSD risks.

What documents must an AMR supplier provide to the buyer?

A technical file demonstrating compliance with EN ISO 3691-4, an EU declaration of conformity, instructions in French, and ideally a training programme for supervising operators. These elements strengthen your regulatory file and make updating your DUERP easier.

Is there a regulatory text specific to autonomous pallet trucks?

No, no official text explicitly settles the matter today. The applicable framework combines the technical EN ISO 3691-4 standard on the manufacturer's side with general Labour Code obligations on the employer's side. Written validation from your regional Carsat is still recommended before any deployment, as the doctrine is still young.

Related reading

• Do you need a CACES certificate to drive an electric or autonomous pallet truck? A detailed look at CACES scope by equipment type.
• CACES for handling robots: do you need certification to operate an autonomous robot? A deeper look at the CACES and EN ISO 3691-4 angle.
• Operating a truck without CACES: what the law actually says, and the difference between CACES and a driving authorization.
• Autonomous pallet truck: the complete 2026 guide — how pallet AMRs work and the technology behind them.
• DUERP for warehouses and logistics: the complete checklist for updating your risk assessment document step by step.
• Mobile robots and forklift operators sharing a warehouse: the protocol to formalise — the operational side of human-robot coactivity.
• Specifications for a mobile warehouse robot: the checklist before your tender, to structure your supplier comparison.
• Mobile robots in washdown food-industry zones: IP69K and compliance for intensive-washing environments.

Are you preparing to deploy an autonomous pallet truck and want to get the regulatory side right? Easy to Carry, distributor of the autonomous pallet truck in France, supports you on the robot's compliance (CE marking, EN ISO 3691-4 documentation) and on updating your DUERP, without ever promising a full exemption from training — since some form of it is still required. Discover the robot or request regulatory support.