1. The deadline: 20 January 2027

The Machinery Regulation (EU) 2023/1230 applies from 20 January 2027 (Art. 54) and repeals the Machinery Directive 2006/42/EC on the same day (Art. 51). There is no choice between the two regimes and no transition period for placing on the market: anyone placing machinery on the market from that date must comply with the Regulation - even if its design started years earlier.

The Regulation does settle two things for existing stock (Art. 52): machinery placed on the market in conformity with the Directive before 20 January 2027 may continue to be made available - so selling stock through the supply chain remains permitted. And EC type-examination certificates issued under the Directive remain valid until they expire.

One trap for anyone reading the legal text: the original Official Journal version said 14 January 2027 - a corrigendum corrected it to 20 January. Cite the uncorrected text and you cite the wrong date; the consolidated text is the version to work from.

2. Digital is allowed - under three conditions

The heart of the change sits in Art. 10(7): “The instructions may be provided in a digital format.” Under the Directive, paper was effectively the default; now the digital form is legally on a par with the paper version. Three conditions are attached:

  1. Access must be findable. The manufacturer must mark on the machinery itself - or, where that is not possible, on its packaging or in an accompanying document - how to access the digital instructions. In practice that usually means a QR code or URL on the nameplate.
  2. The format must belong to the user. The instructions must be printable, downloadable and storable on the user’s own device, so that they remain available even when the machinery fails. That applies explicitly when the instructions are embedded in the machinery’s software - an on-screen manual with no export option is not enough.
  3. At least ten years online. The instructions must remain accessible online for the expected lifetime of the machinery, and for at least ten years after placing on the market. For machinery that runs for decades - the rule rather than the exception in mechanical engineering - the lifetime is the longer and therefore the decisive period.

The EU declaration of conformity may also be provided digitally (Art. 10(8)): instead of enclosing it, the manufacturer can state in the instructions the internet address or machine-readable code where it can be accessed - again for at least ten years. For partly completed machinery the model applies analogously: the assembly instructions may be delivered digitally (Art. 11(7)), though here the text requires only the ten years online, without the lifetime clause.

3. The exceptions: paper remains a right

Digital-only is allowed, but not unconditional. Two exceptions belong in every manufacturer’s processes:

First, the paper request. If the user requests a paper version at the time of purchase, the manufacturer must provide it free of charge within one month. The detail about the time of purchase is easy to miss: the right arises at purchase, not years later in a service case - but sales need to be ready to take the request and trigger it. A process that simply does not exist in many companies today.

Second, non-professional users. For machinery intended for non-professional users - or that can, under reasonably foreseeable conditions, be used by them even if not intended for them - the safety information that is essential for commissioning and safe use must still be supplied on paper. Not the complete instructions, but the safety-critical core. For pure B2B capital equipment this rarely matters; for anything that can end up in a hobby workshop, it very much does.

4. Language and translation: what actually changes

On language, the Regulation changes little: the instructions for use, the safety information and the information required by Annex III must be in a language which can be easily understood by users, as determined by the Member State concerned - clear, understandable and legible. Ship to twenty countries and you still document in twenty language versions. There is one exception with real practical value: maintenance instructions intended for use by specialised personnel mandated by the manufacturer may be written in only one official language of the Union which that personnel understands (Annex III, section 1.7.4).

What is remarkable is what is missing: the obligation known from the Directive to label every version as “original instructions” or a “translation of the original instructions” no longer appears anywhere in the Regulation. Nor does the Regulation prescribe a translation method - machine translation is neither banned nor privileged. What counts is solely the result in the target language, and the manufacturer carries the responsibility for it. That is an opening with a built-in liability question: anyone translating by machine needs quality assurance worthy of the name.

5. Standards: what you can rely on today

An uncomfortable truth about the deadline: no harmonised standards have yet been listed for the Machinery Regulation in the Official Journal. The Commission’s standardisation request to CEN and CENELEC dates from January 2025; since then, the roughly 800 standards harmonised under the Machinery Directive have been under review, with more than 600 examined by mid-2026 according to industry reporting. An implementing decision with the first list of standards is expected towards the end of 2026 - just before the Regulation starts to apply. Until then there is no presumption of conformity via standards for new machinery, only direct demonstration against the requirements of the Regulation itself.

For information for use itself, IEC/IEEE 82079-1 (2021 edition) remains the professional benchmark: it describes how instructions are prepared for their audience, structured and testable - regardless of the medium. It is not a harmonised standard under the Regulation, but it is the documented state of the art that the technical communication field, including the tekom, works to.

And the construction site keeps growing: the Digital Omnibus on AI (Regulation (EU) 2026/1744) of July 2026 amends not only the deadlines of the AI Act but the Machinery Regulation itself: the requirements for safety-related AI in machinery are to be governed primarily in the Machinery Regulation, applying from 2 August 2028. For manufacturers this means the documentation duties and the AI duties are converging - and both hang on the same question of how well your technical content is structured.

6. The opportunity behind the obligation

You can treat digital instructions for use as a tiresome compliance task: put a PDF on a server, print a QR code onto the nameplate, book ten years of hosting, done. That probably satisfies the letter of the Regulation - and gives away the real value of the switch.

Because the problem in the field is not that documentation exists, but whether it is accessible. In the Insight Report Service 2023 (a study by the documentation service provider kothes with the customer service associations of Germany, Austria and Switzerland), 86 percent of service technicians say they spend at least half an hour every day searching for service information - about a third at least an hour. 93 percent report that missing access to information has already led to additional service visits. And almost 40 percent still work with paper. A 400-page PDF behind a QR code changes little about that search time - it merely moves the page-flipping from the binder to the screen.

The infrastructure question, meanwhile, is settled: according to Eurostat, around 95 percent of EU households had internet access in 2025, and just over 93 percent in Germany - the argument that digital instructions will not reach the customer no longer holds. What is missing is structure: content that is addressable by machine, variant and revision status, searchable by section rather than merely findable as a file.

This is exactly where the obligation pays into service. Documentation that is structured, versioned and kept permanently online for the Regulation is the same data foundation a knowledge system in service needs - where AI demonstrably works in after-sales and what it requires, we have shown in our guide. Anyone who has to shoulder the switch anyway should do it properly once: not a PDF dump, but structured content that feeds the compliance document and searchable service knowledge alike. The Regulation supplies the budget argument that documentation projects usually lack.

7. When you are (not yet) under pressure

Honesty includes the opposite direction. Three situations in which 20 January 2027 creates no acute pressure:

  1. You will not be placing new machinery on the market for the foreseeable future. For the installed base, and for stock placed on the market in conformity with the Directive before the deadline, the Regulation changes nothing - making available and selling off remain permitted.
  2. Your documentation is already digital, structured and permanently hosted. Then the switch is at its core a process question: access marking on the machinery, a paper process in sales, ten years of secured hosting. A project, not a programme.
  3. You ship only low-cost consumer products. There, the paper requirement for essential safety information keeps a printed document in the box anyway - the efficiency gain from digitisation is correspondingly smaller.

For everyone else: the switch needs lead time, because it touches technical writing, IT and sales at once - structuring content, settling hosting and availability, marking on the machinery, a paper process in order handling. Start too close to the deadline and a plannable project turns into an emergency.

8. Frequently asked questions

Are digital instructions for use mandatory from 2027?

No. They are permitted, not required - paper remains allowed. What is new is that purely digital delivery is sufficient if the three conditions of Art. 10(7) are met: access marked on the machinery, a format that can be printed, downloaded and saved, and at least ten years of online availability.

Do I still have to supply a paper version?

Only on request - and the request must be made at the time of purchase. The paper version must then be provided free of charge within one month. For machinery that can be used by non-professional users, the essential safety information must additionally always be enclosed on paper.

Does the Machinery Regulation also apply to machinery sold before 2027?

No. Machinery placed on the market in conformity with the Machinery Directive before 20 January 2027 may continue to be made available and sold. EC type-examination certificates issued under the Directive remain valid until they expire.

Is a PDF behind a QR code enough as digital instructions for use?

By the letter of the Regulation, yes - as long as download, printing, saving and ten years of availability are guaranteed; no format is prescribed. In practice an unstructured PDF gives away the value of the switch: technicians and customers keep searching manually. Structured content, searchable by section, meets the same obligation and serves service and knowledge systems at once.

9. Sources

All legal acts and figures cited in the text, with provenance. Studies by vendors or service providers with a commercial interest are marked as such. Some sources are in German - they are the original evidence.

Digital instructions for use are that rare piece of regulation that permits something instead of prohibiting it. The price is processes: findable access, exportable formats, ten years of availability, a paper process in sales. Meet only the letter and you carry those costs and gain little. Use the same switch to structure your content and you get both: conformity for the deadline, and the data foundation that service and knowledge systems will draw on for the next ten years. The deadline is set - what comes of it is the manufacturer’s decision.