The EU Machinery Regulation (EU) 2023/1230

Last reviewed: 11 September 2026~10 min read

On 20 January 2027 the Machinery Directive stops and the Machinery Regulation starts. There is no transition period. If you place machinery on the EU market from that date, it is assessed against Regulation (EU) 2023/1230 — new essential health and safety requirements, a restructured high-risk list, and for the first time explicit obligations covering cybersecurity and machine learning in safety functions.

Applies from
20 Jan 2027

Hard cutover. No dual-compliance window.

Replaces
2006/42/EC

The Machinery Directive, in force since 2009.

High-risk categories
6

Annex I Part A — notified body mandatory.

Retention
10 years

Technical file and declaration, after placing on the market.

What it covers

The Regulation applies to machinery and to related products. That second term is new and it matters, because it replaces the old patchwork of separate categories with one defined set:

  • Interchangeable equipment
  • Safety components
  • Lifting accessories
  • Chains, ropes and webbing
  • Removable mechanical transmission devices

Partly completed machinery keeps its separate treatment: a declaration of incorporation rather than a declaration of conformity, assembly instructions rather than an operator manual, and no CE marking of its own.

The five changes that create actual work

1. It is a regulation

Directly applicable in every Member State on the same day, with no national transposing law. The practical effect: no more checking twenty-seven implementations, and no more waiting for a Member State to act. The rules are the rules, everywhere, on 20 January 2027.

2. Digital and cybersecurity requirements in Annex III

The essential health and safety requirements now address the case where a safety function can be corrupted. Control systems must be designed so that machinery cannot be put into a hazardous state by malicious or accidental interference with software or data. Evidence of the protective measures belongs in your technical file. For connected machinery, this sits alongside — and often overlaps with — the Cyber Resilience Act.

3. Machine learning in safety functions is now a named category

Two of the six Annex I Part A high-risk categories are about self-evolving behaviour using machine learning approaches that ensure safety functions. If your safety function learns, you are in mandatory notified body territory, full stop — applying harmonised standards does not get you out of it. The six categories →

4. The high-risk list was restructured

The old Annex IV of the Directive became Annex I, split into Part A and Part B. Part A is the six categories where a notified body is always required. Part B is the much longer list where self-assessment remains available provided harmonised standards are applied in full. For many manufacturers this is a net loosening — several categories that previously forced third-party involvement now do not.

5. Digital instructions are allowed

Instructions may be supplied in digital format. Two conditions bite: the manufacturer must state how to access them and provide a paper version free of charge on request, and for machinery intended for non-professional users the safety information must be supplied in paper form. Do not read "digital instructions are allowed" as "the manual is now a web page and we are done".

Substantial modification

This is the sleeper issue. The Regulation defines substantial modification: a physical or digital change to machinery after it has been placed on the market that is not foreseen or planned by the manufacturer and that affects safety by creating a new hazard or increasing an existing risk. Make one, and you become the manufacturer of the modified machinery — with the full set of duties, including a new conformity assessment and a new declaration. This catches system integrators, retrofitters and end users who upgrade a line.

What you have to produce

  1. A risk assessment, carried out iteratively, identifying the hazards, estimating and evaluating the risks, and recording the protective measures. How to do it →
  2. Technical documentation per Annex IV, demonstrating conformity with the Annex III essential health and safety requirements. What Annex IV requires →
  3. Instructions for use in the language of the Member State where the machinery is placed on the market.
  4. The EU declaration of conformity per Annex V, or a declaration of incorporation for partly completed machinery. Required content →
  5. The CE marking, affixed visibly, legibly and indelibly. Marking rules →

What to do now

Sources