As discussed in a previous post , Regulation (EU) 2023/1230 updates the EU machinery safety framework. Its main product obligations apply from 20 January 2027. The duties of manufacturers, importers, distributors and suppliers of safety-related software depend on their role and on the product concerned.
👉 Transitional period. Directive 2006/42/EC is repealed from 20 January 2027. Article 52 allows products lawfully placed on the market under that Directive before that date to continue to be made available. The Regulation’s Chapter VI safeguard procedures apply to those products from 19 July 2023. These corrected dates replace the dates printed in the original June 2023 text.
👉 EC type-examination certificates and approval decisions issued in accordance with Article 12 of Directive 2006/42/EC shall remain valid until they expire.
👉 Annex I categories. The new conformity assessment list is divided into Parts A and B. Article 6 sets the conditions for later amendments by delegated act. Classification depends on the actual product and safety functions, not simply on whether it contains AI.
👉 Notified bodies. Annex I Part A requires modules B+C, H or G, each involving a notified body. For Part B, internal production control under module A is available only when the applicable harmonised standards or common specifications cover all relevant essential requirements. Otherwise one of the notified-body routes is required. Products outside Annex I use module A under Article 25(4).
👉 AI and cybersecurity. Annex III addresses protection against corruption and the safety of control systems, including self-evolving behaviour. Machinery safety assessment and obligations under other legislation must each be checked for the system concerned. Our earlier article discusses the legislative development of the new AI Act Regulation.
👉Definitions and Obligations. The Regulation revises and updates definitions and obligations for manufacturers, importers, distributors, and authorized representatives, aligning them with current European law.
👉Enhanced Risk Reporting. Manufacturers will have an explicit obligation to notify regulators of risks in the field, strengthening the reporting process. Distributors also have new obligations, emphasizing collective responsibility for product safety.
👉 Digital instructions. Article 10(7) permits them if access is marked, the user can download, print and save them, and online availability lasts for the expected product life and at least ten years after placing on the market. A paper copy requested at purchase must be supplied free of charge within one month. Essential safety information must still be supplied on paper for intended or reasonably foreseeable non-professional use.
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Download the original June 2023 EU Machinery Regulation here. That archived PDF should be read with the corrigendum and subsequent amendments; use the current consolidated text linked below for updated dates and provisions.
Technical references: Current consolidated Machinery Regulation, Articles 6, 10(7), 25, 51, 52 and 54, Annexes I and III, and the July 2023 corrigendum (checked 1 October 2026).
