The Machinery Directive has governed how machinery is placed on the EU market since 2006. It is now replaced by a regulation, and the difference in wording is not a detail: a directive is transposed into each member state's own law, a regulation applies directly and identically across the union. Same text, same requirements, same day, in every country you sell to. Verkio has a walk-through of what the Machinery Regulation (EU) 2023/1230 changes, which machinery it covers and how to prepare.
It is the placing on the market that counts
The date 20 January 2027 is about when a machine is placed on the market or put into service — not when it was designed or ordered. A project running across that date needs to know which rules the delivery has to answer to.
What is new
- Digital documentation. The instructions may be supplied digitally, but the buyer is entitled to ask for them on paper — and they must be in the language of the country where the machine is used.
- Software and updates. An update that changes what the machine does can amount to a substantial modification, which moves the manufacturer's duties.
- Substantial modification is defined in the text of the law, not only in guidance. That makes the line clearer for whoever is rebuilding.
- The list of machinery subject to special assessment has been reworked, and the requirement for third-party involvement looks different from the directive's.
- Safety components can be software, not only hardware.
- Assemblies of machinery. Whoever puts a line together out of several machines generally becomes the manufacturer of the whole and has to CE mark it.
The CE process, in the order it is actually done
- 1
Work out what you are
Manufacturer, importer, distributor, or a user carrying out a rebuild. The role decides which duties are yours, and it can change in the middle of a project.
- 2
Assess the risks
Identify the hazards, assess the risks and deal with them in the order design, safeguarding, information. The risk assessment is what everything else rests on.
- 3
Design out what can be designed out
Safeguards and the safety-related parts of the control system are sized against the risk they are there to handle. This is where Performance Level comes in.
- 4
Compile the technical file
Drawings, calculations, risk assessment, tests and instructions. The file has to exist and has to be producible — it is what makes the CE mark more than a sticker.
- 5
Declare conformity and mark
The EU declaration is signed by the manufacturer. Only then does the CE mark go on, and only then may the machine be placed on the market.
The course is written for your industry
The steel industry
Process lines, rebuilds and new plant projects.
The mining industry
Machinery and installations in mining and minerals.
The forest industry
Machinery and process lines in sawmills and mills.
The concrete industry
Batching plants, precast lines and rebuilds.
Questions about the regulation
- Do we have to re-mark machinery we already own?
- Not because the regulation starts to apply. A machine lawfully on the market before then may continue to be used. The question arises when you modify it substantially, and then it is the modification that triggers the requirements, not the date.
- We buy a finished machine from a supplier inside the EU. What is our duty?
- As a user you have to make sure the machine is used as the manufacturer intended and is maintained. But if you connect it to other equipment to form a working whole, you can become the manufacturer of that assembly. It is the most common surprise in the regulation.
- What happens if the technical file does not exist?
- Then the basis for the CE marking is missing. The market surveillance authority can demand the file and can prohibit the machine from being placed on the market or used until it exists. In practice it is also the first thing an inspection or an insurance investigation asks for.
- Does a software update count as a modification?
- It can. If the update changes the machine's intended function or affects a safety function, it is a modification to be assessed, exactly like a mechanical rebuild.
Training in the regulation
As an online course at your own pace, and as an instructor-led half day over Teams where you can ask about your own machinery.
See the courses