In short
There are four typical approaches to digital instructions for use: component content management systems (CCMS) for authoring, content delivery portals for delivery, QR code generators for linking and lean provision platforms such as ManualPass for publishing finished PDFs in line with the conditions of Article 10(7). Which approach fits depends on whether you create content yourself, how many variants you have and how you want to organise the obligations under Article 10(7) of Regulation (EU) 2023/1230.
If you want to provide your instructions for use digitally, you will find very different kinds of software. This comparison does not compare individual providers, but solution types. Within each type, products sometimes differ considerably; so check the details in each individual case.
The basis is the Machinery Regulation (EU) 2023/1230. It permits digital instructions for use if there is an indication of access on the machine, the format allows printing, downloading and saving, and the instructions remain online for at least ten years. On request at the moment of purchase, they must be provided in paper format free of charge within one month (Article 10(7)). The Regulation does not prescribe any particular system.
The solution types briefly explained
- Component content management system (CCMS): Software for creating, managing and translating modular documentation, typical for technical writing departments with many variants.
- Content delivery portal: Software for delivering technical content in a searchable, filtered way, often fed from a CCMS.
- QR code generator (dynamic): A service that generates a QR code with a changeable redirect to any target address.
- Lean provision platform (e.g. ManualPass): Software for publishing finished PDF documents per machine type with a fixed QR code, version archive and paper request process.
A more detailed classification can be found in the guide CCMS or provision platform.
Comparison table
| Criterion | Component content management system (CCMS) | Content delivery portal | QR code generator | ManualPass |
|---|---|---|---|---|
| Purpose | Create, manage, translate content | Deliver and search content in a targeted way | Redirect a QR code to a target address | Provide finished PDFs per machine type in line with Article 10(7) |
| Implementation effort | high: project, modularisation, training | medium to high: concept, data preparation | low | low: upload PDF, print label |
| Typical costs | rather high, often project-based | rather high, often project-based | low, mostly subscription | low to medium, subscription with fixed prices |
| Paper request workflow | usually not part of the system | depends on the provider | usually not available | Form, deadline calculation, reminder, proof in the audit log |
| Versioning and proof | Versioning of content in the authoring process | depends on the provider | no document versions, only target address | every version archived, SHA-256 checksum, audit log with a checksum chain |
| Fixed URL over 10 years | concerns the output, not the CCMS itself | depends on the provider and contract | depends on the subscription continuing | fixed QR code per machine type that never changes; archived machines remain accessible; designed for permanent accessibility; contract details in the Terms |
| Multilingualism | translation management often integrated | delivery per language | depends on the target page | scan page in 26 languages, upload of finished language versions |
| Suitable for | large technical writing teams, many variants and languages | service organisations, large product ranges | simple linking without further requirements | small and medium-sized machine builders, importers, distributors |
The types are not mutually exclusive. Often a CCMS or a service provider creates the instructions as a PDF, and a provision platform publishes them. What matters is that for each machine it is clear which link is the authoritative indication of access.
Common misconception
“A QR code on the rating plate is enough.” The QR code is only the indication of access. Behind it there must be a document that can be saved and printed, availability for at least ten years and a process for paper requests.
When ManualPass fits
ManualPass is a good fit if these points apply to you:
- Your instructions for use, EU declarations of conformity and assembly instructions already exist as finished PDF files, created in-house, by a service provider or – as an importer – by the manufacturer.
- You have a manageable to medium number of machine types and want a fixed QR code per type that stays the same for new versions.
- You want to handle paper requests under Article 10(7) with deadline calculation, reminders and proof instead of managing them via an email inbox.
- It is important to you to be able to prove later which document version was provided at which time.
- You want to publish new documents only after review by a second person or manage multiple brands and locations with their own manufacturer details; both are available from the Business plan.
- You want to start without an implementation project and without a demo appointment, test ManualPass free of charge for 14 days without payment details and know the costs in advance; the plans run for 12 months with annual billing and are listed under Pricing.
- You value hosting in Germany and a scan page without tracking cookies.
How the individual features work is shown on the pages QR code, Scan page, Paper request, Archiving, Team and approval and Branding and brands.
When ManualPass does not fit
ManualPass is deliberately limited to providing finished documents. In these cases, a different solution is better suited or additionally needed:
- You first have to create or translate instructions. ManualPass has no authoring or translation function. For that you need a CCMS, a word processing tool or a service provider.
- You need documents per individual unit. ManualPass works with one QR code per machine type, not with individual codes per serial number.
- You want to deliver content topic by topic in the browser. ManualPass provides PDF files; full-text search across modular content, as offered by content delivery portals, is not included.
- You need a connection to ERP, PIM or other systems. ManualPass does not offer such an interface.
- You need a Digital Product Passport or battery passport. ManualPass does not offer these functions; with the digital nameplate per serial number, however, ManualPass is DPP-ready. For machinery as a product group, a product passport is not planned in the ESPR working plan 2025–2030; a battery passport may be relevant for certain built-in batteries from 18 February 2027; more on this in the guide Digital Product Passport for machinery.
- You want to outsource paper dispatch completely. ManualPass organises deadlines and proof; you handle printing and shipping yourself.
- Your purchasing department requires specific certifications from the provider. ManualPass does not currently hold any information security certification. In this case, clarify your requirements in advance via Contact.
If one of these points is decisive for you, a combination may make sense, for example a CCMS for authoring and ManualPass for provision, or another type of solution may fit better.
Frequently asked questions
Is ManualPass an alternative to a component content management system?
Only partly. A CCMS is used to create and translate instructions, ManualPass to provide finished PDFs. If you already use a CCMS or commission a service provider, you can use ManualPass in addition for publication.
Is a dynamic QR code generator sufficient for the Machinery Regulation?
A QR code generator only meets part of the requirements, namely the indication of access. What usually remains open is the process for paper requests, version archiving and the question of whether the link will work for at least ten years, even if the subscription ends.
Can I simply provide the instructions on my own website?
Yes, that is legally possible if the conditions of Article 10(7) of Regulation (EU) 2023/1230 are met. In practice, you must then ensure yourself that links remain stable through website relaunches, old versions are preserved and paper requests are handled on time.
What does a solution for digital instructions for use cost?
That depends on the type of solution. Component content management systems and content delivery portals are often offered on a project basis, QR generators and lean platforms mostly as a subscription. ManualPass costs from €129 per month excl. VAT for up to 10 machine types and 2 users.
Sources
This article reflects the situation as of 05/10/2026 and does not constitute legal advice. The authoritative text is Regulation (EU) 2023/1230 as published in the Official Journal of the EU, together with the national implementing provisions.