# Digital instructions for use under the Machinery Regulation – the guide

> Under Article 10(7) of the Machinery Regulation (EU) 2023/1230, digital instructions for use are expressly permitted from 20 January 2027, but they are not mandatory. Conditions: an indication on the machinery of how to access them, a format that can be printed, downloaded and saved, online availability for at least ten years, and a free paper copy within one month if requested at the time of purchase. For consumer products, the essential safety information must also be supplied on paper.

Source: https://manualpass.eu/en/digital-instructions-for-use/ · Updated: 04/10/2026 · ManualPass (https://manualpass.eu)

With the [Machinery Regulation (EU) 2023/1230](https://manualpass.eu/en/machinery-regulation/), digital instructions for use are regulated for the first time in the enacting terms of EU machinery law. For manufacturers, importers and distributors, this means less paper, but clear conditions. This guide explains what is permitted, which obligations apply and how to implement digital provision step by step.

## What are digital instructions for use?

Digital instructions for use are the instructions for use of a machine that are not supplied as a printed document but provided electronically – for example as a PDF via a QR code, on a website or embedded in the machine software. In terms of content, they do not differ from the paper version: they must contain the same minimum content under section 1.7.4 of Part B of Annex III and clearly describe the product model.

The instructions for use are the information that the manufacturer must supply with every machine and related product so that it can be safely assembled, put into service, used and maintained. The digital format only changes the means of provision, not the obligation to supply them.

Digital instructions for use must be distinguished from the digital product passport. The Machinery Regulation contains no obligation to provide a product passport; details can be found in the guide [Digital product passport for machinery](https://manualpass.eu/en/guides/digital-product-passport-machinery/).

## Are digital instructions for use permitted?

Yes. The Machinery Regulation applies from 20 January 2027 (Article 54, second paragraph) and expressly permits the digital format:

> “Manufacturers shall ensure that the machinery or related product is accompanied by the instructions for use and information set out in Annex III. The instructions for use may be provided in digital format.”
> — Article 10(7), first subparagraph, of Regulation (EU) 2023/1230

The key word is “may”: digital instructions for use are permitted, but not required. You may continue to supply them entirely on paper or combine both approaches.

!!! achtung "Common misconception"
    “Digital instructions for use will only be permitted from 2027.” That is not quite right. Edition 2.3 of the Commission's Guide to the Machinery Directive 2006/42/EC (April 2024, §§ 255 and 261) already accepts digital instructions and the digital EC declaration of conformity today – under conditions that correspond to those of the Machinery Regulation.

Under the amended Guide 2.3, the core conditions already apply under the Directive: an access indication, a printable and saveable format, ten years of availability, a free paper copy on request within one month, and safety information on paper for consumers ([DGUV Test](https://dguv.de/dguv-test/aktuelles/2024/2024_details_634838.jsp), [Swissmem](https://www.swissmem.ch/de/wissen/wirtschaftsrecht/maschinenrichtlinie-2006/42/eg-betriebsanleitung-und-konformitaetserklaerung-per-sofort-in-digitaler-form-moeglich.html)). If you switch now, you can therefore use your solution even before 2027. The differences between the two sets of rules are explained in the guide [Machinery Directive vs. Machinery Regulation](https://manualpass.eu/en/guides/machinery-directive-vs-machinery-regulation/).

### From when does the new rule apply to which machine?

According to the prevailing interpretation, the decisive factor is the time at which the individual unit is placed on the market. Placing on the market means the first making available of a product on the Union market. Units placed on the market for the first time from 20 January 2027 must comply with the Regulation – even if the model has been built for some time. Machinery placed on the market under the Directive before that date may continue to be sold (Article 52).

## The conditions of Article 10(7) in detail

Anyone providing the instructions for use in digital format must meet three conditions (Article 10(7), second subparagraph, points (a) to (c)). In addition, there are the paper obligations under the third and fourth subparagraphs and the language rule.

!!! fakt "Legal basis at a glance"
    Access indication on the machinery (point (a)) · format for printing, downloading and saving (point (b)) · online during the expected lifetime, at least ten years after placing on the market (point (c)) · paper free of charge within one month if requested at the time of purchase (third subparagraph) · safety information on paper for consumer products (fourth subparagraph). Source: Article 10(7) of Regulation (EU) 2023/1230.

### a) Access indication on the machinery

The manufacturer must indicate on the machinery or related product “how to access the digital instructions for use”. Only where this is not possible may the indication be placed on the packaging or in an accompanying document instead.

**Implementation:** In practice, a QR code on the rating plate or a durable label has proven effective, supplemented by a short, legible web address for users without a smartphone. The code must be affixed so that it lasts for the lifetime of the machine. What matters is that the target address remains stable – a code that leads nowhere after a website relaunch no longer meets the condition. More on this in the guide [Instructions for use via QR code](https://manualpass.eu/en/guides/instructions-for-use-qr-code/).

### b) Print, download, save

The format must allow the user to “print and download them and save them on an electronic device so that he or she can access them at any time, in particular during a breakdown of the machinery […]”. The condition expressly also applies to instructions embedded in the machine software.

**Implementation:** A PDF generally meets this requirement without additional effort. Web-only views, apps requiring a login or viewers without a download function are problematic because the user cannot save the instructions independently of the machine and the provider. Test access on an ordinary smartphone without additional software.

### c) Online availability: lifetime, at least ten years

Digital instructions for use must be accessible online “during the expected lifetime […] and for at least 10 years after the machinery or related product has been placed on the market”. The period runs separately for each unit, so with series production it is extended with every machine delivered.

**Implementation:** Plan availability independently of website relaunches, domain changes and staff changes. Instructions for discontinued models must also remain accessible. The “expected lifetime” is not defined in the Regulation; for long-lived machinery it may exceed ten years. This obligation must be distinguished from the ten-year retention of the technical documentation for authorities (Article 10(3)) – see [Instructions for use: 10 years](https://manualpass.eu/en/guides/instructions-10-year-availability/).

!!! tipp "Practical tip"
    Archive every published version unchanged with its date. This allows you to show, in a liability case or towards authorities, which version a customer could access at a given point in time.

## Paper copy on request

The digital format does not completely eliminate paper:

> “However, where the user so requests at the time of purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month.”
> — Article 10(7), third subparagraph, of Regulation (EU) 2023/1230

Three elements are specified: the request at the time of purchase, the one-month period and the absence of charges for the user. What “at the time of purchase” means in practice – for example with framework agreements or multi-stage ordering processes – and exactly when the one-month period begins remains open and subject to interpretation. Clarification is expected in the Commission's guide to the Machinery Regulation.

**Implementation:** Offer a clearly visible way to make a request, for example a form or an email address on the access page and in the purchase documents. Record the date of receipt, the deadline and the dispatch date so that you can prove timely fulfilment. The complete process is described in the guide [Paper copy of the instructions for use on request](https://manualpass.eu/en/guides/paper-instructions-on-request/).

## Exception for consumers: safety information on paper

For products intended for or reasonably foreseeably used by non-professional users, the manufacturer must provide the safety information that is essential for safely putting the product into service and using it in paper format (Article 10(7), fourth subparagraph). Simply put, a non-professional user is a person who does not use the product in the course of their professional activity.

The obligation does not cover the entire instructions for use, but the essential safety information. How far this term extends has not yet been conclusively clarified. With a mixed customer base, for example machine tools that are also bought by DIY users, you should assume consumer use as a precaution. Details in the guide [Safety information for consumers on paper](https://manualpass.eu/en/guides/consumer-safety-information-paper/).

## Language of digital instructions for use

The instructions for use, safety information and information set out in Annex III “shall be in a language which can be easily understood by users, as determined by the Member State concerned, and shall be clear, understandable and legible” (Article 10(7)). The digital format does not change this – but it makes it easier to provide several language versions behind a single access indication.

In Germany, § 2 MaschinenDG (Maschinenverordnung-Durchführungsgesetz, the German act implementing the Machinery Regulation) requires German for the instructions for use, safety information and EU declaration of conformity. In Germany, if the German version is missing, a fine of up to 10,000 € per infringement may be imposed under § 9 MaschinenDG, in addition to measures by the authorities. An EU-wide exception applies to maintenance instructions intended for specialised personnel mandated by the manufacturer: they may be drawn up in an official language of the Union understood by that personnel (section 1.7.4 of Part B of Annex III).

Other Member States determine their languages themselves; multilingual states may require several languages. Check the requirements for each target country – guidance in the guide [Instructions for use: language in the EU](https://manualpass.eu/en/guides/instructions-for-use-language/).

## EU declaration of conformity via link or code

The EU declaration of conformity is the manufacturer's declaration that the product meets the applicable requirements (Article 21, model in Part A of Annex V). It, too, no longer has to be supplied on paper:

> “[…] or alternatively the manufacturers shall indicate in the instructions and information set out in Annex III, section 1.7, the internet address or machine-readable code where that EU declaration of conformity can be accessed.”
> — Article 10(8) of Regulation (EU) 2023/1230

A digitally provided declaration of conformity must be available online for the expected lifetime and in any case for at least ten years after placing on the market or putting into service. In practice, it makes sense to bundle the instructions for use and the declaration of conformity behind the same access indication. Details in the guide [Providing the EU declaration of conformity digitally](https://manualpass.eu/en/guides/digital-eu-declaration-of-conformity/).

## Assembly instructions for partly completed machinery

Simply put, partly completed machinery is an assembly which cannot in itself perform a specific application and is intended to be incorporated into machinery. Its manufacturer must supply assembly instructions in accordance with Annex XI; these “may be provided by the manufacturer in digital format” (Article 11(7)).

The same conditions apply as for machinery: access indication, a format that can be printed, downloaded and saved, and online availability for at least ten years. If the person incorporating it requests a paper copy at the time of purchase, the assembly instructions must be provided on paper free of charge within one month. The EU declaration of incorporation (Part B of Annex V) can likewise be made accessible via an internet address or machine-readable code in the assembly instructions (Article 11(8)).

## Technical implementation options compared

The Regulation does not prescribe any particular technology. What matters is that the conditions of Article 10(7) are met on a lasting basis. Four approaches are common:

| Option | Advantages | Disadvantages |
|---|---|---|
| Own website (download area) | Full control, no additional costs if a website already exists | Links break on relaunch or domain change; versioning, paper requests and records must be organised in-house |
| PDF provision platform | Quick to set up, permanent QR codes, native download/print, often with version archive | Ongoing costs; content is not created, only provided; check vendor lock-in |
| Content delivery portal | Modular, searchable content, often linked to a component content management system | Higher implementation and maintenance effort; download and printing of the complete document must be ensured |
| Embedded in the machine software | Instructions available directly at the machine | Not accessible if the machine breaks down – therefore download and saving are additionally required; access indication and online availability remain mandatory |

For many small and medium-sized manufacturers who already produce their instructions as PDFs, a lean provision solution is sufficient. Those maintaining modular content in many variants are more likely to benefit from a content management system and portal. A more detailed comparison is offered in the guide [Content management system or provision platform](https://manualpass.eu/en/guides/ccms-vs-pdf-publishing/) and on the [comparison](https://manualpass.eu/en/comparison/) page.

## Step by step to digital instructions for use

1. **Take inventory of products:** List all machine types and partly completed machinery with their documents: instructions for use, assembly instructions, EU declaration of conformity or incorporation, safety information.
2. **Clarify the target group:** Check for each product whether non-professional users will foreseeably use it. If so, plan for the safety information on paper.
3. **Determine languages:** Identify the target countries and the languages required there; in Germany, German is mandatory.
4. **Review documents:** Make sure that each set of instructions clearly describes the product model and contains the minimum content under section 1.7.4 of Part B of Annex III.
5. **Choose the means of provision:** Use the table above to decide how the documents will remain reliably accessible for at least ten years.
6. **Affix the access indication:** Integrate the QR code and short address into the rating plate or label; only as a fallback on the packaging or accompanying document.
7. **Set up the paper process:** Define the request channel, responsible persons, deadline monitoring and proof for the paper copy within one month.
8. **Secure versions and records:** Archive every version unchanged and document changes.
9. **Test:** Scan the code with different devices, download the PDF, print it and check legibility.

A detailed checklist to tick off can be found in the [Machinery Regulation checklist](https://manualpass.eu/en/guides/machinery-regulation-checklist/).

### Quick checklist

- ☐ Access indication (QR code and short address) permanently on the machinery
- ☐ Instructions as a document that can be printed, downloaded and saved
- ☐ Availability for the lifetime, at least ten years, secured organisationally
- ☐ Paper request channel with one-month deadline and proof
- ☐ Safety information on paper for consumer products
- ☐ All required language versions, German in Germany
- ☐ EU declaration of conformity enclosed or accessible via link/code

## Common mistakes with digital instructions for use

- **QR code pointing to a changeable address:** If the code points to a page that disappears with the next website relaunch, the ten-year period is at risk.
- **Dynamic QR generators on subscription:** If the service is cancelled, printed codes may stop working.
- **Online view only, without download:** Without the option to download and save, point (b) is not met.
- **Login or app required:** Additional hurdles make access harder, especially in the event of a fault at the machine.
- **Consumer exception overlooked:** For products for non-professional users, the safety information on paper is missing.
- **Paper requests without deadline monitoring:** Requests end up in the general inbox and the one-month period expires.
- **Old versions overwritten:** It can later no longer be proven which version a customer received.
- **Confusing a permission with an obligation:** Digital instructions for use are an option, not a must.

!!! achtung "Common misconception"
    “With digital instructions, the obligation to supply them no longer applies.” The obligation remains; digital provision is merely a permissible way of fulfilling it. Under Articles 13 and 15, importers and distributors check whether the instructions and information are available in an easily understandable language – more on this under [Obligations for importers](https://manualpass.eu/en/guides/machinery-regulation-importer-obligations/).

## Outlook: Commission guide and Omnibus IV

**Guide to the Machinery Regulation:** The Commission is preparing a guide to the application of the Regulation, including a sub-group on digital instructions. As of October 2026, it has not yet been published; it has been announced for the fourth quarter of 2026, by 20 January 2027 at the latest. Open questions such as the “expected lifetime” or the “time of purchase” could be clarified there.

**Omnibus IV (digitalisation):** In May 2025, the Commission proposed a simplification package that would also amend the Machinery Regulation – with the principle of “digital by default”, a purely electronic EU declaration of conformity via link or QR code without login, and new deadlines for paper on request. The Council and Parliament reached a provisional agreement on 9 June 2026; safety information is to remain on paper where there is a risk of serious harm to consumers. This is a possible future change: as of October 2026, it has not been published in the Official Journal, and the final details for machinery are open.

Until then, Article 10(7) and (8) apply in the version described here. If you set up digital provision properly today, you are well prepared for both developments.

## How to implement this with ManualPass

ManualPass is a provision platform for existing PDF documents; instructions are not created or translated. For each machine type, you receive a permanent [QR code](https://manualpass.eu/en/features/qr-code/) with a short link that never changes – new versions appear automatically. The [scan page](https://manualpass.eu/en/features/scan-page/) works without an app or login in 26 languages; PDFs can be opened, downloaded, saved and printed.

Every version remains [archived](https://manualpass.eu/en/features/version-archive/) with a SHA-256 checksum, and the [paper copy request](https://manualpass.eu/en/features/paper-copy-request/) calculates a 30-day deadline, sends a reminder before it expires and documents the dispatch, which you handle yourself. Servers are located in Germany. You can find the plans under [Pricing](https://manualpass.eu/en/pricing/).

## Frequently asked questions

**Are digital instructions for use for machinery permitted?**
Yes. Article 10(7) of the Machinery Regulation (EU) 2023/1230 states: “The instructions for use may be provided in digital format.” Even under the Machinery Directive 2006/42/EC, edition 2.3 of the Commission's Guide (April 2024) accepts the digital format under comparable conditions.

**Will digital instructions for use be mandatory from 2027?**
No. The Machinery Regulation permits the digital format; it does not require it. Manufacturers can continue to supply the instructions for use entirely on paper or combine both approaches.

**How long must digital instructions for use be available online?**
During the expected lifetime of the machinery and for at least ten years after it has been placed on the market (Article 10(7), second subparagraph, point (c) of Regulation (EU) 2023/1230). The period applies to each unit placed on the market, so with ongoing series production it keeps moving further into the future.

**Do I still have to supply paper despite digital instructions for use?**
Yes, in two cases. If the user requests a paper copy at the time of purchase, the manufacturer must provide it free of charge within one month. For products intended for non-professional users, the essential safety information must always be supplied on paper.

**Is a QR code on the rating plate sufficient as an access indication?**
A QR code is a common way of indicating how the digital instructions for use can be accessed. It should be supplemented by a short, legible web address and must lead to the same working target address throughout the entire availability period.

**In which language must digital instructions for use be provided?**
In the language determined by the Member State concerned. In Germany, § 2 MaschinenDG requires German for the instructions for use, safety information and EU declaration of conformity. The digital format does not change these language requirements.

## Sources

- [Regulation (EU) 2023/1230 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230)
- [Article 10 of Regulation (EU) 2023/1230 – Obligations of manufacturers (gesetze.legal, German)](https://gesetze.legal/eu/vo_eu_2023_1230/10)
- [Article 11 of Regulation (EU) 2023/1230 – partly completed machinery (gesetze.legal, German)](https://gesetze.legal/eu/vo_eu_2023_1230/11)
- [German Machinery Regulation Implementation Act (MaschinenDG)](https://www.gesetze-im-internet.de/maschinendg/)
- [DGUV Test: Guide to the Machinery Directive 2.3 (German)](https://dguv.de/dguv-test/aktuelles/2024/2024_details_634838.jsp)
- [Swissmem: Instructions and declaration of conformity in digital form (German)](https://www.swissmem.ch/de/wissen/wirtschaftsrecht/maschinenrichtlinie-2006/42/eg-betriebsanleitung-und-konformitaetserklaerung-per-sofort-in-digitaler-form-moeglich.html)
- [Council of the EU: Provisional agreement on the omnibus (9 June 2026)](https://www.consilium.europa.eu/en/press/press-releases/2026/06/09/simplification-council-and-parliament-strike-deal-to-help-growing-businesses-thrive-and-accelerate-digitalisation/)

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Note: general information, not legal advice.