Frequently asked questions about digital instructions for use and ManualPass

Yes. Article 10(7) of Regulation (EU) 2023/1230 provides: “The instructions for use may be provided in digital format.” Even under the Machinery Directive 2006/42/EC, the guide in edition 2.3 (April 2024) accepts the digital format under comparable conditions.

No. The Machinery Regulation permits the digital format but does not require it. What is mandatory – as under the Directive – is that every machine is accompanied by instructions for use; from 20 January 2027, the manufacturer decides under Article 10(7) whether to provide them on paper or digitally.

Regulation (EU) 2023/1230 applies from 20 January 2027 (Article 54); at the same time, the Machinery Directive 2006/42/EC is repealed (Article 51). Machinery placed on the market under the Directive before this date may continue to be made available (Article 52). What matters is the time at which the individual unit is placed on the market.

Under the second subparagraph of Article 10(7) of Regulation (EU) 2023/1230, the machine (or, where that is not possible, its packaging or an accompanying document) must indicate how the instructions can be accessed. The format must allow printing, downloading and saving. The instructions must be accessible online during the expected lifetime and for at least ten years after placing on the market.

Yes. If the user requests a paper version at the moment of purchase, the manufacturer must provide it free of charge within one month (third subparagraph of Article 10(7)). What “at the moment of purchase” means in practice and when the period begins has not yet been conclusively clarified; a Commission guide is expected.

For products intended for non-professional users or which may, under reasonably foreseeable conditions, be used by them, the safety information which is essential for putting into service and using the product safely must be supplied on paper (fourth subparagraph of Article 10(7)). The rest of the instructions may be provided digitally.

Yes. Instead of enclosing the EU declaration of conformity, the manufacturer can state in the instructions for use the internet address or a machine-readable code where it can be accessed (Article 10(8)). It must then be available online for the expected lifetime and for at least ten years after placing on the market or putting into service.

In German. In Germany, under Section 2 of the MaschinenDG (German Machinery Act), the instructions for use, safety information and EU declaration of conformity must be written in German. Infringements can be fined up to €10,000 under Section 9 of the MaschinenDG.

Yes, in graduated form. Importers must ensure that the instructions for use and the information referred to in Article 10(7) are enclosed (Article 13(4)); distributors check before making the product available whether they are enclosed in an understandable language (Article 15(2)). Anyone who places a product on the market under their own name or trade mark is considered a manufacturer (Article 17).

Possibly. The Commission proposal on digitalisation (Omnibus IV) provides for amendments to Article 10(7) and (8); the Council and Parliament reached a provisional agreement on 9 June 2026. As of October 2026, the amendment has not been published in the Official Journal, so the current version continues to apply until further notice.

ManualPass is software (SaaS) for small and medium-sized machine builders as well as importers and distributors. You upload instructions for use, EU declarations of conformity, assembly instructions and safety information as PDFs and provide them digitally per machine type via a fixed QR code and short link.

In addition to the instructions for use, ManualPass provides EU declarations of conformity, EU declarations of incorporation, assembly instructions for partly completed machinery, safety information and other documents such as maintenance schedules, spare parts lists or data sheets. All documents of a machine type appear together behind the same QR code, each in the languages uploaded.

No. ManualPass provides finished documents but does not create or translate any content. You upload your instructions as PDFs – in up to 26 languages per document, depending on which language versions you have.

No. Every machine type receives a fixed QR code and short link that never changes. New document versions automatically appear on the scan page without you having to attach a new label.

No. The QR code leads to a public, mobile-optimised scan page without an app and without a login. There, the PDF can be opened, downloaded, saved and printed.

The scan page is available in 26 languages and detects the user’s language automatically. The interface and emails are also available in 26 languages, and documents can be uploaded in 26 languages.

ManualPass generates print-ready QR labels in three sizes (60, 85 and 120 mm) with up to three languages per label. You also receive the QR code as SVG if you want to integrate it into your own rating plate.

Users request the paper copy via a form on the scan page. ManualPass calculates the deadline, informs you and the requester by email and reminds you seven days before the deadline expires. You handle printing and shipping yourself; after marking the request as sent, the recipient is informed and the process is recorded in the log.

Every uploaded version remains archived unchanged and retrievable and receives a SHA-256 checksum, which is visible on the scan page. An audit log with a checksum chain makes subsequent tampering detectable.

Starter costs €129 per month (up to 10 machine types, 2 users), Professional €279 (up to 50, 5 users), Business €549 (up to 250, 15 users), each per month excl. VAT; Enterprise (unlimited) is available with price on request. The mandatory features – QR code, scan page, 26 languages, paper request, version archive and audit log – are included in every plan. Details are on the pricing page.

Prices are stated per month; billing is annual, in advance, for 12 months. The first invoice is issued at the end of the free trial or when you subscribe; there are no discounts for longer terms.

Yes. Every new account has a 14-day free trial with the plan you choose when registering. You do not need to provide payment details for the trial; you register at app.manualpass.eu/registrieren.

After 14 days, you choose a plan and a payment method in the “Account & plans” area. If you do not choose a plan, you can no longer edit anything in the account. However, your scan pages and QR codes remain accessible, so labels already attached continue to work.

You pay by credit or debit card, for example Mastercard or Visa, via the payment service provider Stripe. Alternatively, you choose to pay by invoice: you then transfer the amount with a payment term of 14 days.

ManualPass sends invoices automatically by email. In addition, all invoices are available for download as PDFs in the customer area, for example for your accounting.

No. Card payments are processed by the payment service provider Stripe. You enter the card details directly at Stripe; they are not stored at ManualPass.

Starter includes 2 users, Professional 5 and Business 15; in Enterprise, users are unlimited. Individual users cannot be added – if you need more, switch to a larger plan.

The Owner can do everything, Editors manage machines, documents and paper requests, and with the Read only role colleagues see the content without changing anything. From the Business plan, the Approver role is added for the approval workflow.

Yes, from the Business plan. With the approval workflow based on the four-eyes principle, a new document only becomes public once a second authorised person has approved it; nobody can approve their own uploads. A rejection is made with a reason and communicated by email.

Your own logo and brand colour are available from Professional, multiple brands and locations from Business. The scan page then shows the name, address, contact, logo and colour of the respective brand. The Enterprise plan includes all additional features.

Yes. You can register yourself at app.manualpass.eu/registrieren without arranging a demo appointment first, and test ManualPass free of charge for 14 days without payment details. The current terms can be found on the pricing page.

ManualPass’s servers are located in Germany. No tracking cookies are set on the public scan page. Further information can be found on the Security page and in the privacy policy.

The term is 12 months. You can cancel with 30 days’ notice to the end of the contract year; otherwise the contract automatically renews for 12 months. You cancel in the customer area under “Account & plans”; the binding provisions on term and cancellation can be found in the Terms. If you have any questions, you can reach us via the contact page.

Check the details in the Terms. ManualPass is designed so that documents remain permanently accessible, including for archived machines that are no longer built. Since the online obligation runs for at least ten years, you should check this point with any provider before concluding a contract.

No. ManualPass covers the provision of documents under the Machinery Regulation. For machinery as a product group, a product passport is not planned in the ESPR working plan 2025–2030 (as of October 2026). With the digital nameplate – an identification link per serial number based on the principle of IEC 61406 and machine-readable data – ManualPass is DPP-ready, however.