In short
Software for instructions for use solves three different tasks: an authoring system (CCMS) is used for creating and translating content, a content delivery portal for the intelligent delivery of content, and lean PDF publishing for publishing finished documents in line with the conditions of the Regulation. The Machinery Regulation does not prescribe a particular system – what matters is that the conditions of Article 10(7) of Regulation (EU) 2023/1230 are met.
Anyone searching for "instruction manual software" quickly comes across very different products. Some help with writing, some with delivering content, some only with publishing finished documents. These systems are not competitors in the strict sense, but tools for different steps.
This guide explains the three approaches neutrally, shows what the Machinery Regulation actually requires and gives you criteria for making a choice. It is aimed at small and medium-sized machine builders as well as importers and distributors.
What tasks are involved in instructions for use?
Three tasks arise around the instructions for use, and they are often mixed up:
- Creating and translating: writing content, maintaining variants, producing language versions.
- Managing and delivering: storing content in a structured way and delivering it specifically to users, service or sales.
- Providing in compliance with the law: publishing the finished instructions so that the requirements of the Machinery Regulation are met – with access information, a permanent link and a paper copy on request.
Which of these tasks you need to support with software depends on how you work today. Anyone who receives their instructions from a service provider as a finished PDF has different needs from a technical writing department with hundreds of variants.
What is an authoring system (CCMS)?
An authoring system (component content management system, CCMS for short) is software for creating, managing and translating technical documentation in reusable modules. Instead of copying entire documents, technical writers write individual building blocks, such as a safety notice or a chapter on maintenance. These building blocks are reassembled for each machine variant.
Typical strengths of a CCMS are variant management, translation management and output in several formats, for example PDF, HTML or print. Many systems support industry standards such as iiRDS or VDI 2770 for exchanging documentation data.
A CCMS is a tool for professional technical writing. Introducing one is usually a project: content has to be modularised, processes defined and staff trained. The benefit increases with the number of variants, languages and updates.
What is a content delivery portal?
A content delivery portal is software that makes technical content searchable and filtered for users, for example by product, serial number, role or language. It is often fed from an authoring system and displays content not only as PDF but as individual topics in the browser or in an app.
Portals are often aimed at service technicians, operators and dealers who need to find a specific piece of information quickly. Typical functions are full-text search, user management and links to spare-parts or service information. Here, too, introduction is usually a project involving concept design and data preparation.
What is lean PDF publishing?
Lean PDF publishing is a platform to which you upload finished documents as PDFs and make them publicly accessible via a permanent link or QR code. It does not create content or translate, but focuses on publication.
The focus is on the conditions that the law attaches to provision: permanent access, download and printing, proof of versions and handling paper requests. Introduction is usually a matter of hours rather than months, because no content needs to be restructured.
What does the Machinery Regulation actually require?
The Machinery Regulation (EU) 2023/1230 applies from 20 January 2027. It expressly permits digital instructions for use but does not prescribe any particular software system.
"The instructions for use may be provided in digital format."
Conditions for the digital format (Article 10(7) of Regulation (EU) 2023/1230)
- a) The machinery – or, where this is not possible, the packaging or an accompanying document – indicates how the digital instructions can be accessed.
- b) The format allows printing, downloading and saving on an electronic device.
- c) The instructions are accessible online during the expected lifetime, for at least ten years after placing on the market.
In addition (third subparagraph): paper format at the user's request at the time of purchase, within one month and free of charge.
None of these points requires an authoring system or a portal. Conversely, a CCMS does not automatically meet these points either: a permanent link, a traceable process for paper requests and proof of which version applied when must be organised in any case. Details on the deadline can be found in the guide Paper copy on request.
Common misconception
"We need an authoring system for the Machinery Regulation." That is not true. The Regulation governs the content, language and provision of the instructions. Which tool you use to write the instructions remains your decision.
The three approaches compared
The following table describes typical characteristics. Individual products may differ; check the details with the provider in each case.
| Criterion | Authoring system (CCMS) | Content delivery portal | Lean PDF publishing |
|---|---|---|---|
| Main purpose | Create, manage, translate content | Deliver and search content in a targeted way | Publish finished documents in line with Article 10(7) |
| Implementation effort | high (project, modularisation, training) | medium to high (concept design, data preparation) | low (upload PDF, attach QR code) |
| Typical costs | rather high, often project-based | rather high, often project-based | rather low, often as a subscription |
| Prerequisite | structured content, technical writing team | content from a CCMS or prepared data | finished PDF files |
| Variant management | core function | via filters and metadata | at machine-type level |
| Translation | often integrated or connected | delivery per language | upload of finished language versions |
| Paper request process | usually not part of the system | depends on the provider | integrated depending on the provider |
| Suitable for | large documentation teams, many variants | service organisations, large product ranges | SMEs, importers, distributors |
Which criteria should you base your decision on?
The choice depends less on feature lists than on your starting position. These criteria help you assess it:
Who creates your instructions?
If you run your own technical writing team with many variants and languages, a CCMS is an obvious tool. If, on the other hand, you receive finished instructions from a service provider or – as an importer – from the manufacturer, you primarily need a solution for provision.
How many machine types and languages do you have?
With few machine types and a manageable number of languages, the effort of modularisation is often greater than the benefit. With hundreds of variants, on the other hand, a CCMS can quickly pay off.
How do you secure ten years of online availability?
The online obligation runs for at least ten years after placing on the market – longer than many software contracts. Ask every provider whether the link stays stable, what happens when the contract ends and how, if you switch, you will continue to serve the access information on machines already delivered. More on this in the guide Instructions for use online for 10 years.
Can you prove which version applied?
In liability cases, it is crucial which version of the instructions a customer could access at a given point in time. Make sure that old versions remain archived unchanged and that changes are logged traceably, for example via checksums.
How do you handle paper requests?
The obligation to provide a free paper copy within one month is a process, not a document. Clarify where requests come in, who monitors the deadline and how you prove completion.
Where is the data hosted?
Check the server location, the data processing agreement and whether tracking takes place on the public page. For many companies in the DACH region, hosting in the EU or in Germany is a selection criterion.
Can the approaches be combined?
Yes, and in practice this is common. A typical scenario: a technical writing service provider creates the instructions with its CCMS and delivers them as a PDF. The machine builder publishes this PDF via a publishing platform and attaches the QR code to the rating plate.
Companies with their own portal also sometimes use an additional, lean solution for individual product lines or for traded goods. What matters is that for each machine it is clear which link is the legally relevant access information.
Practical tip
Separate the decision "What do we write with?" from the decision "How do we provide?". This prevents a large authoring project from delaying the timely implementation of the provision obligations by 20 January 2027.
Checklist: questions for every provider
- Does the link or QR code per machine type remain the same permanently, even with new document versions?
- Can users open, download and print the instructions without a login and without an app?
- Do old versions remain archived unchanged and accessible?
- Is there a process for paper requests with deadline monitoring and evidence?
- How are several languages provided – in Germany at least German under Section 2 MaschinenDG?
- Where are the servers located, is there a data processing agreement, are tracking cookies set?
- What happens to documents and links when the contract ends?
- Are the costs known in advance, and can you start without a long project?
How to implement this with ManualPass
ManualPass is a lean publishing platform: you upload finished instructions for use, EU declarations of conformity and assembly instructions as PDFs. For each machine type you receive a permanent QR code that does not change with new versions. Every version remains archived with a SHA-256 checksum, and paper requests are handled via a form with deadline calculation and reminder. ManualPass does not create or translate instructions – that remains the task of your technical writing team or service provider. A comparison of the solution types can be found in the comparison, and the plans under Pricing.
Frequently asked questions
Do I need an authoring system for the Machinery Regulation?
No. Regulation (EU) 2023/1230 governs the content, language and provision of the instructions for use, but not the software used to create them. An authoring system is worthwhile above all when there are many variants and languages; for provision itself, it is not a prerequisite.
What is the difference between an authoring system and a content delivery portal?
An authoring system (CCMS) is a tool for creating, managing and translating modular content. A content delivery portal is a tool for delivering this content to users, usually with search and filters by product or role. Many companies use both systems together.
Is it enough to provide finished PDFs digitally?
Legally yes, provided the conditions of Article 10(7) of Regulation (EU) 2023/1230 are met: access information on the machinery, a format that can be printed, downloaded and saved, and online availability for the expected lifetime, at least ten years. In practice, PDF meets the format requirement well.
Can I combine an authoring system with PDF publishing?
Yes. The authoring system or an external technical writing service produces the finished instructions as a PDF, and the publishing platform publishes them under a permanent link or QR code. The two tools then cover different process steps.
What should I look out for regarding hosting and data protection?
Ask about the server location, a data processing agreement and whether tracking cookies are set on the public page. It is also important what happens to your documents and links when the contract ends, because the online obligation runs for at least ten years.
Sources
This article reflects the situation as of 04/10/2026 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.