Machinery for consumers: paper is still required

In short

For machinery intended for consumers, paper remains mandatory – but not for the entire instructions for use. Under Article 10(7), fourth subparagraph, of Regulation (EU) 2023/1230, the safety information that is essential for safe putting into service and use must be supplied in paper format where the product is intended for non-professional users or where it may, under reasonably foreseeable conditions, be used by them. The rest of the instructions may be provided digitally under the conditions of Article 10(7).

The Machinery Regulation (EU) 2023/1230 expressly permits digital instructions for use. For products that may end up with private individuals, however, there is an important exception: part of the information must still be supplied in printed form. This article clarifies when the paper requirement applies, what it covers and how to proceed with a mixed customer base.

What does Article 10(7), fourth subparagraph, govern?

Article 10(7) of the Machinery Regulation has four subparagraphs. The first permits the digital format, the second sets out its conditions, the third gives users a right to paper on request. The fourth subparagraph concerns consumers.

Legal basis

For products intended for non-professional users or which may, under reasonably foreseeable conditions, be used by them, the manufacturer provides the safety information that is essential for safe putting into service and use in paper format. Reference: Article 10(7), fourth subparagraph, of Regulation (EU) 2023/1230 (paraphrased). Applies from 20 January 2027 (Article 54).

The obligation is therefore narrowly defined: not the entire instructions, but the essential safety information must be available on paper. Everything else may be provided digitally.

"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

Not entirely new

Even under the Machinery Directive 2006/42/EC, the Guide in edition 2.3 (April 2024) accepts digital instructions only if consumers receive the safety information on paper. The Regulation raises this interpretation to the status of a legal obligation.

Who is a "non-professional user"?

A non-professional user is a person who uses machinery outside their trade, business or profession. Typical examples are DIY enthusiasts, hobby gardeners or private individuals who buy a device for their own household. The Regulation also uses the term elsewhere: anyone who substantially modifies machinery as a non-professional user for their own use does not thereby become the manufacturer (Article 18).

It is important that the fourth subparagraph covers two cases:

Intended use: the product is intended for non-professional users, such as a lawnmower for a private garden.
Foreseeable use: the product is intended for professionals but is, under reasonably foreseeable conditions, also used by private individuals.

The second case is the tricky one. It does not depend on what you write in the instructions, but on how the product actually reaches the market.

How can you recognise foreseeable use by consumers?

The Regulation does not specify any criteria, and the Commission's guide to the Machinery Regulation has not yet been published. The following indicators are therefore our interpretation, not a binding rule:

Distribution channel: the product is available in DIY stores, in general online retail or on marketplaces without proof of business status.
Price and size: the product is affordable for private individuals and can be used without special infrastructure, for example with household electricity.
Advertising and presentation: brochures or shop texts also address hobby or home users.
Market observation: you know from customer enquiries or complaints that private individuals use the product.

In our assessment, a note "For commercial use only" does not on its own rule out foreseeable use by consumers if the distribution channel suggests otherwise.

What can "essential safety information" be?

The Regulation does not define which content specifically belongs to the essential safety information. The scope is open and is to be clarified in the Commission's guide, which is announced for Q4 2026, by 20 January 2027 at the latest.

Interpretation, not legal text

The following list is a practice-oriented interpretation based on the wording "safe putting into service and use". It does not replace a risk assessment for your specific product.

From the wording, it can be inferred that everything a user needs to know in order to put the product into service safely for the first time and use it safely is included. In practice, the following come into consideration in particular:

Intended use and reasonably foreseeable misuse
Warnings about residual risks that could not be eliminated by design
Safe installation, assembly and connection, for example to the mains
Required personal protective equipment
Stopping in an emergency and disconnecting from the power supply
Information on groups of persons, such as children, who must not operate the product
Safe procedure for cleaning, troubleshooting and simple maintenance by the user
Information on where the complete instructions for use can be accessed digitally and that a paper copy can be requested

According to this interpretation, spare parts lists, circuit diagrams or detailed maintenance instructions for specialised personnel, for example, do not necessarily have to be on paper.

Practical tip

Create a separate short "Safety information" document instead of shortening the instructions. Derive the content from your risk assessment and refer in the document to the complete digital instructions.

What may remain digital?

The complete instructions for use may also be provided digitally for consumer products. The conditions of Article 10(7), second subparagraph, then apply:

The product indicates how the digital instructions can be accessed – alternatively the packaging or an accompanying document.
The instructions can be printed, downloaded and saved, including in case of an outage.
They are online during the expected lifetime and for at least ten years after placing on the market.

In addition, every user retains the right to receive the instructions in paper format free of charge on request at the time of purchase – within one month (third subparagraph). How to organise these requests is described in the guide Paper copy of the instructions for use on request.

Mixed customer base: what to do?

Many manufacturers and importers sell the same model to trade businesses and to private customers. As soon as use by consumers is reasonably foreseeable, the fourth subparagraph applies to the product. The Regulation does not distinguish according to the individual buyer.

This results in three practical approaches, which we list in descending order of legal certainty:

Approach	Advantage	Risk
Supply the safety information on paper with every unit	Simple, no demarcation problem	Low printing costs
Separate variants with their own article number and their own distribution channel	Professional variant without paper possible	Distribution channels must actually remain separate
No paper, only a note "For commercial use only"	No printing	High if consumers can still purchase the product

With a mixed customer base, we recommend the first approach. An enclosed sheet or leaflet costs little and avoids the difficult question of whether a unit ends up with a consumer.

What applies to importers and distributors?

Importers must ensure that the instructions for use and information under Article 10(7) are supplied (Article 13(4)). Before making a product available, distributors check whether this information is supplied in a language that can be easily understood by users (Article 15(2)). If you source consumer products from third countries, you should therefore check the paper sheet at goods receipt.

Language and fines in Germany

Under Section 2 MaschinenDG, the safety information under Article 10(7), fourth subparagraph, must be "drawn up in German". If the safety information is not provided, this is an administrative offence under Section 9(1) no. 5 MaschinenDG. The fine is up to €10,000 (Section 9(2)). More on language questions in the guide Language of the instructions for use.

Outlook: Omnibus IV

The Commission's "Omnibus IV" proposal (2025/0134(COD)) would amend Article 10(7) and (8) again and make the digital format the norm. According to the provisional agreement between the Council and Parliament of 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 that, as of October 2026, has not been published in the Official Journal. Until then, the fourth subparagraph applies as described above.

How to implement this with ManualPass

In ManualPass, you can mark a machine type as a "Product for consumers". The public scan page then indicates that the essential safety information is supplied in paper format. You provide the complete instructions for use digitally as a PDF, accessible via a permanent QR code through the scan page in 26 languages. You continue to create and enclose the printed safety sheet yourself. You will find the plans under Pricing.

Frequently asked questions

Must the entire instructions for use be supplied on paper for consumer products?

No. Article 10(7), fourth subparagraph, of Regulation (EU) 2023/1230 requires only the safety information that is essential for safe putting into service and use to be provided in paper format. The complete instructions for use may be provided digitally, provided that access information, a format that can be printed and saved, and at least 10 years of online availability are ensured.

Who is a non-professional user?

The Regulation does not expressly define the term. According to the general understanding, it refers to persons who use machinery outside their trade, business or profession, i.e. typically private individuals. What matters is not only for whom the product is intended, but also whether use by such users is reasonably foreseeable.

What applies if I sell to both business and private customers?

If use by non-professional users is reasonably foreseeable, the paper requirement for the essential safety information applies. Since you usually cannot control where an individual unit ends up, we recommend supplying the safety information on paper with every unit when your customer base is mixed. This is an interpretation, not an express rule of the Regulation.

In which language must the safety information be supplied?

In the language determined by the Member State concerned. In Germany, the safety information under Article 10(7), fourth subparagraph, must be drawn up in German (Section 2 MaschinenDG). If it is not provided, a fine of up to €10,000 may be imposed in Germany under Section 9 MaschinenDG.

Will Omnibus IV change the paper requirement for consumers?

Possibly in some details. According to the provisional agreement between the Council and Parliament of 9 June 2026, safety information is to remain on paper where there is a risk of serious harm to consumers. As of October 2026, this possible future change has not been published in the Official Journal; the current Article 10(7), fourth subparagraph, is decisive.

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.