# Providing the EU declaration of conformity digitally – obligations and practice

> Providing the EU declaration of conformity digitally is permitted under Article 10(8) of Regulation (EU) 2023/1230: instead of supplying it with the machinery, you state an internet address or a machine-readable code in the instructions for use. The declaration must then remain available online for the expected lifetime, and in any case for at least ten years after placing on the market or putting into service.

Source: https://manualpass.eu/en/guides/digital-eu-declaration-of-conformity/ · Updated: 04/10/2026 · ManualPass (https://manualpass.eu)

The EU declaration of conformity (EU DoC) is the declaration by which the manufacturer confirms, under its sole responsibility, that its machinery meets the applicable requirements of EU law. Until now it was usually a signed sheet in the documentation folder. From 20 January 2027, the Machinery Regulation (EU) 2023/1230 expressly allows it to be provided via an internet address or a QR code instead.

This guide explains the conditions, lists the mandatory content as a checklist and answers practical questions about signature, versions and imports. For the overall legal framework, see the page on the [Machinery Regulation](https://manualpass.eu/en/machinery-regulation/).

## Is a digital EU declaration of conformity permitted?

Yes. Article 10(8) puts digital provision on an equal footing with supplying the declaration with the product.

> "… or, alternatively, manufacturers shall include in the instructions for use 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

Important: the address or code must appear **in the instructions for use**. A QR code on the machine alone does not meet this requirement. In practice, a single code often leads to a page with both the instructions for use and the EU DoC; in addition, the address belongs in the instructions themselves. How to design such a code is shown in the guide [Instructions for use via QR code](https://manualpass.eu/en/guides/instructions-for-use-qr-code/).

Even under the Machinery Directive 2006/42/EC, the Guide in edition 2.3 (April 2024) accepts the digital EC declaration of conformity under comparable conditions.

## How long must the EU DoC be online?

!!! fakt "Legal basis"
    Digital EU declarations of conformity must remain available online for the expected lifetime, "in any case for a period of at least 10 years after the placing on the market or putting into service" (Article 10(8), second subparagraph, of Regulation (EU) 2023/1230).

Placing on the market is the first making available of a product on the Union market (see the [glossary](https://manualpass.eu/en/glossary/)). What counts is the individual unit: if a machine type is built for eight years, the declaration for the last unit delivered must still be accessible ten years after that.

Two obligations are often confused:

| Obligation | Content | Addressee | Reference |
|---|---|---|---|
| Online availability | EU DoC publicly accessible, lifetime, at least 10 years | Users | Article 10(8), second subparagraph |
| Retention | Keep technical documentation and EU DoC available for at least 10 years | Market surveillance authorities | Article 10(3) |

How to secure both periods technically, including through a website relaunch or a change of provider, is described in the guide [10 years of availability](https://manualpass.eu/en/guides/instructions-10-year-availability/).

## What mandatory content does Annex V, Part A require?

The content and form of the EU DoC are governed by Article 21 and the model in **Annex V, Part A**. The following checklist summarises the information in general terms. For the exact wording and numbering, please refer to the text of the Regulation on [EUR-Lex](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230).

- ☐ Unique identification of the machinery or related product (e.g. product, type or serial number)
- ☐ Name and address of the manufacturer and, where applicable, its authorised representative
- ☐ Statement that the declaration is issued under the sole responsibility of the manufacturer
- ☐ Description of the object of the declaration allowing traceability
- ☐ Statement that the object complies with the Machinery Regulation and, where applicable, other relevant Union harmonisation legislation
- ☐ References to the harmonised standards, common specifications or other technical specifications applied
- ☐ Where involved: notified body, conformity assessment procedure performed and certificate issued
- ☐ Place and date of issue
- ☐ Name and function of the signatory, and signature

!!! achtung "Check before publishing"
    This list is an abridged working aid. Compare your template in full with Annex V, Part A on EUR-Lex before 20 January 2027. Existing EC declarations of conformity under Annex II of the Machinery Directive cannot be adopted without review.

Two rules from Article 21 are particularly important in practice:

- **One declaration for everything:** where the machinery is subject to several EU legal acts requiring a declaration of conformity, only **one** EU DoC is drawn up (Article 21(3)).
- **Keep it updated and translated:** the declaration must be kept up to date and translated into the language(s) required by the Member State (Article 21(2)).

## Does the digital EU DoC have to be signed?

The model in Annex V, Part A provides for a signature. Digital provision does not change this: the declaration available online must also show who signed it on behalf of the manufacturer, and when and where.

Based on our review, the Regulation does not expressly specify which form of electronic signature is sufficient. This question is open to interpretation; as of October 2026, the European Commission's guide to the Machinery Regulation has not yet been published. Two approaches are common in practice:

1. Sign the original by hand, archive it and put a PDF version of it online.
2. Sign the PDF file electronically so that the signature remains verifiable.

More important than the signature technology is that the file published online cannot later be altered unnoticed. A checksum per file makes changes detectable. A checksum is a value calculated from the file content that changes whenever the file changes.

## What applies when standards change or a new version is issued?

The EU DoC must be kept up to date (Article 21(2)). A new version typically becomes necessary when the standards applied change, the machinery is modified in its design or the manufacturer's details change.

For digital provision, this means:

- ☐ Draw up and sign the new version with its own date of issue.
- ☐ Provide it under the same address or the same code.
- ☐ Archive older versions unchanged and keep them accessible.
- ☐ Record from which date or serial number each version applies.

The last point is a recommendation from practice: for a unit delivered in 2027, the declaration valid at that time is decisive, not the 2031 version. Anyone who deletes old versions can no longer prove this later.

## Which language, and which penalties?

In Germany, the EU DoC must be drawn up **in German** under Section 2 MaschinenDG (the German Machinery Regulation Implementation Act). If it is not provided in German, Section 9 MaschinenDG provides for a fine of up to €10,000. Other Member States determine their language(s) themselves; multilingual states may require several languages.

For digital declarations, it is practical to offer all language versions under one address so that users and authorities can find the right version.

## EU declaration of conformity or declaration of incorporation?

| Feature | EU declaration of conformity | EU declaration of incorporation |
|---|---|---|
| Applies to | Machinery and related products | Partly completed machinery |
| Model | Annex V, Part A | Annex V, Part B |
| Digital permitted | yes, Article 10(8) | yes, Article 11(8) |
| Where the address/code is given | Instructions for use and information under Annex III, section 1.7 | Assembly instructions |
| Online availability | Lifetime, at least 10 years | At least 10 years |
| Retention | 10 years (Article 10(3)) | 10 years (Article 11(3)) |

Partly completed machinery is an assembly that is not yet machinery in its own right and is intended to be incorporated into other machinery. Once it is incorporated, the manufacturer of the final machinery issues the EU declaration of conformity.

## Who must keep the EU DoC when importing?

- **Importers** keep a copy of the EU DoC at the disposal of the market surveillance authorities for ten years (Article 13(8)).
- **Distributors** verify the CE marking before making the product available and check whether the EU DoC is provided "in accordance with Article 10(8)" (Article 15(2)).
- Anyone who places machinery on the market **under their own name or trademark** is considered the manufacturer and issues the declaration themselves (Article 17).

If a manufacturer outside the EU provides its declaration only on its own website, the importer bears the risk of the address disappearing. More on this in the guide [Obligations for importers](https://manualpass.eu/en/guides/machinery-regulation-importer-obligations/).

## What may change in the future?

The Commission's Omnibus IV proposal (digitalisation) provides that the EU DoC would in future be provided exclusively electronically via a link or QR code without login. 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; the final details for machinery are open. Until then, Article 10(8) applies as described above.

## How to implement this with ManualPass

With ManualPass, you upload your signed EU declaration of conformity as a PDF to the machine type, in several languages if needed. It is accessible via the same permanent QR code or short link as the instructions for use, without an app or login. Every version remains archived unchanged, with a SHA-256 checksum on the scan page and a change log with a checksum chain. Discontinued machines remain publicly accessible. Learn more about [archiving](https://manualpass.eu/en/features/version-archive/) and [pricing](https://manualpass.eu/en/pricing/).

## Frequently asked questions

**May the EU declaration of conformity for machinery be provided digitally?**
Yes. Under Article 10(8) of Regulation (EU) 2023/1230, instead of supplying the declaration with the product, the manufacturer may state an internet address or a machine-readable code in the instructions for use and the information set out in Annex III, section 1.7. The rule applies from 20 January 2027.

**How long must the digital EU declaration of conformity be available online?**
For the expected lifetime of the machinery, and in any case for at least ten years after placing on the market or putting into service (Article 10(8), second subparagraph). This is distinct from the obligation to keep the declaration at the disposal of the market surveillance authorities for ten years (Article 10(3)).

**Does the digital EU declaration of conformity have to be signed?**
The model in Annex V, Part A provides for a signature with place, date, name and function. Which form of electronic signature is sufficient is not expressly regulated. A common approach is to archive the signed original and make a PDF version of it available online.

**In which language must the EU declaration of conformity be provided in Germany?**
In German. This is required by Section 2 of the German MaschinenDG; Article 21(2) of Regulation (EU) 2023/1230 requires translation into the language(s) required by the Member State concerned. In Germany, if the declaration is not provided in German, a fine of up to €10,000 may be imposed.

**What is the difference between the EU declaration of conformity and the declaration of incorporation?**
The EU declaration of conformity (Annex V, Part A) belongs to complete machinery and related products. The EU declaration of incorporation (Annex V, Part B) belongs to partly completed machinery. The declaration of incorporation may also be provided digitally and must then remain online for at least ten years (Article 11(8)).

**Who must keep the EU declaration of conformity when importing?**
Under Article 13(8), importers keep a copy of the EU declaration of conformity at the disposal of the market surveillance authorities for ten years. Before making the product available, distributors verify that the declaration is provided in accordance with Article 10(8) (Article 15(2)).

## Sources

- [Regulation (EU) 2023/1230 (EUR-Lex) – full text of Annex V, Part A](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 21 of Regulation (EU) 2023/1230 – EU declaration of conformity (gesetze.legal, German)](https://gesetze.legal/eu/vo_eu_2023_1230/21)
- [Article 13 of Regulation (EU) 2023/1230 – obligations of importers (gesetze.legal, German)](https://gesetze.legal/eu/vo_eu_2023_1230/13)
- [German Machinery Regulation Implementation Act (MaschinenDG)](https://www.gesetze-im-internet.de/maschinendg/)
- [Swissmem: instructions and declaration of conformity in digital form](https://www.swissmem.ch/de/wissen/wirtschaftsrecht/maschinenrichtlinie-2006/42/eg-betriebsanleitung-und-konformitaetserklaerung-per-sofort-in-digitaler-form-moeglich.html)

---
Note: general information, not legal advice.