10-year availability: securing instructions for use and EU DoC long term

“Ten years” appears in several places in the Machinery Regulation (EU) 2023/1230. But it refers to two different obligations with different addressees. Anyone who mixes them up may archive everything neatly for the authorities – while the QR code on the machine leads nowhere. This guide separates the two obligations and shows how to secure your digital instructions for use over the long term.

Retention or online availability – what is the difference?

The retention obligation concerns documents you keep available for the market surveillance authorities. Online availability concerns documents your customers must be able to access at any time.

The technical documentation is the internal documentation with which the manufacturer demonstrates the conformity of its machinery, such as the risk assessment, drawings and test reports. Under Article 10(3) you keep it available for the authorities for at least ten years. What is new is that, upon a reasoned request, authorities may also ask for source code or programming logic, insofar as this is necessary for checking conformity.

Importers are affected too: under Article 13(8) they keep the EU declaration of conformity available for ten years. For partly completed machinery, Article 11 lays down an online obligation of at least ten years for the assembly instructions, there without the reference to lifetime.

When do the 10 years start?

The online period starts with placing on the market. Placing on the market means the first making available of a product on the Union market – of each individual unit, not of the model.

According to the common interpretation, this means: what counts is the last unit delivered of a machine type.

• You sell a machine type from 2027 to 2035.
• The last unit is placed on the market in December 2035.
• The instructions must then be accessible online until at least December 2045 – longer if the expected lifetime goes beyond that.

For the digital EU declaration of conformity, Article 10(8) names putting into service as a reference point in addition to placing on the market. As a precaution, plan with the later of the two dates.

What does “expected lifetime” mean?

The Regulation does not define the term. It is an open point that requires interpretation; the European Commission’s guidance on it is still pending.

In practice, many machines run for 20 years or longer. For them, ten years of online availability is not enough. Determine the expected lifetime for each machine type, for example based on design data, experience or spare parts availability, and document your reasoning.

Do old versions have to remain accessible?

The Regulation says nothing explicit about this. It does, however, require that users can access the instructions at all times, in particular during a failure of the machinery (Article 10(7), point (b)). This means the instructions that belong to their machine.

If the instructions change, for example after a design change, the new version will not necessarily match older units. There are therefore good reasons to keep every delivered version accessible for the entire period. Clearly indicate which years of manufacture or variants a version applies to.

What risks threaten availability over 10 years?

Ten to twenty years is a long time in IT. Websites, providers and company structures will almost certainly change during that period. The QR code on the rating plate, on the other hand, never changes.

Website relaunch

A relaunch often changes paths and file names. A QR code that points to “/downloads/manual_v3.pdf” then leads to an error page. All machines that have already been delivered are affected.

Domain change

A change of company name, a merger or a new brand often results in a new domain. If the old domain is not permanently redirected or if it expires, all printed links become worthless.

Change of provider

Dynamic QR code generators redirect via the provider’s servers. If you cancel the contract or the provider discontinues the service, the codes stop working. The same applies to document portals whose links are tied to the provider.

Insolvency or closure of the business

The Regulation does not explicitly address what happens to online availability if the manufacturer becomes insolvent. For importers and distributors, this is a reason to keep their own copies of the instructions. For manufacturers, it pays to organise the provision so that it does not depend on a single person or a single server.

How do you secure the 10 years technically?

The following measures complement each other. None of them alone covers all risks.

Stable URL

The access information on the machine should point to an address that never changes – regardless of the structure of your website. A common approach is one short link per machine type that internally points to the current version. More on this in the guide instructions for use via QR code.

Version archive

Every version delivered with a machine should be preserved unchanged. Customers with older machines need the version that matches their unit. At the same time, in the event of a dispute, you can prove which instructions applied at which point in time.

Checksums

A checksum (for example SHA-256) is a digital fingerprint of a file. Even a tiny change to the document results in a completely different checksum. If you record the checksum at the time of publication, you can prove years later that the file is unchanged.

Exports and backups

Additionally keep all published PDF files in your own archive, independent of the provision service. Create an overview: machine type, version, period of validity, checksum, link. This lets you republish everything when changing provider without having to search for documents.

Checklist: 10-year availability

• Expected lifetime determined and justified for each machine type
• Date of the last placing on the market recorded per type, end date of the online obligation calculated
• Access information points to a stable address, not to a file path
• All delivered versions archived and accessible
• Checksum documented for each file
• Own backup of all PDF files in place
• Relaunch and domain change process includes a link check of all QR codes
• Technical documentation and EU declaration of conformity archived for the authorities for at least ten years

What are the consequences of infringements?

In Germany, the Machinery Regulation Implementation Act (MaschinenDG) governs the penalties. If documents are not retained, or not retained for ten years, a fine of up to 10,000 € is possible under Section 9(1) no. 1 and (2) MaschinenDG. In addition, authorities can order measures up to and including a recall.

Possible changes through Omnibus IV

The Omnibus IV (digitalisation) package could bring a possible future amendment 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 and the details for machinery are open. Plan according to the law currently in force.

How to implement this with ManualPass

With ManualPass, you upload instructions for use and EU declarations of conformity as PDFs and provide them per machine type under a fixed QR code and short link that never changes. Every version remains archived unchanged and accessible, with a SHA-256 checksum per file that is visible on the scan page. A change log with a checksum chain makes subsequent tampering detectable.

You can archive discontinued machine types; they remain publicly accessible. The servers are located in Germany. Details can be found under archiving and versioning and pricing.

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.