Instructions for use via QR code – how to implement it correctly

A QR code on the rating plate instead of a binder in the control cabinet: the Machinery Regulation (EU) 2023/1230 explicitly makes this possible from 20 January 2027. Digital instructions for use are an option, not an obligation. But anyone who uses them must meet several conditions – and that is exactly where mistakes happen in practice.

This guide shows what is legally required, what belongs on the label, how to place the code and why the link behind the code matters more than the code itself. The guide on digital instructions for use provides the overall picture.

Is a QR code permitted as access information?

Yes. The Regulation does not prescribe a specific technical means; it requires an indication of how users can reach the digital instructions. A QR code is an obvious means for this. A QR code is a two-dimensional, machine-readable code that, in this case, usually contains a web address.

For the EU declaration of conformity, Article 10(8) expressly names the “machine-readable code” as an alternative to an accompanying declaration. More on this in the guide digital EU declaration of conformity.

Where must the QR code be affixed?

The Regulation sets an order of priority:

1. On the machinery or the related product – this is the rule.
2. On the packaging or in an accompanying document – only where affixing it to the machinery is not possible.

“Not possible” is likely to apply mainly to very small products or unsuitable surfaces. If you print the code only on the carton for aesthetic reasons, you risk the information being lost after unpacking.

Placement on the machine

• On or directly next to the rating plate: this is where service technicians and operators look first.
• Accessible without tools: not behind covers, guards or inside the control cabinet.
• Outside danger zones: nobody should have to reach into a working area to scan.
• Accessible during standstill and failure: so not only on a display that needs power.
• Protected from contamination: not directly next to sources of coolant, chips or exhaust gases.

What belongs on the rating plate or label?

In practice, the QR code alone is not enough. A good label explains what is behind the code and also works without a scanner. This checklist helps:

• QR code of sufficient size with a quiet zone
• Web address in plain text (as short as possible) as an alternative to scanning
• Short explanatory text, e.g. “Instructions for use and EU declaration of conformity”
• Machine type or model designation so that the assignment is unambiguous
• Note on the paper copy available on request
• Language note or language codes if several languages are available
• Durable material, resistant to oil, cleaning agents, UV and temperature

Independently of the QR code, Article 10(6) requires the manufacturer’s name or trade mark, postal address and a digital means of contact to be indicated on the machinery (alternatively on the packaging or accompanying documents). This information is usually on the rating plate anyway.

Why one fixed code per machine type?

The instructions for use must clearly describe the product model. For most manufacturers, it is therefore natural to assign one QR code per machine type. A fixed code means: the address in the code never changes, even when the instructions change.

This has three advantages:

• Labels can be printed in series and kept in stock.
• New versions appear under the same address, without replacing labels in the field.
• Ten-year availability depends on a single, controlled address.

What happens when the instructions change?

Instructions are corrected, supplemented and translated. Users should always find the valid version under the code. At the same time, it makes sense to archive older versions unchanged and keep them accessible.

The reason is practical: after an accident or in a dispute, the question arises which version applied at the time of delivery. If you archive every version with its date and checksum, you can prove it. A checksum is a value calculated from the file content that changes with every change to the file. More on this in the guide 10-year availability.

Dynamic QR generators: the subscription risk

Many online generators offer “dynamic” QR codes. The code then does not contain your target address but a redirect address of the generator provider. This is convenient because the target can be changed later. But it creates a dependency.

The Regulation requires online availability for the expected lifetime, but at least ten years after placing on the market. Labels on machines at customer sites can hardly be replaced afterwards. So before choosing a solution, check:

• Which domain does the code point to – your own or a third party’s?
• What happens to the redirect when the contract ends?
• Does the address remain valid after a website relaunch or domain change?
• Can the landing page be reached without advertising, login or app?

A fixed link pointing directly to a permanently operated document page is the more robust choice for machinery. If the code points to your own website, secure the address with a permanent redirect at every relaunch.

Legibility and size: keeping the code scannable

The Regulation sets no technical requirements for the code. These rules have proven effective:

Be more generous with machines that are only accessible from a distance. A code that can only be read with a ladder or a torch serves its purpose poorly.

Enabling download, printing and saving

Article 10(7), point (b) requires a format that allows users to print the instructions, download them and save them on an electronic device. This expressly also applies to instructions embedded in the machinery’s software.

In practice, this means:

• The instructions are available as a complete file, usually as a PDF.
• The landing page works without login, without an app and on a smartphone.
• Download and print functions are not blocked.
• A video-only manual or a web view without download is not sufficient.

What applies when offline?

The Regulation explicitly states the purpose of saving: users should be able to access the instructions “at all times, in particular during a failure of the machinery”. A QR code is of little help if there is no mobile network in the factory hall.

That is why an offline plan is part of the QR concept:

• In the delivery note, the commissioning record or on the landing page, point out that the instructions should be downloaded in advance.
• Recommend that operators save a copy locally or keep a printed copy at the machine.
• For consumer machinery, the essential safety information must be provided on paper anyway (Article 10(7), fourth subparagraph).

Common mistakes with QR codes for instructions for use

• The code is only on the packaging, although the machine has space for it.
• The code leads to the website’s home page instead of directly to the instructions.
• The address changes with the next website relaunch.
• The instructions can only be viewed in the browser, not downloaded.
• The label is dirty or faded after a few months.
• The instructions are not available in the language of the destination country; in Germany, Section 2 MaschinenDG requires German.

How to implement this with ManualPass

ManualPass assigns a fixed QR code with a short link to each machine type that never changes; new document versions appear automatically, without a new label. Print-ready labels are available in 60, 85 and 120 mm with up to three languages, and the code is also available as SVG for your own rating plate. The public scan page works without an app or login, detects the language automatically and allows the PDF to be opened, downloaded, saved and printed. All versions remain archived with a SHA-256 checksum. More on the QR code feature 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.