Checklist: documentation under the Machinery Regulation by 20 January 2027

The Machinery Regulation 2023/1230 applies from 20 January 2027. From that day on, every newly placed unit must be delivered with documents under the new law. This checklist is intended as a worksheet: print the page and tick off the points for each machine type.

Placing on the market means the first making available of an individual product on the EU market. The checklist covers the documentation, not the technical safety requirements for the machinery itself. References without further specification refer to Regulation (EU) 2023/1230.

What must be done by when?

The checklist: 15 points in 5 groups

A. Responsibility and planning

☐ 1. Clarify your role. Are you a manufacturer, importer or distributor? Anyone who places a product on the market under their own name or substantially modifies it takes on the manufacturer’s obligations. Reference: Articles 10, 13, 15, 17, 18.

☐ 2. Record machine types and cut-off date. List all machine types that will still be delivered from 20 January 2027 – including stock. Determine from which unit the new documents apply. Reference: Articles 52 and 54.

☐ 3. Determine the conformity assessment procedure. Check whether a machine type falls under Annex I, Part A (6 categories, notified body mandatory) or Part B (19 categories). For all other machinery, internal production control (Module A) applies. Reference: Article 25, Annex I.

B. Technical documentation and declarations

☐ 4. Update the technical documentation and retain it for 10 years. The documentation must be available to the market surveillance authorities for at least ten years. New: source code or programming logic upon a reasoned request. Reference: Article 10(3).

☐ 5. Draw up the EU declaration of conformity according to the new model. The EU DoC follows Annex V, Part A, is continuously updated and translated into the language of the Member State. Where several EU acts apply, a single declaration is sufficient. Reference: Article 21(2) and (3).

☐ 6. Enclose or link the EU DoC. Decide: enclose it on paper, or indicate the internet address or machine-readable code in the instructions for use. A digital EU DoC must remain online for at least ten years. Reference: Article 10(8).

☐ 7. Treat partly completed machinery separately. Provide assembly instructions under Annex XI and the EU declaration of incorporation under Annex V, Part B. Both are also possible digitally, with at least 10 years of online availability. Reference: Article 11(3), (7) and (8).

C. Instructions for use

☐ 8. Check the content. The instructions must clearly describe the product model and contain the minimum content, such as manufacturer details, designation of the machinery and residual risks. Reference: Article 10(7), Annex III, Part B, section 1.7.4.2.

☐ 9. Determine the language. In Germany, the instructions for use, safety information and EU DoC must be “drawn up in German”. For every other destination country, the language laid down there applies. Exception: maintenance instructions for the manufacturer’s specialised personnel. Reference: Article 10(7); Section 2 MaschinenDG; Annex III, section 1.7.4.

☐ 10. Affix access information (digital format only). Indicate on the machinery how the digital instructions can be accessed – for example via QR code and short link. Only where that is not possible: on the packaging or in an accompanying document. Reference: Article 10(7), second subparagraph, point (a).

☐ 11. Check the format (digital format only). Users must be able to print the instructions, download them and save them on their own device – also in the event of a machine failure. This also applies to instructions embedded in software. Reference: Article 10(7), second subparagraph, point (b).

☐ 12. Secure online availability (digital format only). The instructions must remain online during the expected lifetime and for at least ten years after placing on the market. Clarify what happens to the links in the event of a website relaunch or change of provider. Reference: Article 10(7), second subparagraph, point (c).

D. Paper and consumers

☐ 13. Set up a process for paper on request. If a user requests a paper copy at the time of the purchase, supply it free of charge within one month. Define who receives requests, monitors the deadline and documents shipping. Reference: Article 10(7), third subparagraph.

☐ 14. Identify consumer products. If a product is intended for non-professional users or can, under reasonably foreseeable conditions, be used by them, enclose the essential safety information in paper format. Reference: Article 10(7), fourth subparagraph; Section 2 MaschinenDG.

E. Marking and evidence

☐ 15. Document contact details and approvals. The machinery bears the name or trade mark, postal address and a digital means of contact. Also record which document version applies to which units and who approved it. Reference: Article 10(6); evidence recommendation without its own legal basis.

Which documents belong to which type of machinery?

How do I document approvals in a traceable way?

The Regulation does not prescribe a specific approval procedure. But in the event of a query from market surveillance or a liability case, you must be able to show which version accompanied a unit. A simple scheme has proven effective:

• Each document version is given a version number, date and responsible person.
• Old versions are not overwritten but archived.
• For each machine type, it is recorded from which serial number or delivery date a version applies.
• Fulfilled paper requests are logged with date of receipt and shipping date.

What applies to consumer machinery?

For products that can be used by non-professional users, purely digital provision is not sufficient. The essential safety information for safe putting into service and use must be provided on paper. Exactly what content this covers has not been conclusively clarified. More on this in the guide safety information for consumers on paper.

A note on developments: with the “Omnibus IV” proposal, Article 10(7) and (8) could be amended again in the future. This is a possible future amendment, not published in the Official Journal as of October 2026. This checklist follows the text currently in force.

What fines apply in Germany?

The MaschinenDG provides for fines of up to 10,000 € for documentation infringements (Section 9(2)). These include, for example, documents not retained for 10 years (Section 9(1) no. 1), instructions for use not provided in German (no. 4), safety information not provided (no. 5) and an EU DoC not provided in German (no. 6). The higher range only applies to the cases listed in Section 9(1) nos. 7, 16 and 17, such as failure to take corrective action.

How to implement this with ManualPass

ManualPass supports you with points 6 and 10 to 13 and with the evidence from point 15, as far as provision is concerned; affixing the labels as well as printing and shipping remain your task. You upload your finished PDFs and receive a fixed QR code with a print-ready label for each machine type. The scan page allows opening, downloading and printing; every version remains archived with a SHA-256 checksum. Paper requests run via a form with automatic deadline calculation and reminders; you handle printing and shipping yourself. Details under paper request and pricing.

ManualPass does not create or translate the content of the instructions – points 1 to 5, 8 and 9 remain your task. The comparison Machinery Directive vs. Machinery Regulation shows what has changed compared with the Directive.

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.