Paper copy of the instructions for use on request – deadline, costs, process

The Machinery Regulation (EU) 2023/1230 allows instructions for use to be provided in digital format. At the same time, it requires that users receive a paper copy on request – free of charge and within one month. Many conversion projects underestimate this obligation because requests are rare and then have to be handled quickly.

This guide explains exactly what the Regulation requires, which points are still open and how to set up a process that lets you fulfil every request on time and prove it later. You will find the overall framework in the guide on digital instructions for use.

What does the Machinery Regulation say about paper format?

Digital instructions for use are an option, not an obligation. If a manufacturer chooses them, it must meet several conditions – including the paper copy on request.

“However, upon request of the user at the time of the purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month.”

The key facts at a glance:

Already under the Machinery Directive 2006/42/EC, the Guide in edition 2.3 (April 2024) accepts digital instructions under comparable conditions, including paper within one month on request.

Who may request the paper copy?

The person entitled is the user, i.e. the person or company that acquires and uses the machinery. For partly completed machinery, it is the person incorporating it who can request the assembly instructions on paper (Article 11(7)).

The user does not have to give any particular reason. So do not check whether the request is “justified”, only whether it can be assigned to a machine.

What does “at the time of the purchase” mean?

This is the greatest uncertainty. The Regulation does not define whether only a request made when the contract is concluded counts, or also one made shortly afterwards, for example on delivery or putting into service. It is also unclear how framework contracts and multi-stage ordering processes are to be treated.

In practice, a generous approach is advisable: actively offer the paper copy in the ordering process and also handle later requests. Rejecting a request saves little money but can lead to disputes with customers or queries from market surveillance.

How long is the deadline – and when does it start?

The deadline is one month. Because the start of the period is not expressly regulated, you should take the conservative approach and count from receipt of the request. Plan printing and shipping so that the document reaches the user within this month – not just so that it leaves your premises.

With shipping abroad, extensive instructions or several languages, one month can become tight. An internal buffer of seven to ten days before the deadline makes sense.

Who bears printing and shipping costs?

The manufacturer. The Regulation requires provision free of charge, without restriction. You should therefore charge neither printing, postage nor handling costs. A minimum order quantity or tying the copy to a service contract is not compatible with the wording either.

Include the costs as a flat amount in the product price. How often requests come in depends heavily on the customer group and industry; a fixed process keeps the effort per request low in any case.

Process: handling a paper request in seven steps

A fixed process prevents requests from getting stuck in one employee’s inbox. The following steps work with a form, an email inbox or a ticket system.

1. Define the request channel and make it visible

Define a clear channel, for example a form on the page the machine’s QR code points to, or a dedicated email address. Mention this channel where users find the digital instructions and in the ordering process. The guide instructions for use via QR code shows how to design the access information.

2. Record the request completely

For each request, record at least:

• name, company and postal address of the requester
• machine type or model (ideally with the serial number of the machine)
• requested language
• date and time of receipt
• reference to the purchase (e.g. order or invoice number)

3. Calculate the deadline and confirm receipt

Enter the deadline (receipt plus one month) and set a reminder before it expires. Confirm receipt to the requester in writing. The confirmation is also your first piece of evidence.

4. Determine the correct version and language

Supply the version that belongs to the user’s machine, in the requested or required language. In Germany, the instructions for use must be drawn up in German under Section 2 MaschinenDG. Note the version number so that it is clear later which version was sent.

5. Print and ship

Print the instructions completely and legibly. Choose a shipping method with tracking if receipt needs to be provable.

6. Document shipping and inform the recipient

Record the shipping date, shipping method and tracking number, and inform the requester that the copy has been sent. This completes the process.

7. Evaluate the cases

Evaluate the requests regularly: which machine types, which languages, which customer groups? If requests accumulate for one type, it may be more economical to include printed instructions with it as standard.

How do you prove fulfilment?

The Regulation does not prescribe any particular form of documentation. In the event of a dispute or a query from market surveillance, however, you must be able to prove that you delivered on time. This checklist covers the typical evidence:

• Date of receipt of the request, logged so it cannot be altered
• Confirmation of receipt to the requester
• Machine type, language and document version sent
• Shipping date and tracking number or proof of shipment
• Shipping notification to the requester
• Responsible person in the company
• Records of the cases kept in a central location

Does the obligation also apply to importers and distributors?

Article 10(7) is addressed to the manufacturer. Under Article 13(4), importers must ensure that the machinery is accompanied by the instructions for use and the information under Article 10(7). Before making the machinery available, distributors check whether these documents are provided in a language that can be easily understood by users (Article 15(2)).

Article 17 is important: anyone who places machinery on the market under their own name or trade mark is considered a manufacturer. The obligation to supply paper on request then also lies with you. Placing on the market means the first making available of a product on the Union market (see glossary).

If the manufacturer is based outside the EU, it is hardly feasible in practice to fulfil paper requests from there within one month. Agree contractually who receives and prints requests. More on this in the guide obligations for importers.

When is paper mandatory anyway?

Regardless of any request, Article 10(7), fourth subparagraph requires paper if machinery is intended for non-professional users or can, under reasonably foreseeable conditions, be used by them. In that case, the safety information essential for safe putting into service and use must be provided on paper – not necessarily the entire instructions.

Exactly which information this includes still requires interpretation. Details can be found in the guide on safety information on paper.

Common mistakes with paper requests

Other typical mistakes:

• No defined request channel; requests get lost in the sales department.
• A flat shipping fee or handling charge is billed.
• The current version is sent instead of the version that belongs to the machine.
• There is no evidence of receipt and shipping.
• The deadline is counted from the start of processing instead of from receipt.

What may change in the future?

The Commission proposal Omnibus IV (digitalisation) provides for amendments to the Machinery Regulation, including new deadlines for paper on request. The Council and Parliament reached a provisional agreement on 9 June 2026. As of October 2026, however, the amendment has not been published in the Official Journal; the final rules for machinery are still open. Until then, Article 10(7) applies in the version quoted above.

How to implement this with ManualPass

On the public scan page of each machine type, ManualPass offers a “Request paper copy” form. A deadline of 30 days from receipt is calculated automatically (in shorter calendar months such as February, the statutory one-month period may end earlier), the manufacturer and the requester receive an email, and a reminder follows seven days before the deadline. You handle printing and shipping yourself; “mark as shipped” notifies the recipient and records the case verifiably in the change log. Details on the paper request 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.