For importers and distributors: Machinery Regulation documentation under control

An importer is anyone who places machinery from a third country on the EU market for the first time. A distributor is anyone in the supply chain who resells machinery without being the manufacturer or importer. For both, the Machinery Regulation (EU) 2023/1230 puts a sharper focus on documentation from 20 January 2027.

Your obligations in brief

• Importers (Article 13): You check the technical documentation, CE marking and enclosed documents. You ensure that the instructions for use and the information referred to in Article 10(7) are enclosed, indicate your own contact details and keep the EU declaration of conformity available for ten years.
• Distributors (Article 15): Before selling, you check the CE marking, the EU declaration of conformity and whether the instructions for use are enclosed in a language easily understood by users.
• Own brand (Article 17): If you place machinery on the market under your name or trade mark, you are considered the manufacturer – with all obligations under Article 10.

In Germany, the instructions for use, safety information and EU declaration of conformity must be available in German under Section 2 of the MaschinenDG. The guide Obligations for importers and distributors explains this in detail.

The typical situation with imported goods

The machine comes from a third country, with the instructions in English or in the manufacturer’s language. A German version is supplied later, revised, corrected again. The EU declaration of conformity is a scan in an email. With several suppliers and many models, it is easy to lose track of which version belongs to which delivery.

How to provide the documents with ManualPass

1. Create a model: For each model you receive a fixed QR code and short link.
2. Upload checked documents: German instructions for use, EU declaration of conformity and – if available – further language versions as PDFs.
3. Attach the label: Stick the label on the machine at goods receipt – only if that is not possible, on the packaging or an accompanying document – or send the QR code as SVG to the manufacturer for the rating plate.
4. Update instead of relabelling: When a corrected version arrives, upload it. The QR code stays the same, and the old version remains archived.

You receive paper requests via the paper request feature with deadline calculation and reminders.

Many suppliers, many models, own brand

ManualPass does not check content and does not translate. Whether the supplier’s documents are complete and correct remains your task to check as the importer.

Read more about logo, brands and locations under Branding and brands, and about roles and approval under Team and approval.

Which plan suits you?

Up to 10 models and 2 users: Starter for €129 per month. Up to 50 models and 5 users, with your own logo: Professional for €279 per month. Up to 250 models and 15 users, with multiple brands and approval workflow: Business for €549 per month. For unlimited ranges and users, with a dedicated contact person and an individual contract, there is Enterprise – price on request.

All prices are excl. VAT; the term is 12 months, billed annually in advance. The mandatory features are included in every plan. Details under Pricing. You create an account yourself, without a demo appointment, and test ManualPass free of charge for 14 days without payment details.