EU Machinery Regulation: questions people actually ask

No. The obligation attaches to machinery placed on the market from 20 January 2027. Machines already placed are not retrospectively caught. But everything you place from the cutover is on the new rules — including a design you have been selling unchanged for a decade.

No. The declaration must reference Regulation (EU) 2023/1230 and follow Annex V. A 2006/42/EC template with the date changed is on the documented failure list, because the references are the first thing a surveillance authority reads.

Not for new placements. The cutover is hard: comply from the date, or do not place the machine on the market.

Always for Annex I Part A, including machinery whose safety functions use self-evolving behaviour — harmonised standards do not remove that step. For Annex I Part B, only where harmonised standards do not cover all the relevant essential requirements. Outside Annex I, no. The free checker walks the three tiers.

It depends on what the AI does. The trigger is a safety function ensured by a system with fully or partially self-evolving behaviour — that falls in Annex I Part A. An AI feature that has nothing to do with a safety function is a different question. Where the line falls for your machine is an engineering and legal judgement we cannot make for you.

Yes, provided they are accessible for the product’s lifetime and a paper copy is available free of charge on request at purchase, delivered within one month (Art. 10(7)). The paper path has to exist and to be logged — ‘we would send one if asked’ is not the same as a process.

Safety-related control systems and software must be protected against corruption, accidental or malicious, and the technical file needs evidence of hardware and software integrity (Annex III, 1.1.9 and 1.2.1). It is a genuinely new requirement with no equivalent in 2006/42/EC, which is why it is where updated machines fail first.

It ships with a declaration of incorporation, not a declaration of conformity. Shipping the wrong one is on the failure list, and it is an easy mistake when the same team drafts both.

Ten years. In practice the harder requirement is the one before it: the file has to be assembled in one place and producible on a surveillance request’s deadline.

We will not put a date on someone else’s capacity. What the corpus says, and what we would act on, is that notified-body capacity is finite and the cutover is fixed — so the booking date, not the engineering, is usually what decides whether a machine makes 20 January 2027. If you need one and have not booked, that is the first call to make.

The routing logic is the same function. What the checker cannot do is take your whole range, produce the Annex IV file skeleton, the delta report against 2006/42/EC, the gap list, or an Annex V declaration drafted for each machine. That is the €590 pack.

No. This site is internal readiness documentation. It is not legal advice, it is not a conformity assessment, and it does not certify anything or replace a notified body. Verify against Regulation (EU) 2023/1230 before relying on it.