The Machinery Directive Is Ending:
Are You Ready for 20 January 2027?
The countdown to a major transition has begun across Europe. The new Machinery Regulation (EU) 2023/1230 will replace Directive 2006/42/EC on 20 January 2027. From that date, the CE marking of machinery can only be carried out under the new Regulation. For machinery placed on the market after that date there is no transition period during which the two pieces of legislation can be applied side by side. Machinery placed on the market in conformity with 2006/42/EC before 20 January 2027 is not affected by the change.
| ⚠ Important: From 20 January 2027, all machinery placed on the EU market must comply with Regulation (EU) 2023/1230. After that date, declarations of conformity issued under Directive 2006/42/EC will not be valid for new products. |
Why Does This Change Matter?
The Machinery Directive 2006/42/EC has been the legal backbone of machinery safety in the EU since it became mandatory in December 2009. For 15 years it has shaped the design, assessment and certification of millions of machines. The technological environment, however, has changed fundamentally. Machines now incorporate artificial intelligence, connect to cloud networks, receive over-the-air software updates and work alongside people.
The new act is a Regulation, not a directive; it applies directly, on the same date and in the same way, in all EU and EFTA member states. This removes inconsistencies in national implementation and makes the internal market more uniform.
KEY DATES
| Date | Milestone |
|---|---|
| 2023 | Regulation published |
| January 2024 | Notified body requirements start to apply |
| 2026 | Harmonised standards |
| End of 2026 | Application guide |
| 20 January 2027 | Regulation becomes mandatory |
Figure 1: Timeline of the transition to the EU Machinery Regulation 2023/1230
What Is Changing?
About 90% of the Regulation is the same as the Directive. Manufacturers with up-to-date CE marking processes are starting from a good position. In some key areas, however, there are genuinely new obligations:
What Changes with the EU Machinery Regulation 2023/1230?
| Topic | Description |
|---|---|
| Digital safety components | Software, AI systems and connected machinery are brought into scope |
| Cybersecurity requirement | The risk assessment must cover cyber risks and the life cycle |
| Mandatory notified body | Annex I, Part A: notified body involvement is required for high-risk categories |
| Digital instructions | Instructions for use may be provided in digital format; a paper copy must be supplied free of charge if the user requests it |
Figure 2: Summary of the main changes introduced by Regulation (EU) 2023/1230
High-Risk Machinery: Scope of Mandatory Notified Body Involvement
One of the most important structural changes is the reorganisation of the list of high-risk machinery. The former Annex IV list has moved to Annex I of the Regulation and is divided into two parts:
- Annex I, Part A: Mandatory third-party assessment. Notified body involvement is required even where the relevant harmonised standards have been applied. It covers six categories: removable mechanical transmission devices and their guards, vehicle servicing lifts, portable cartridge-operated fixing machinery, and safety components and machinery with safety functions that have self-evolving (AI-based) behaviour. Categories such as woodworking machinery and presses are in Part B.
- Annex I, Part B: Reflects the former Annex IV approach. Notified body involvement is not mandatory provided the manufacturer applies in full harmonised standards covering all the relevant essential health and safety requirements.
| As a notified body accredited to ISO/IEC 17065, we have been preparing for these requirements since the Regulation entered into force in July 2023. Building on our experience as a notified body under 2006/42/EC (NB 2908), we are preparing for our notification under (EU) 2023/1230. |
Voluntary Third-Party Certification
Where a notified body is not mandatory, the manufacturer is the only party standing behind its declaration. TESTPLUS also serves this area on a voluntary basis as an independent third-party body, both for machinery outside Annex IV of 2006/42/EC and for Article 13 equipment under 2000/14/EC. An impartial assessment identifies nonconformities before the product reaches the market and gives buyers, importers and market surveillance authorities evidence they can rely on.
Voluntary certificates are issued outside our notified body scope and do not replace the manufacturer’s declaration of conformity.
Cybersecurity and Artificial Intelligence: No Longer Optional
For the first time in EU machinery legislation, cybersecurity is defined as an explicit essential health and safety requirement (EHSR). Annex III of the Regulation requires machinery designed with digital connectivity to be protected against accidental or unauthorised access that could compromise its safety functions.
Similarly, where AI-based systems perform safety-related functions, manufacturers must demonstrate that these systems behave reliably and predictably throughout the intended operating conditions. Risk assessments must now cover the entire life cycle of the software, including updates, modifications and degradation over time.
Your 6-Step Transition Action Plan
- Audit your portfolio: Identify which machines fall under Annex I, Part A (mandatory notified body) or Part B.
- Update your risk assessments: Include cybersecurity risks, AI behaviour and life-cycle updates.
- Engage your notified body early: Act before you face competition for assessment capacity in 2026.
- Review your technical file: The structure of Annex IV has been updated; make sure your technical file matches the new template.
- Plan the move to digital instructions: The Regulation allows digital operating instructions; build the infrastructure now.
- Train your teams: Make sure your engineering, compliance and after-sales teams understand the new obligations.
| We are a notified body accredited to ISO/IEC 17065 for conformity assessment under the Machinery Directive. To make sure your products are fully ready before the January 2027 deadline, contact us today about a readiness assessment for Regulation (EU) 2023/1230. |
Related Pages
- Machinery CE Certification (2006/42/EC)
- Noise Certification (2000/14/EC)
- Construction Equipment Noise Measurement
Sources and Further Reading
- Regulation (EU) 2023/1230 — OJ L 165, 29.06.2023
- Commission Implementing Decision (EU) 2026/80 of 12 January 2026 — OJ L 2026/80
- Commission Implementing Decision (EU) 2024/1256 of 30 April 2024 — OJ L 2024/1256
- single-market-economy.ec.europa.eu — Harmonised standards for the Machinery Directive
- IBF Solutions: Machinery Directive OJ update, 13.03.2026
