Artifact GuideEU

EU Machinery Regulation Conformity Assessment and CE

From 20 January 2027, Regulation (EU) 2023/1230 ties CE marking to completed conformity assessment, technical documentation, and an EU declaration of conformity.

Before that date, Directive 2006/42/EC remains the main release framework. The product category, release date, and transitional status determine which route to use.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Sections
4

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated Jul 25, 2026
Overview

For machinery and related products governed by Regulation (EU) 2023/1230 from 20 January 2027, the manufacturer prepares technical documentation, applies the Article 25 route, draws up the EU declaration of conformity after demonstrating compliance, and then affixes CE marking. Products placed on the market in conformity with Directive 2006/42/EC before that date fall under the Article 52 transition rule.

Section 1

Choose the route from the machinery category

Article 25 starts with the category of machinery or related product. If the product is not listed in Annex I, the default route is internal production control, module A, in Annex VI.

Annex I Part A is different: the manufacturer must use one of the notified-body routes listed in Article 25(2). Those routes are EU type-examination followed by conformity to type, full quality assurance, or unit verification.

Annex I Part B sits between those positions. Internal production control is available only when the product is designed and constructed according to harmonised standards or common specifications that are specific to that category and cover all relevant essential health and safety requirements. If that condition is not met, the manufacturer must use one of the notified-body routes in Article 25(3).

The manufacturer makes and records this route decision. An importer must verify before placement that the manufacturer completed the appropriate assessment, prepared Annex IV Part A documentation, affixed CE marking, and supplied the required documents. A distributor must act with due care and check the marking, documents, identification, and operator details before making the product available. These supply-chain checks do not transfer the manufacturer's design and assessment responsibility unless Article 17 or Article 18 applies.

  • Annex I Part A includes removable mechanical transmission devices and guards, vehicle servicing lifts, portable cartridge-operated fixing and impact machinery, and machine-learning safety components or embedded safety systems in the listed cases.
  • Annex I Part B covers named higher-risk product categories such as specified woodworking saws and other listed machinery; use the exact Annex I wording before selecting the route.
  • A person carrying out a substantial modification can enter the manufacturer's role and trigger the Article 25 route for the affected machinery or related product. Article 18 excludes a non-professional user who substantially modifies machinery solely for personal use from the Regulation's manufacturer obligations.
Section 2

Build the technical documentation before marking

The technical documentation in Annex IV Part A has to explain how the manufacturer ensured conformity with the applicable essential health and safety requirements in Annex III. It is not just a certificate folder.

For machinery and related products, the record should identify the product and intended use, contain the risk assessment, list applicable essential health and safety requirements, describe protective measures and residual risks, include drawings and explanations, identify harmonised standards or common specifications used, and keep test, inspection, and examination results.

Where relevant, Annex IV also calls for instructions for use, declarations or assembly instructions for incorporated partly completed machinery, declarations for other Union harmonisation legislation, production controls for series manufacture, and safety-related software source code or programming logic when a competent authority makes a reasoned request.

  • Keep the technical documentation and EU declaration of conformity available to market surveillance authorities for at least 10 years after placing on the market or putting into service.
  • For partly completed machinery, use Annex IV Part B technical documentation and the EU declaration of incorporation rather than a CE marking file.
  • Keep the documentation aligned to the product version, safety-related software version, incorporated products, and applied standards.
Section 3

Draw up the declaration and affix CE marking

After the relevant has demonstrated compliance with Annex III, Article 10 requires the manufacturer to draw up the EU declaration of conformity and affix CE marking. The CE marking must be visible, legible, indelible, and affixed before the machinery or related product is placed on the market or put into service.

The declaration should follow Annex V Part A. It identifies the machinery or related product, manufacturer, object of the declaration, applicable Union harmonisation legislation, applied harmonised standards or common specifications, and the notified-body route where one was used.

For the Article 25(2) and Article 25(3) notified-body procedures listed in Article 24(3), the CE marking is followed by the identification number of the notified body involved in the procedure. Partly completed machinery follows a different document set: an EU declaration of incorporation and assembly instructions, not CE marking as a complete machine.

  • Provide the EU declaration of conformity with the machinery or provide an internet address or machine-readable code in the instructions where it can be accessed.
  • Keep digital EU declarations of conformity accessible online for the expected lifetime of the machinery or related product and at least 10 years after placing on the market or putting into service.
  • Make instructions for use and safety information available with the machinery or related product; where digital instructions are used, check the paper-safety-information rule for non-professional use.
Section 4

Transition from Directive 2006/42/EC

Regulation (EU) 2023/1230 generally applies from 20 January 2027, when Directive 2006/42/EC is repealed. Article 52 prevents Member States from impeding the making available of products placed on the market in conformity with the Directive before that date. Some institutional and delegated provisions apply earlier under Article 54, but that does not move the general product-compliance date forward.

For a product first placed on the market or put into service from 20 January 2027, do not treat a Directive technical file as automatically sufficient. Remap Directive references, check Annex I Part A or Part B status, update technical documentation to Annex IV Part A, update the declaration to Annex V Part A, and apply the Regulation's conditions for digital instructions and declarations.

  • Use Directive 2006/42/EC for products placed on the market before 20 January 2027 and the Regulation route for products placed on the market or put into service from that date.
  • Check if safety components or embedded systems with self-evolving machine-learning behaviour fall into Annex I Part A.
  • Update declaration and instruction delivery records where the team moves from paper-only packs to digital access.
Recommended next step

Check the conformity route before CE marking

Review the product category, Annex I status, technical documentation, declaration content, instruction delivery, and notified-body route before release.

Primary sources

References and citations

eur-lex.europa.eu
Referenced sections
  • Articles 51, 52, and 54 establish repeal, transitional treatment, and the corrected 20 January 2027 general application date; the correlation table and annexes support the Regulation-era document mapping.
"References to the repealed Directive 2006/42/EC shall be construed"
Related guides

Explore more topics

Declaration of Conformity vs Declaration of Incorporation | Machinery Regulation FAQ
FAQ on when machinery needs an EU Declaration of Conformity and when partly completed machinery needs an EU Declaration of Incorporation under Regulation (EU) 2023/1230.
Directive 2006/42/EC to Machinery Regulation transition
Transition guide for moving EU machinery files from Directive 2006/42/EC to Regulation (EU) 2023/1230, focused on the 20 January 2027 changeover, pipeline products, declarations, standards, technical documentation, software, cybersecurity, and digital instructions.
EU Machinery Regulation Applicability Test
Test whether a product is machinery, a related product, partly completed machinery, a safety component, substantially modified, excluded, or covered by overlapping EU product laws.
EU Machinery Regulation compliance
Machinery Regulation compliance checklist covering scope, EHSR risk assessment, technical documentation, instructions, conformity assessment, EU declarations, CE marking, software, transition, and market surveillance.
EU Machinery Regulation compliance checklist
Checklist for Regulation (EU) 2023/1230 covering scope, EHSR risk assessment, technical documentation, instructions, conformity assessment, EU declarations, CE marking, digital duties, transition, and market surveillance.
EU Machinery Regulation deadlines and compliance calendar
Calendar for Regulation (EU) 2023/1230 dates, Directive 2006/42/EC transition, release documentation gates, standards monitoring, and substantial-modification reviews.
EU Machinery Regulation FAQ
Answers to Machinery Regulation questions on scope, partly completed machinery, Annex I categories, Article 25 conformity assessment, digital instructions, software, cybersecurity, transition, CE files, and overlap with other EU product laws.
EU Machinery Regulation Partly Completed Machinery
What counts as partly completed machinery under Regulation (EU) 2023/1230, what documents travel with it, and where the final assembler takes over.
EU Machinery Regulation requirements
Requirements under Regulation (EU) 2023/1230: machinery scope, EHSR risk assessment, technical documentation, instructions, conformity assessment, EU declaration, CE marking, software evidence, transition, and surveillance.
EU Machinery Regulation Safety Components
Definition, scope, conformity assessment, technical documentation, declaration, CE marking, and cited examples for safety components under Regulation (EU) 2023/1230.
EU Machinery Regulation scope and machine categories
Scope guide for Regulation (EU) 2023/1230 covering machinery, related products, partly completed machinery, Annex I categories, exclusions, substantial modification, and category evidence.
EU Machinery Regulation substantial modification decision workflow
Workflow for assessing substantial modification under Regulation (EU) 2023/1230: change facts, hazard and risk impact, manufacturer obligations, conformity assessment, CE marking, and evidence.
EU Machinery Regulation vs LVD
Compare the EU Machinery Regulation and Low Voltage Directive boundary for machinery EHSRs, electrical risks, excluded electrical products, CE documentation, and evidence reuse.
EU Machinery Regulation vs Market Surveillance Regulation: compliance comparison
Compare Machinery Regulation product compliance duties with EU MSR market surveillance duties, authority requests, online sales, corrective action and evidence records.
EU Machinery Regulation: autonomous mobile and collaborative machinery
Official source guide to Regulation (EU) 2023/1230 requirements for autonomous mobile machinery, human-machine interaction, controls, software, cybersecurity, risk assessment, technical documentation, and conformity routes.
EU Machinery Regulation: when does a modification constitute substantial modification?
Guide to substantial modification under Regulation (EU) 2023/1230: change triggers, risk assessment, EHSRs, technical documentation, conformity assessment, CE marking, and records.
EU Machinery Risk Assessment Method
How to document an EU Machinery Regulation risk assessment: ISO 12100 hazard identification, EHSR mapping, risk reduction, residual risk, software, cybersecurity, and technical-file evidence.
How to map Annex III EHSRs under the EU Machinery Regulation | Machinery Regulation FAQ
FAQ on mapping Annex III essential health and safety requirements to hazards, risk reduction, software controls, technical documentation, and Annex I classification under Regulation (EU) 2023/1230.
Machinery CE documentation template for Regulation (EU) 2023/1230
Template fields for Machinery Regulation CE documentation: product identity, scope, EHSR risk assessment, standards, tests, instructions, EU declaration, CE marking, notified body route, software, cyber, and substantial modification checks.
Machinery Regulation and EU AI Act overlap for AI-enabled safety functions
FAQ on Machinery Regulation overlap with the EU AI Act for self-evolving or machine-learning safety functions, Annex I categories, standards work, and technical documentation boundaries.
Machinery Regulation Annex I conformity route workflow
Classify machinery against Annex I Part A and Part B, choose the Article 25 conformity assessment route, and assemble the technical evidence file.
Machinery Regulation Annex I high-risk categories
Explain what Annex I does under Regulation (EU) 2023/1230, which listed machinery categories trigger special conformity routes, and what evidence to keep.
Machinery Regulation category and scope checks
Check whether a product is machinery, a related product, partly completed machinery, a safety component, excluded from scope, or listed in Annex I under Regulation (EU) 2023/1230.
Machinery Regulation cybersecurity evidence FAQ
What cybersecurity evidence connected or software-enabled machinery should keep for protection against corruption, safety-related control systems, and machinery risk assessment.
Machinery Regulation digital instructions
EU Machinery Regulation guide to digital instructions for use: access marking, print and download access, paper copies, non-professional safety information, languages, and records.
Machinery Regulation penalties and enforcement
EU Machinery Regulation enforcement guide covering Member State penalty rules, corrective action, market surveillance powers, and cross-border authority cooperation.
Machinery Regulation related products scope guide
Classify EU Machinery Regulation related products, including interchangeable equipment, safety components, lifting accessories, lifting chains, ropes, webbing, and removable transmission devices.
Machinery Regulation software and cybersecurity considerations
How Regulation (EU) 2023/1230 treats safety-related software, control systems, corruption protection, technical documentation, and cyber-safety risk evidence.
Machinery Regulation Technical Documentation and Technical File
What to keep in the EU Machinery Regulation technical file: product identification, risk assessment, EHSR mapping, standards, tests, instructions, declarations, software evidence, retention, and notified-body records.
Machinery Regulation technical file acceptance workflow
Release-gate workflow for accepting an EU Machinery Regulation technical file: scope, EHSR risk evidence, standards, tests, declarations, notified-body records, software, cyber, and signoff.
Machinery Regulation Timeline and Transition: practical guide
EU Machinery Regulation timeline covering corrected application dates, the Directive 2006/42/EC changeover, certificate continuity, product placement decisions, and transition evidence.
Machinery Regulation vs EMC Directive
Compare EU machinery safety duties with EMC duties for equipment, CE documentation, harmonised standards, declarations, and combined technical files.
Machinery Regulation vs EU AI Act: machinery safety overlap
A cited-source comparison of the EU Machinery Regulation and EU AI Act for machinery with AI-enabled safety functions, software, cyber-safety and technical documentation overlap.
Machinery Regulation vs Machinery Directive
Official source comparison of Regulation (EU) 2023/1230 and Directive 2006/42/EC across legal form, timing, scope, digital instructions, cybersecurity, conformity assessment, documentation, and CE marking.
Machinery vs RED comparison
Compare EU Machinery Regulation and Radio Equipment Directive boundaries for machinery safety, radio equipment scope, CE documentation, and shared evidence.
What counts as machinery under Regulation (EU) 2023/1230?
FAQ on the Machinery Regulation definition of machinery, including assemblies, drive systems, missing components, software, related products, partly completed machinery, safety components, and exclusions.
When can a software update affect Machinery Regulation compliance?
FAQ on when machinery software updates can trigger Machinery Regulation review, including safety functions, substantial modification, corruption protection, instructions, and CE technical-file evidence.
When does used or modified machinery need a new conformity assessment? | Machinery Regulation FAQ
FAQ on used and modified machinery under Regulation (EU) 2023/1230, including substantial modification, first EU use, technical documentation, and market surveillance evidence.
When is a notified body needed under the EU Machinery Regulation?
FAQ on when Machinery Regulation Annex I products need a notified body, how to find designated bodies, and what manufacturers still own.
Which Article 25 conformity assessment module applies? | EU Machinery Regulation FAQ
FAQ on Article 25 of Regulation (EU) 2023/1230: Module A, Module B plus C, Module H, Module G, Annex I triggers, notified body involvement, and technical file evidence.