EU Machinery Regulation Digital Instructions

Article 10(7) says machinery or related products must be accompanied by instructions for use and the information set out in Annex III, and that the instructions may be provided in digital format. The same paragraph requires the instructions and information to clearly describe the product model to which they correspond.

Treat digital publication as part of the conformity pack for the exact model, series, type, software variant, and market language set. If the same online file is reused across models, the release record should show how the user can identify the correct instructions for the product in front of them.

When instructions are digital, the manufacturer must mark on the machinery or related product how to access them. If marking on the product is not possible, Article 10 permits the access information on packaging or an accompanying document.

The digital format must let the user print, download, and save the instructions on an electronic device so they can access them at all times, including during a breakdown. The same print-download-save rule applies when the instructions are embedded in the machinery or related product software.

Digital access does not remove the paper-copy obligation. If the user asks at the time of purchase, the manufacturer must provide paper instructions free of charge within one month.

A product aimed at non-professional users, or reasonably foreseeable to be used by non-professional users, needs a separate paper safeguard. Article 10 requires the manufacturer to provide in paper format the safety information essential for putting the machinery or related product into service and using it safely.

This is narrower than a full printed manual but broader than a label-only warning. The paper safety information should cover the essential safe commissioning and safe-use points a non-professional user needs before relying on a digital manual.

Digital delivery does not weaken the language rule. Instructions for use, safety information, and Annex III information must be in a language easily understood by users, as determined by the Member State concerned, and must be clear, understandable, and legible.

Annex III also requires the wording and layout of instructions for non-professional operators to take account of the level of general education and acumen that can reasonably be expected from those operators. For digital instructions, this makes readability, navigation, and version clarity part of the release review, not only translation.

Article 10 requires digital instructions to remain accessible online during the expected lifetime of the machinery or related product and for at least 10 years after placing on the market. The same Article separately requires manufacturers to keep technical documentation and the EU declaration of conformity available to market surveillance authorities for at least 10 years after placing on the market or putting into service.

A usable control set therefore needs more than a public URL. Keep the published file, version history, translation approvals, access method, paper-request process, safety-insert record, and release approval tied to the model record and the technical documentation.