- Legacy framework relevant to transition questions.
References and citations
- Primary source for scope, Annex I routing, software duties, digital-document rules, and timing.
Clear answers with practical next steps.
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Cited legal and guidance references.
This FAQ is written for teams building route decisions and technical files, not for academic interpretation. Where answers depend on product specifics, each response tells you what facts to collect and which artifacts to produce.
Q: What products are in scope? A: The Regulation covers machinery, related products, and partly completed machinery. Related products include interchangeable equipment, safety components including software, lifting accessories, chains, ropes and webbing, and removable mechanical transmission devices.
Q: What is excluded? A: Article 2 lists exclusions such as certain fairground equipment, weapons, some transport-sector products, and specified electrical or radio products where other EU sector legislation governs the risk. Keep a short exclusion memo and record why each likely exclusion does or does not apply.
Q: Why does Annex I matter so much? A: Annex I controls the Article 25 route. Part A always goes to third-party routes. Part B may still use Module A, but only when harmonised standards or common specifications cover all relevant EHSR for that category and are fully applied.
Q: When do we need a notified body? A: Always for Annex I Part A. Often for Part B unless the Module A condition is satisfied. When the chosen procedure involves a notified body, its identification number must follow the CE mark.
Q: What has to be in the technical documentation? A: Annex IV is the minimum content list. The file must show the risk-assessment logic, the applicable EHSR, the protective measures, the verification evidence, and the controlled outputs such as instructions and declarations.
Q: What is the practical risk-assessment method? A: Define limits and intended use, identify hazards and hazardous situations, estimate and evaluate risk, apply the safety-integration hierarchy, and record residual risks and verification evidence.
Q: What does the Regulation require for software? A: It requires protection against corruption, identification of installed software necessary for safe operation, evidence of legitimate or illegitimate intervention, and retention of certain software-related logs for fixed periods.
Q: Can authorities ask for source code? A: Yes. Annex IV allows safety-related source code or programming logic to be requested where necessary to verify compliance with the relevant essential health and safety requirements.
Q: What ships with partly completed machinery? A: Assembly instructions, the declaration of incorporation, and the Annex IV Part B technical documentation set.
Q: Can those documents be digital? A: Yes, but the access conditions matter. Assembly instructions must be printable, downloadable, and savable, paper copies must be available free of charge within one month on request, and digital access must remain online for 10 years.
Q: When does the Regulation apply? A: The corrigendum confirms entry into force on 19 July 2023 and general application from 14 January 2027, with several provisions applying earlier under Article 54.
Q: What should teams do now? A: Finish product-family scope and Annex I classification, decide the Article 25 route, stand up digital-instructions and declaration controls, and make software evidence retrievable before 2027.
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