--- title: "What counts as machinery under Regulation (EU) 2023/1230?" canonical_url: "https://www.sorena.io/artifacts/eu/machinery-regulation/faq/machinery-definition" source_url: "https://www.sorena.io/artifacts/eu/machinery-regulation/faq/machinery-definition" author: "Sorena AI" description: "FAQ on the Machinery Regulation definition of machinery, including assemblies, drive systems, missing components, software, related products, partly completed machinery, safety components, and exclusions." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Machinery Regulation" - "Regulation (EU) 2023/1230" - "machinery definition" - "partly completed machinery" - "safety components" - "related products" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # 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. *FAQ* *EU* ## Machinery Regulation FAQ Machinery Definition Regulation (EU) 2023/1230 defines machinery by function: linked parts or components, at least one moving part, a specific application, and in most cases a drive system other than directly applied human or animal effort. Use this FAQ to distinguish machinery from related products, partly completed machinery, safety components, missing-component cases, software-upload cases, and Article 2 exclusions. Under Regulation (EU) 2023/1230, a product can count as machinery when it is an assembly of linked parts or components, at least one part moves, the parts are joined for a specific application, and the assembly is fitted with or intended to be fitted with a drive system other than directly applied human or animal effort. Article 3 also treats several boundary cases as machinery, including assemblies missing only site connection components, assemblies that function only when installed on a vehicle, building, or structure, integral assemblies of machines, manual lifting-load assemblies, and assemblies missing only the software upload foreseen by the manufacturer. ## What counts as machinery under Regulation (EU) 2023/1230? The core Article 3 definition is functional rather than label-based. Machinery is an assembly joined for a specific application, made of linked parts or components, with at least one moving part, and fitted with or intended to be fitted with a drive system other than directly applied human or animal effort. Do not stop the analysis because the drive, connection kit, installation base, or application software is missing. Article 3 still covers assemblies missing only components needed to connect them on site or to sources of energy and motion, assemblies ready to function only after mounting on a means of transport, building, or structure, and assemblies missing only the software upload intended for the manufacturer's specific application. - Treat an integrated line or cell as machinery when machinery or partly completed machinery is arranged and controlled to achieve the same end as an integral whole. - Treat a manual lifting-load assembly as machinery even when the only power source is directly applied human effort. - Separate the machinery definition from the wider scope question: Article 2 also brings related products and partly completed machinery into the Regulation. Sources for this answer: - [Regulation (EU) 2023/1230 Article 3 definitions](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Defines machinery, including drive-system, missing-component, installed-assembly, integral-assembly, lifting-load, and software-upload cases. - [European Commission machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Commission sector source describing machinery as moving-component assemblies joined for a specific application. ## Related products and partly completed machinery Article 2 applies the Regulation to machinery and five related-product categories: interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, and removable mechanical transmission devices. It also applies to partly completed machinery. Partly completed machinery is not yet machinery because it cannot itself perform a specific application. Its intended role is incorporation into, or assembly with, machinery, other partly completed machinery, or equipment so that machinery is formed. - Interchangeable equipment changes or adds a function after machinery or an agricultural or forestry tractor has been put into service, but a tool is not interchangeable equipment. - A lifting accessory is independently placed on the market and enables a load to be held, either between machinery and load, on the load itself, or as an intended integral part of the load. - A removable mechanical transmission device transmits power between self-propelled machinery or a tractor and other machinery or related products; if placed on the market with a guard, the device and guard are treated as one item. Sources for this answer: - [Regulation (EU) 2023/1230 Article 2 scope](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Lists the related products and states that the Regulation also applies to partly completed machinery. - [Regulation (EU) 2023/1230 Article 3 definitions](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Defines interchangeable equipment, lifting accessories, removable mechanical transmission devices, and partly completed machinery. ## Safety components and digital safety functions A safety component can be physical or digital, including software. Article 3 requires four elements: it is a component of a product within scope, it is designed or intended to fulfil a safety function, it is independently placed on the market, and its failure or malfunction endangers the safety of persons. The same definition excludes components that are necessary for the product to function, or where normal components may be substituted for the product to function. That boundary is why a safety-component decision should state both the safety function and whether the component is independently marketed for that function. - Record the safety function, the hazardous event controlled by that function, and the consequence if the component or software fails. - Check whether the item is independently placed on the market rather than only supplied inside the finished machinery. - Check Article 2 before classifying spare parts: identical replacement safety components supplied by the original manufacturer are excluded when the Article 2 spare-part conditions are met. Sources for this answer: - [Regulation (EU) 2023/1230 Article 3 safety component definition](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Defines safety components as physical or digital components, including software, when the safety-function and market-placement conditions are met. - [Regulation (EU) 2023/1230 Article 2 exclusions](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Excludes identical replacement safety components supplied by the original manufacturer under the stated spare-part condition. ## Exclusions that often change the answer Article 2 contains specific exclusions, so a product can match part of the machinery concept and still fall outside the Regulation for that reason. The exclusion analysis should be narrow and source-tied, because several exclusions contain exceptions for machinery mounted on excluded transport products. Common boundary checks include transport products, electrical and electronic products covered by the Low Voltage Directive or Radio Equipment Directive, seagoing vessels and mobile offshore units, research equipment for temporary laboratory use, military or police products, fairground equipment, mine winding gear, and products intended to move performers during artistic performances. - For air, water, rail, motor-vehicle, two- or three-wheel vehicle, quadricycle, and tractor cases, check whether the machinery mounted on the transport product remains carved back into scope. - For electrical and electronic products, check whether the item falls within the listed Article 2 product categories and within the Low Voltage Directive or Radio Equipment Directive scope. - Do not use an exclusion as a shorthand for all obligations; document the exact Article 2 point and any other EU product law that remains relevant. Sources for this answer: - [Regulation (EU) 2023/1230 Article 2 exclusions](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Lists products outside the Regulation and preserves scope for certain machinery mounted on transport products. - [European Commission machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Commission sector page used for machinery policy context and links to EU machinery legislation resources. ## Evidence for a machinery-definition decision A useful scope record is short but specific. It should identify the item assessed, the intended application, moving parts, drive system or manual lifting-load basis, missing components or software, installation dependency, and whether multiple units are arranged and controlled as an integral whole. If the answer is not machinery, the record should say whether the product is a related product, partly completed machinery, a safety component, or excluded under a specific Article 2 point. That makes the conclusion reusable for technical documentation, declarations, instructions, supplier reviews, and later design changes. - Attach product drawings, bill of materials, control-system descriptions, software-release notes, installation assumptions, and intended-use statements that support the classification. - For partly completed machinery, keep the incorporation rationale and the evidence showing why the item cannot itself perform the specific application. - For exclusions, cite the exact Article 2 exclusion and preserve the analysis of any carve-back, such as machinery mounted on a transport product. Sources for this answer: - [Regulation (EU) 2023/1230 Article 10 manufacturer obligations](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Requires technical documentation and conformity assessment before machinery or a related product is placed on the market or put into service. - [Regulation (EU) 2023/1230 Annex IV technical documentation](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Specifies technical documentation content for machinery, related products, and partly completed machinery, including applied standards and specifications. ## Primary sources - [Regulation (EU) 2023/1230 on machinery](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Primary legal source for Article 2 scope, Article 3 definitions, manufacturer obligations, technical documentation, and Annex IV evidence references used on this FAQ. - Quote: "This Regulation applies to machinery" - [European Commission machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Commission context source for machinery-sector policy and EU machinery legislation resources. - Quote: "The machinery sector is an important part of the engineering industry." ## Topic Guides - [Declaration of Conformity vs Declaration of Incorporation | Machinery Regulation FAQ](/artifacts/eu/machinery-regulation/faq/doc-and-doi.md): 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](/artifacts/eu/machinery-regulation/transition-from-directive-2006-42-ec.md): 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](/artifacts/eu/machinery-regulation/applicability-test.md): 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](/artifacts/eu/machinery-regulation/compliance.md): 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](/artifacts/eu/machinery-regulation/checklist.md): 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](/artifacts/eu/machinery-regulation/deadlines-and-compliance-calendar.md): 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](/artifacts/eu/machinery-regulation/faq.md): 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](/artifacts/eu/machinery-regulation/partly-completed-machinery.md): 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](/artifacts/eu/machinery-regulation/requirements.md): 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](/artifacts/eu/machinery-regulation/safety-components.md): Definition, scope, conformity assessment, technical documentation, declaration, CE marking, and grounded examples for safety components under Regulation (EU) 2023/1230. - [EU Machinery Regulation scope and machine categories](/artifacts/eu/machinery-regulation/scope-and-machine-categories.md): 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](/artifacts/eu/machinery-regulation/substantial-modification-workflow.md): 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](/artifacts/eu/machinery-regulation/machinery-vs-lvd.md): 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](/artifacts/eu/machinery-regulation/machinery-vs-msr.md): 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](/artifacts/eu/machinery-regulation/autonomous-mobile-and-collaborative-machinery.md): Grounded 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?](/artifacts/eu/machinery-regulation/substantial-modification.md): 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](/artifacts/eu/machinery-regulation/risk-assessment-method.md): 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](/artifacts/eu/machinery-regulation/faq/annex-iii-ehsr.md): 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](/artifacts/eu/machinery-regulation/machinery-ce-documentation-template.md): 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](/artifacts/eu/machinery-regulation/faq/ai-act-overlap.md): 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](/artifacts/eu/machinery-regulation/annex-i-route-workflow.md): 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](/artifacts/eu/machinery-regulation/annex-i-and-high-risk-machinery.md): 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](/artifacts/eu/machinery-regulation/category-and-scope-workflow.md): 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 conformity assessment and CE marking](/artifacts/eu/machinery-regulation/conformity-assessment-and-ce.md): EU Machinery Regulation guide to Article 25 conformity assessment routes, Annex I machinery categories, technical documentation, EU declarations, CE marking, and instructions. - [Machinery Regulation cybersecurity evidence FAQ](/artifacts/eu/machinery-regulation/faq/cybersecurity.md): 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](/artifacts/eu/machinery-regulation/digital-instructions.md): 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](/artifacts/eu/machinery-regulation/penalties-and-fines.md): 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](/artifacts/eu/machinery-regulation/related-products.md): 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](/artifacts/eu/machinery-regulation/software-and-cybersecurity-considerations.md): 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](/artifacts/eu/machinery-regulation/technical-documentation-and-technical-file.md): 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](/artifacts/eu/machinery-regulation/technical-file-acceptance-workflow.md): 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](/artifacts/eu/machinery-regulation/timeline-and-transition.md): EU Machinery Regulation guide to Timeline and Transition with scope decisions, owner actions, evidence records, source-linked citations, and practical next steps. - [Machinery Regulation vs EMC Directive](/artifacts/eu/machinery-regulation/machinery-vs-emc.md): 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](/artifacts/eu/machinery-regulation/machinery-regulation-vs-eu-ai-act.md): A grounded 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](/artifacts/eu/machinery-regulation/machinery-regulation-vs-machinery-directive.md): Grounded 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](/artifacts/eu/machinery-regulation/machinery-vs-red.md): Compare EU Machinery Regulation and Radio Equipment Directive boundaries for machinery safety, radio equipment scope, CE documentation, and shared evidence. - [When can a software update affect Machinery Regulation compliance?](/artifacts/eu/machinery-regulation/faq/software-updates.md): 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](/artifacts/eu/machinery-regulation/faq/used-and-modified-machinery.md): 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?](/artifacts/eu/machinery-regulation/faq/notified-bodies.md): 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](/artifacts/eu/machinery-regulation/faq/article-25-modules.md): 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. *Recommended next step* *Placement: after definition evidence section* ## Review a machinery scope decision Turn the machinery-definition answer into a reusable scope record for product, engineering, legal, quality, and regulatory teams: category, Article 2 or Article 3 basis, evidence, assumptions, and change triggers. - [Open Research Copilot](/solutions/research-copilot.md): Answer Machinery Regulation scope, timing, and interpretation questions with cited outputs. - [Talk through implementation](/contact.md): Review your scope, evidence model, controls, and next actions. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). 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