ComparisonEU machinery

Machinery Regulation vs Machinery Directive what actually changes

Regulation (EU) 2023/1230 replaces Directive 2006/42/EC for EU machinery rules from 20 January 2027, while keeping the same core machinery-safety architecture: essential health and safety requirements (EHSRs), technical documentation, conformity assessment, declarations, and CE marking.

Products placed on the market under the Directive before 20 January 2027 may continue to be made available, and existing EC type-examination certificates remain valid until they expire. New Regulation files still need a fresh scope, Annex I route, documentation, and digital-delivery review.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Use the Directive for products placed on the market before 20 January 2027 and the Regulation for products placed on the market or put into service under the new regime from that date. A Directive-era file can supply evidence, but it does not settle the Regulation's product category, test, Annex I conformity route, digital-instruction conditions, or software and data requirements. Products lawfully placed under the Directive before the switchover may continue to be made available, and Directive EC type-examination certificates remain valid until they expire.

Side-by-side comparison

Regulation (EU) 2023/1230 vs Directive 2006/42/EC

A cited-source comparison for product, regulatory, quality, and engineering teams updating machinery compliance files from the Machinery Directive to the Machinery Regulation.

Review all sources
First framework
Regulation (EU) 2023/1230

The replacement EU machinery regime applying from 20 January 2027, with directly applicable rules for machinery, related products, and partly completed machinery.

Second framework
Directive 2006/42/EC

The legacy Machinery Directive regime that has governed machinery placed on the EU market before the Regulation replaces it.

Scope boundary

Regulation (EU) 2023/1230

The Regulation expressly covers machinery, listed related products, and partly completed machinery; related products include interchangeable equipment, safety components, lifting accessories, chains, ropes, webbing, and removable mechanical transmission devices.

Directive 2006/42/EC

The Directive covers machinery and includes categories such as interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, removable mechanical transmission devices, and partly completed machinery.

Operational implication

Keep a scope table that identifies the exact product category before deciding whether old Directive evidence can be reused under the Regulation.

Legal form

Regulation (EU) 2023/1230

A regulation: the recitals explain that a regulation was chosen because uniform application is needed for product requirements, EHSRs, and conformity assessment procedures across the EU.

Directive 2006/42/EC

A directive: the Commission guide stresses that the Directive and national implementing texts are the legally binding instruments for the Directive regime.

Operational implication

Do not treat the change as only a citation update. Review whether national transposition assumptions, local guidance, or Directive-era interpretations still fit the directly applicable Regulation text.

Trigger

Regulation (EU) 2023/1230

Regulation (EU) 2023/1230 applies from 20 January 2027 for the main machinery regime, with specified articles applying earlier.

Directive 2006/42/EC

Directive 2006/42/EC is repealed from 20 January 2027, but products placed on the market in conformity with it before that date may continue to be made available. Existing EC type-examination certificates remain valid until they expire.

Operational implication

Record the first placement date, not only the engineering release or later distribution date. Keep the certificate number and expiry date where a Directive EC type-examination certificate is still being relied on.

Core obligations

Regulation (EU) 2023/1230

The Regulation requires manufacturers to draw up Annex IV Part A technical documentation before placing machinery or a related product on the market or putting it into service; partly completed machinery uses Annex IV Part B relevant technical documentation.

Directive 2006/42/EC

The Directive guide maps the legacy technical file for machinery to Annex VII A and relevant technical documentation for partly completed machinery to Annex VII B.

Operational implication

Build a correlation table from Directive technical-file sections to Regulation Annex IV, then mark any missing Regulation evidence instead of renaming the old file.

Evidence record

Regulation (EU) 2023/1230

The Regulation defines as a physical or digital modification after placing on the market or putting into service, not foreseen or planned by the manufacturer, that affects safety by creating a new hazard or increasing an existing risk and requires either the addition of guards or protective devices whose implementation necessitates modification of the existing safety control system, or additional protective measures to ensure stability or mechanical strength.

Directive 2006/42/EC

The Directive guide discusses modification and placing-on-the-market questions, but the new Regulation gives a more explicit legal definition for .

Operational implication

Run a separate change assessment for retrofits, software updates, safety-function changes, and digital changes instead of assuming the original CE file still controls.

Instructions and declarations

Regulation (EU) 2023/1230

The Regulation permits instructions for use, EU declarations of conformity, assembly instructions, and declarations of incorporation to be provided in digital format subject to specific conditions; essential safety information for non-professional use still needs paper delivery.

Directive 2006/42/EC

Directive-era files center on instructions and EC declarations supplied with machinery, without the same Regulation structure for digital access mechanisms.

Operational implication

Update instruction and declaration procedures to record the digital access method, paper-request process, language controls, and non-professional-use paper safety information.

Software and machine learning

Regulation (EU) 2023/1230

The Regulation adds explicit EHSR treatment for safety-related software and data protection against accidental or intentional corruption, and Annex I Part A includes safety components and embedded systems with fully or partly self-evolving machine-learning behaviour ensuring safety functions.

Directive 2006/42/EC

Directive-era controls still cover safety-related control systems and machine safety, but they do not contain the same Regulation wording for self-evolving safety functions and corruption of safety-related software or data.

Operational implication

Add software bill-of-material, version, change-control, safety-function, data-integrity, and cybersecurity evidence where software or connected control systems can affect safety.

Overlap and reuse

Regulation (EU) 2023/1230

Use the Regulation column for products placed on the market or put into service under Regulation (EU) 2023/1230, substantial modifications after placement that meet the Regulation definition, and transition files for releases intended from 20 January 2027.

Directive 2006/42/EC

Use the Directive column for legacy evidence and products placed under Directive 2006/42/EC before the Regulation replaces it.

Operational implication

Use a gap register covering product category, placement regime, Annex I/Annex IV route, standards basis, documentation delta, digital-instruction choice, software/cyber delta, declaration terminology, and CE marking evidence.

Practical decision rule

Regulation (EU) 2023/1230

Machinery and related products whose category is not listed in Annex I use internal production control; Annex I Part A requires notified-body involvement and Annex I Part B can use internal production control only where the relevant harmonised standards or common specifications fully cover the category and requirements.

Directive 2006/42/EC

The Directive uses Annex IV machinery routing, including internal checks, EC type-examination, and full quality assurance routes depending on category and standards coverage.

Operational implication

Re-route every Annex IV/Annex I product instead of copying the old Directive conformity path into the Regulation file.

Practical decision rule

Practical decision rule

  • Use Regulation (EU) 2023/1230 when the facts match the left-side scope, trigger, and evidence rows.
  • Use Directive 2006/42/EC when the facts match the right-side scope, trigger, and evidence rows.
  • Reuse controls only where the comparison rows show the same actor, obligation, timing, and evidence basis.
Section 1

Where the Regulation changes the compliance file

The Regulation replaces Directive 2006/42/EC and defines products within scope as machinery, listed related products, and partly completed machinery.

For product teams, the practical change is that transition work should not stop at updating labels. Recheck the scope conclusion, Annex I category, substantial-modification analysis, digital instruction delivery, software and cyber-safety requirements, conformity-assessment route, technical documentation, declaration wording, and CE marking file.

  • Use Directive evidence for machinery placed under Directive 2006/42/EC, but do not assume it proves every Regulation (EU) 2023/1230 requirement.
  • Treat substantial physical or digital modifications as a separate gating question because the Regulation defines when a change can create a new compliance obligation.
  • Document whether instructions, EU declarations, and assembly instructions will be supplied on paper, digitally, or through the Regulation's permitted access mechanisms.
Section 2

Transition and application timing

The main manufacturer-facing switchover is 20 January 2027. The current consolidated Regulation sets that as the main application date and repeals Directive 2006/42/EC from the same date. Article 52 prevents Member States from impeding the continued making available of products placed on the market in conformity with the Directive before that date.

Some provisions apply earlier to notification of conformity assessment bodies, delegated acts, committees and transition arrangements. Select the product regime from the placement or putting-into-service event and the applicable transitional rule; an earlier institutional date does not start the full manufacturer regime.

  • Before 20 January 2027, preserve Directive evidence for products placed on the market under Directive 2006/42/EC; continued distribution after that date is different from first placement under the new Regulation.
  • For releases intended on or after 20 January 2027, route the file through Regulation (EU) 2023/1230 scope, Annex I, documentation, declaration, and CE marking checks.
  • Track existing EC type-examination certificates through their expiry date, but reassess the product and conformity route before relying on them for a new Regulation placement.
Recommended next step

Turn the comparison into a transition gap register

Map each machinery model, safety component, related product, partly completed machinery file, and software change to the Directive evidence you can reuse and the Regulation evidence you must refresh.

Section 3

Evidence to compare before reusing Directive files

A Directive-era technical file can be useful background, but the comparison should identify what still maps cleanly and what must be refreshed under the Regulation. The Regulation points manufacturers to Annex IV technical documentation, Annex III essential health and safety requirements, Annex V declarations, Article 25 conformity assessment, and Article 24 CE marking.

Keep the comparison concrete: one line per product or model, one line for the legal regime used at placement, one line for the relevant Annex I category, and one line for each changed assumption such as software, digital instructions, machine-learning safety functions, or a .

  • Carry forward risk assessment, standards, test, declaration, and instruction evidence only where the underlying requirement still matches.
  • Add a Regulation gap column for digital delivery conditions, software/data protection against corruption, and Annex I Part A or Part B routing.
  • Keep notified-body evidence separate from self-assessment evidence so the conformity route is reviewable after transition.
Primary sources

References and citations

eur-lex.europa.eu18 citations
Referenced sections
  • Current consolidated legal source for scope, substantial modification, EHSRs, digital instructions, software and data requirements, conformity assessment, technical documentation, declarations, CE marking, and Articles 51-54 transition rules.
  • Supports the Regulation scope, substantial-modification definition, manufacturer duties, technical documentation, conformity assessment, declarations, and CE marking requirements.
  • Articles 51, 52, and 54 support the 20 January 2027 switchover, continued availability of products placed under the Directive before that date, and continued validity of Directive EC type-examination certificates until expiry.
Show 15 more
  • Supports the Regulation evidence set: technical documentation, EHSRs, conformity assessment, declaration, and CE marking.
  • Supports the Regulation scope language for machinery, related products, and partly completed machinery.
  • Supports the need to map product categories to Regulation scope before reusing evidence.
  • Primary Regulation text for checking whether Directive-era assumptions still map.
  • Supports the Regulation application and repeal provisions.
  • Supports Regulation technical documentation requirements for machinery, related products, and partly completed machinery.
  • Supports using Regulation Annex IV as the target structure for refreshed files.
  • Supports the Regulation definition of substantial modification.
  • Supports requiring a new assessment for physical and digital safety-affecting modifications.
  • Supports manufacturer duties for instructions, declarations, and digital delivery.
  • Supports the Regulation requirements for software/data protection and Annex I machine-learning safety-function categories.
  • Supports adding software, data, and safety-function evidence to Regulation transition files.
  • Supports Regulation-side routing for placement, putting into service, substantial modification, and required evidence.
  • Supports the Regulation fields that should appear in a transition gap register.
  • Supports Regulation Article 25 and Annex I routing.
"machinery, the related products listed"
More quoted passages
"draw up the technical documentation"
"This Regulation applies to machinery"
"products within the scope"
"repealing Directive 2006/42/EC"
"Entry into force and application"
"Annex IV, Part A"
"relevant technical documentation"
"by physical or digital means"
"creating a new hazard"
"internet address or machine-readable code"
"self-evolving behaviour"
"protection against corruption"
"putting into service"
"technical documentation"
"conformity assessment procedures"
ec.europa.eu10 citations
Referenced sections
  • Commission guidance source for Directive-era interpretation of scope, technical files, instructions, declarations, CE marking, and conformity assessment.
  • Supports the Directive-era baseline for technical files, instructions, declarations, CE marking, and conformity assessment guidance.
  • Supports Directive-era scope interpretation for machinery and partly completed machinery.
Show 7 more
  • Supports the Directive baseline and the distinction between guidance and legally binding Directive/national texts.
  • Supports Directive technical-file references for machinery and partly completed machinery.
  • Supports the Directive-era guide baseline for modification and placing-on-the-market analysis.
  • Supports the Directive baseline for instructions and EC declarations.
  • Supports the Directive baseline for machinery control-system safety guidance.
  • Supports the Directive-side file elements that may be reused or remapped.
  • Supports the Directive conformity-assessment baseline, including Annex IV and associated procedures.
"Guide to application"
More quoted passages
"Scope of the Machinery Directive"
"only the Machinery Directive"
"Technical file for machinery"
"The form of the instructions"
"Reliability of control systems"
"technical file"
"Procedures for conformity assessment"
data.europa.eu4 citations
Referenced sections
  • Primary legal source for the legacy Directive side of the comparison.
  • Supports the legacy Directive baseline and its machinery-safety architecture before repeal and replacement.
  • Supports the Directive scope baseline.
Show 1 more
  • Supports Directive-side routing for legacy machinery evidence.
"on machinery"
More quoted passages
"scope"
"Directive 2006/42/EC"
eur-lex.europa.eu4 citations
Referenced sections
  • Primary legal source for the Regulation's scope, conformity assessment, digital instructions, and application timing.
  • Supports the 20 January 2027 application and repeal/replacement timing and distinguishes earlier article application dates.
  • Supports the 20 January 2027 application date and earlier article-specific application dates.
Show 1 more
  • Supports the repeal and replacement of Directive 2006/42/EC as of 20 January 2027.
"machinery and related products"
More quoted passages
"It shall apply from 20 January 2027"
"Directive 2006/42/EC is repealed with effect from 20 January 2027"
eur-lex.europa.eu3 citations
Referenced sections
  • Supports the Regulation legal-form comparison and uniform-interpretation rationale.
  • Supports the Regulation summary of digital instructions, digital declarations, and paper safeguards.
  • Supports the Regulation conformity-assessment overview for Annex I Part A and Part B.
"in the form of a regulation"
More quoted passages
"may be provided in digital format"
"procedure involving a notified body"
webgate.ec.europa.eu2 citations
Referenced sections
  • Supports the notified-body context by listing Regulation (EU) 2023/1230 on machinery among active conformity-assessment legislation.
  • Supports the notified-body context for active machinery legislation.
"Regulation (EU) 2023/1230 on machinery"

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