EU Machinery Regulation vs Market Surveillance Regulation (MSR) Side-by-side comparison
The Machinery Regulation is the product-compliance rulebook for machinery, related products and partly completed machinery: scope, Annex III essential health and safety requirements (EHSRs), technical documentation, conformity assessment, declarations, instructions and CE marking.
The Market Surveillance Regulation is the horizontal enforcement layer: an EU-based responsible economic operator, authority cooperation, targeted distance sales, corrective measures, online-interface powers for serious risk, and controls on products entering the Union market.
The Machinery Regulation determines whether machinery, a related product, or partly completed machinery complies with its product rules. Regulation (EU) 2019/1020 governs how authorities supervise covered products and how economic operators cooperate. Before offering machinery in the Union, identify the responsible for the Article 4 tasks, make the name and contact details available as required, index the technical evidence for authority requests, and connect product correction to withdrawal, recall, online, and border measures. The MSR has applied since 16 July 2021; the Machinery Regulation's main product regime applies from 20 January 2027.
Side-by-side comparison
EU Machinery Regulation vs Market Surveillance Regulation (MSR): side-by-side comparison
A practical comparison for separating Machinery Regulation product-compliance duties from Market Surveillance Regulation authority, cooperation, corrective-action, online-sales and border-control duties.
Product-compliance regime for machinery, related products and partly completed machinery: EHSRs, technical documentation, conformity assessment, declarations, instructions, CE marking and machinery-specific corrective action.
Second framework
Market Surveillance Regulation (MSR)
Horizontal market-surveillance and enforcement framework: authority powers, cooperation duties, responsible economic-operator tasks, distance sales, online interfaces, corrective action and controls on products entering the Union market.
EU Machinery Regulation vs Market Surveillance Regulation (MSR): side-by-side comparison
The Machinery Regulation sets EU rules for machinery, related products and partly completed machinery so compliant products meet Annex III EHSRs and can move freely for the aspects covered by the Regulation.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
MSR applies to products covered by the Union harmonisation legislation listed in Annex I and to the extent that legislation lacks a more specific rule with the same objective. It sets the horizontal surveillance, cooperation, and border framework.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Start with the Machinery Regulation for the product-compliance answer, then use MSR for the responsible operator, authority response, market measures, and border process. Apply a more specific Machinery Regulation procedure where it controls the same issue.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Machinery Regulation duties sit with manufacturers, authorised representatives, importers and distributors, with different duties for machinery or related products and partly completed machinery.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
MSR defines economic operators to include manufacturers, authorised representatives, importers, distributors, fulfilment service providers and others with obligations connected to manufacture, market availability or putting products into service; it also requires cooperation with market surveillance authorities.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Keep a role map that shows who owns the Machinery Regulation product file and who is the MSR response contact for authority requests, online sales, logistics and fulfilment facts.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Machinery compliance asks whether the product was designed and constructed to meet applicable Annex III EHSRs, whether the correct conformity assessment procedure was used, and whether the required declaration, instructions and CE marking are in place.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
MSR asks whether products made available on the Union market comply with the applicable Union harmonisation law and whether the authority can obtain documents, product information, samples and corrective action when risk or non-compliance appears.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
A finished conformity file is not the end of the workflow; it must be indexed so authorities can inspect the same EHSR, technical and declaration evidence quickly.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Machinery evidence should include the risk assessment, EHSR mapping, technical documentation, standards or common specifications relied on, conformity assessment route, EU declaration of conformity or incorporation, instructions, and change or corrective-action records.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
on machinery
MSR evidence should identify which Article 4 operator qualifies and why, show its name and contact details, and include declaration and technical-documentation availability, authority requests, supply-chain information, targeted online offers, sampling, and corrective measures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Use one evidence index with separate tags; a risk assessment may support both sides, while an online-interface warning, border hold or authority request belongs mainly to the MSR response file.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
The Machinery Regulation focuses on whether the product placed on the market or put into service meets machinery requirements and whether required instructions and declarations accompany or are accessible for the product.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
MSR treats an online or other distance-sales offer as made available on the market only when it targets Union end users. Online-interface orders require a serious risk and no other effective means to eliminate it.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
For online machinery sales, preserve language, currency, delivery area, advertising, fulfilment, and other targeting facts. Keep declaration and instruction access records, plus a proportionate warning or takedown procedure for an authority order.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Regulation (EU) 2023/1230 generally applies from 20 January 2027. Until then, Directive 2006/42/EC remains the machinery conformity basis for products first placed on the market before the changeover.
Articles 51-54 support the Machinery Regulation transition and main 20 January 2027 application date.
Regulation (EU) 2019/1020 has generally applied since 16 July 2021. Its Article 4 operator, distance-sales, authority-cooperation, and border framework therefore already applies where the covered Union harmonisation legislation brings the product within scope.
Articles 4, 6, 44, and Annex I support the Article 4 operator tasks, distance-sales rule, 16 July 2021 application date, and machinery legislation coverage.
Do not wait for 20 January 2027 to build the MSR response layer. Use the current Machinery Directive or later Machinery Regulation as the product-law basis, while keeping the Article 4 operator, online-offer, authority-response, corrective-action, and import-control records active now.
Under the Machinery Regulation, manufacturers, importers and distributors must act when machinery, related products or partly completed machinery are not in conformity; actions can include bringing the product into conformity, withdrawal or recall, and informing competent authorities when risk thresholds are met.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
on machinery
MSR defines corrective action and allows market surveillance authorities to require proportionate measures, including bringing the product into compliance, preventing availability, withdrawing or recalling it, warnings, user alerts, risk conditions, or rendering the product inoperable.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Corrective-action procedures should state both the product fix and the market measure: what changes in the technical file, what happens to stock and online offers, who notifies authorities, and how users or customers are warned.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Machinery Regulation surveillance is handled by market surveillance authorities using the Regulation's machinery-specific national procedure, Union safeguard procedure and formal non-compliance process.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Commission machinery sector page used for machinery market surveillance, AdCo, notified bodies and national-authority context.
Market surveillance
MSR supplies the broader authority toolkit: designated market surveillance authorities, document and data requests, inspections, sampling, investigation powers, cooperation between authorities and customs-related controls.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Authority playbooks should identify the competent national authority, the product facts, the technical file owner, the notified body if involved, the MSR response contact and the communication channel used for the request.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Use the Machinery Regulation when the question is product scope, EHSR coverage, conformity assessment, technical documentation, declarations, instructions, CE marking, partly completed machinery or machinery-specific non-compliance.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Use MSR when the question is authority cooperation, responsible operator availability, online offer targeting, document production, market-surveillance powers, corrective market measures, product sampling, border controls or cross-border authority coordination.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
When product non-compliance also requires a market measure, correct the product under the Machinery Regulation and manage the surveillance response under MSR.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
The Machinery Regulation determines whether the machinery product itself is compliant and whether declarations, instructions, markings and technical documentation support placing it on the market.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
MSR contains a separate chapter on controls for products entering the Union market and covers suspension or refusal of release for free circulation where authorities find serious risk or non-compliance.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
For imported machinery, include customs and logistics records in the MSR pack, but keep the underlying compliance answer tied to the Machinery Regulation technical and conformity file.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Scope boundary
Machinery Regulation
The Machinery Regulation sets EU rules for machinery, related products and partly completed machinery so compliant products meet Annex III EHSRs and can move freely for the aspects covered by the Regulation.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
MSR applies to products covered by the Union harmonisation legislation listed in Annex I and to the extent that legislation lacks a more specific rule with the same objective. It sets the horizontal surveillance, cooperation, and border framework.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
Start with the Machinery Regulation for the product-compliance answer, then use MSR for the responsible operator, authority response, market measures, and border process. Apply a more specific Machinery Regulation procedure where it controls the same issue.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Covered actors
Machinery Regulation
Machinery Regulation duties sit with manufacturers, authorised representatives, importers and distributors, with different duties for machinery or related products and partly completed machinery.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
MSR defines economic operators to include manufacturers, authorised representatives, importers, distributors, fulfilment service providers and others with obligations connected to manufacture, market availability or putting products into service; it also requires cooperation with market surveillance authorities.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
Keep a role map that shows who owns the Machinery Regulation product file and who is the MSR response contact for authority requests, online sales, logistics and fulfilment facts.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Trigger
Machinery Regulation
Machinery compliance asks whether the product was designed and constructed to meet applicable Annex III EHSRs, whether the correct conformity assessment procedure was used, and whether the required declaration, instructions and CE marking are in place.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
MSR asks whether products made available on the Union market comply with the applicable Union harmonisation law and whether the authority can obtain documents, product information, samples and corrective action when risk or non-compliance appears.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
A finished conformity file is not the end of the workflow; it must be indexed so authorities can inspect the same EHSR, technical and declaration evidence quickly.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Core obligations
Machinery Regulation
Machinery evidence should include the risk assessment, EHSR mapping, technical documentation, standards or common specifications relied on, conformity assessment route, EU declaration of conformity or incorporation, instructions, and change or corrective-action records.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
on machinery
Market Surveillance Regulation (MSR)
MSR evidence should identify which Article 4 operator qualifies and why, show its name and contact details, and include declaration and technical-documentation availability, authority requests, supply-chain information, targeted online offers, sampling, and corrective measures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
Use one evidence index with separate tags; a risk assessment may support both sides, while an online-interface warning, border hold or authority request belongs mainly to the MSR response file.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Evidence record
Machinery Regulation
The Machinery Regulation focuses on whether the product placed on the market or put into service meets machinery requirements and whether required instructions and declarations accompany or are accessible for the product.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
MSR treats an online or other distance-sales offer as made available on the market only when it targets Union end users. Online-interface orders require a serious risk and no other effective means to eliminate it.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
For online machinery sales, preserve language, currency, delivery area, advertising, fulfilment, and other targeting facts. Keep declaration and instruction access records, plus a proportionate warning or takedown procedure for an authority order.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Application dates
Machinery Regulation
Regulation (EU) 2023/1230 generally applies from 20 January 2027. Until then, Directive 2006/42/EC remains the machinery conformity basis for products first placed on the market before the changeover.
Articles 51-54 support the Machinery Regulation transition and main 20 January 2027 application date.
Market Surveillance Regulation (MSR)
Regulation (EU) 2019/1020 has generally applied since 16 July 2021. Its Article 4 operator, distance-sales, authority-cooperation, and border framework therefore already applies where the covered Union harmonisation legislation brings the product within scope.
Articles 4, 6, 44, and Annex I support the Article 4 operator tasks, distance-sales rule, 16 July 2021 application date, and machinery legislation coverage.
Operational implication
Do not wait for 20 January 2027 to build the MSR response layer. Use the current Machinery Directive or later Machinery Regulation as the product-law basis, while keeping the Article 4 operator, online-offer, authority-response, corrective-action, and import-control records active now.
Supports the 20 January 2027 change in the machinery product-law basis.
Corrective action
Machinery Regulation
Under the Machinery Regulation, manufacturers, importers and distributors must act when machinery, related products or partly completed machinery are not in conformity; actions can include bringing the product into conformity, withdrawal or recall, and informing competent authorities when risk thresholds are met.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
on machinery
Market Surveillance Regulation (MSR)
MSR defines corrective action and allows market surveillance authorities to require proportionate measures, including bringing the product into compliance, preventing availability, withdrawing or recalling it, warnings, user alerts, risk conditions, or rendering the product inoperable.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
Corrective-action procedures should state both the product fix and the market measure: what changes in the technical file, what happens to stock and online offers, who notifies authorities, and how users or customers are warned.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Enforcement
Machinery Regulation
Machinery Regulation surveillance is handled by market surveillance authorities using the Regulation's machinery-specific national procedure, Union safeguard procedure and formal non-compliance process.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Commission machinery sector page used for machinery market surveillance, AdCo, notified bodies and national-authority context.
Market surveillance
Market Surveillance Regulation (MSR)
MSR supplies the broader authority toolkit: designated market surveillance authorities, document and data requests, inspections, sampling, investigation powers, cooperation between authorities and customs-related controls.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
Authority playbooks should identify the competent national authority, the product facts, the technical file owner, the notified body if involved, the MSR response contact and the communication channel used for the request.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Commission machinery sector page used for machinery market surveillance, AdCo, notified bodies and national-authority context.
Market surveillance
Overlap and reuse
Machinery Regulation
Use the Machinery Regulation when the question is product scope, EHSR coverage, conformity assessment, technical documentation, declarations, instructions, CE marking, partly completed machinery or machinery-specific non-compliance.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
Use MSR when the question is authority cooperation, responsible operator availability, online offer targeting, document production, market-surveillance powers, corrective market measures, product sampling, border controls or cross-border authority coordination.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
When product non-compliance also requires a market measure, correct the product under the Machinery Regulation and manage the surveillance response under MSR.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Practical decision rule
Machinery Regulation
The Machinery Regulation determines whether the machinery product itself is compliant and whether declarations, instructions, markings and technical documentation support placing it on the market.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Market Surveillance Regulation (MSR)
MSR contains a separate chapter on controls for products entering the Union market and covers suspension or refusal of release for free circulation where authorities find serious risk or non-compliance.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Operational implication
For imported machinery, include customs and logistics records in the MSR pack, but keep the underlying compliance answer tied to the Machinery Regulation technical and conformity file.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
market surveillance and compliance of products
Practical decision rule
How should teams split Machinery Regulation and MSR work?
Ask first whether the issue is a product-compliance question, a market-surveillance response question, or both.
Keep EHSR, risk assessment, technical documentation, conformity assessment and declarations under the Machinery Regulation evidence owner.
Keep authority requests, online-offer facts, supply-chain information, border controls, cooperation logs and corrective market measures under the MSR response owner.
When a risk or non-compliance is found, connect the two workflows so the product correction and the market action tell the same factual story.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Commission machinery sector page used for machinery market surveillance, AdCo, notified bodies and national-authority context.
Market surveillance
1
Section 1
What each regulation controls
The Machinery Regulation controls the compliance case for the product itself. For machinery and related products, the record should show the covered product, the applicable Annex III essential health and safety requirements, the risk assessment, the chosen conformity assessment route, technical documentation, instructions, EU declaration of conformity and CE marking. For partly completed machinery, the focus shifts to the relevant EHSRs, technical documentation, assembly instructions and EU declaration of incorporation.
The MSR controls the surveillance environment around products subject to listed Union harmonisation legislation. Article 4 requires specified products to have an EU-established manufacturer, importer, authorised representative with the relevant mandate, or fulfilment service provider responsible for defined compliance tasks. Authorities can request documentation and data, inspect and sample products, require corrective measures, and act at the border. They may order online warnings, content removal, access restriction, or interface warnings only where no other effective means are available to eliminate a serious risk.
Use the Machinery Regulation to decide whether the machine, related product or partly completed machinery is compliant before placing it on the market or putting it into service.
Use MSR to identify the Article 4 responsible economic operator, prepare authority access to evidence, determine whether a distance-sales offer targets Union end users, and manage corrective or border action.
Do not replace the Machinery Regulation conformity assessment with a market-surveillance checklist; the MSR check comes after, around, or because of the product-compliance file.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
rules for machinery, related products and partly completed machinery
Articles 4, 6, 14, 16, 27-29 and Annex I support the responsible economic operator, targeted distance-sales rule, authority powers, corrective measures, online-interface conditions, and border controls.
2
Section 2
Evidence to keep distinct
For Machinery Regulation compliance, keep evidence that proves the product design and documentation meet the applicable EHSRs: risk assessment, standards or common-specification mapping, Annex III checklist, technical documentation, conformity assessment route, declaration, instructions, source-code or programming-logic access path where relevant, and records of substantial changes or corrective action.
For MSR readiness, keep the authority-response layer: the Article 4 operator's name, postal address, email address, mandate or role basis, technical documentation index, declaration availability, supply-chain and distribution information, online-offer targeting records, cooperation log, authority requests, product-sampling records, risk assessments, corrective-action plan, withdrawal or recall records, and border-control correspondence.
Tag each record as Machinery Regulation evidence, MSR response evidence, or both.
Make sure the declaration and technical documentation can be produced to market surveillance authorities in the form and language the authority can use.
Keep corrective-action records granular enough to show whether the fix brought the product into conformity, stopped availability on the market, withdrew or recalled the product, warned users, or mitigated the risk.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Supports the responsible-operator record, authority document and data access, distribution traceability, sampling, risk assessment, corrective measures, and border correspondence.
Recommended next step
Prepare Machinery Regulation and MSR evidence together
Turn the product-compliance file and market-surveillance response pack into one evidence index without merging their legal tests, owners or corrective-action triggers.
Product, safety and quality teams should own the Machinery Regulation file because it turns hazards, EHSRs, standards, technical documentation and conformity assessment into the release decision. Regulatory, legal, logistics, support and marketplace teams should own the MSR response layer because it handles authority contact, distribution facts, online offers, corrective action and border questions.
The two layers meet when an authority asks for the technical file, when an importer or distributor believes machinery is non-compliant, when online offers target Union end users, when a product entering the Union market is held, or when a risk requires corrective action throughout the Union.
Route product-design and conformity questions to the Machinery Regulation owner.
Route authority requests, online-offer takedown/warning issues, supply-chain traceability and border holds to the MSR owner.
Escalate to both owners when non-compliance requires product changes and market measures at the same time.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.
Primary legal source for Article 4 responsible economic operators, targeted distance sales, authority powers, corrective measures, serious-risk online-interface powers, cooperation, and controls on products entering the Union market.
Articles 4, 6, 14, 16, 27-29 and Annex I support the responsible economic operator, targeted distance-sales rule, authority powers, corrective measures, online-interface conditions, and border controls.
Supports the responsible-operator record, authority document and data access, distribution traceability, sampling, risk assessment, corrective measures, and border correspondence.
Grounds the Machinery Regulation side: scope for machinery, related products and partly completed machinery; Annex III EHSRs; technical documentation; conformity assessment; declarations; corrective action; and market-surveillance procedures.
Articles 51-54 support the Machinery Regulation transition and main 20 January 2027 application date.
Supports the 20 January 2027 change in the machinery product-law basis.
Articles 4, 6, 44, and Annex I support the Article 4 operator tasks, distance-sales rule, 16 July 2021 application date, and machinery legislation coverage.
Supports maintaining the horizontal surveillance and cooperation layer independently of the machinery product-law changeover.
Summarises Machinery Regulation obligations for manufacturers, importers and distributors, including EHSRs, conformity assessment, CE marking, instructions, declarations and partly completed machinery documents.
"rules for machinery, related products and partly completed machinery"
Grounds the MSR side: market surveillance, responsible economic-operator tasks, distance sales, cooperation, authority powers, corrective actions and controls on products entering the Union market.