EU Machinery Regulation Related Products

Start with the application date and the legal category definition, not the sales name. The Commission states that Regulation (EU) 2023/1230 applies on a mandatory basis from 20 January 2027 and that products placed on the EU market before that date must comply with Directive 2006/42/EC.

A retrofit attachment is interchangeable equipment only if the operator assembles it with machinery or an agricultural or forestry tractor after that base product is put into service, to change its function or give it a new function, and the attachment is not a tool. A component is a safety component only if it meets every part of the Article 3 definition, including independent placing on the market, a safety function, failure or malfunction that endangers persons, and the condition that it is not necessary for the product to function or can be replaced by a normal component for that purpose.

For lifting products, the definitions are narrow. A lifting accessory is independently placed on the market and holds the load from between the lifting machinery and the load, on the load itself, or as an intended integral part of the load; slings and their components are included. Chains, ropes and webbing qualify only when designed and constructed for lifting as part of lifting machinery or lifting accessories. A removable mechanical transmission device transmits power between self-propelled machinery or a tractor and other machinery or a related product, joining them at the first fixed bearing; if marketed with a guard, the device and guard are one item.

Use the partly completed machinery category only where the assembly is not yet machinery because it cannot itself perform a specific application and is intended to be incorporated into or assembled with machinery, other partly completed machinery, or equipment.

That boundary changes the documentation package. Machinery and related products move through technical documentation, conformity assessment, EU declaration of conformity, CE marking, instructions for use, and product identification. Partly completed machinery uses technical documentation, EU declaration of incorporation, assembly instructions, and incorporation-facing identification.

For machinery and related products, Annex IV, Part A technical documentation must cover the intended use, risk assessment, applicable essential health and safety requirements, protective measures, design drawings, standards or other technical specifications used, test and inspection evidence, instructions, and the measures used to keep series production in conformity.

For safety components and digital or software-enabled safety functions, preserve enough design, validation, version, and change-control evidence to explain the safety function and the consequences of failure. Where source code or programming logic is relevant to checking compliance, the Regulation allows competent authorities to request it when necessary.

For a related product placed on the market or put into service from 20 January 2027, confirm that Annex IV, Part A technical documentation exists, the relevant Article 25 conformity assessment has been completed, the EU declaration of conformity is available, and the CE marking is affixed before release. Screen Annex I before selecting a procedure. Part A includes removable mechanical transmission devices and their guards, as well as safety components with fully or partially self-evolving machine-learning behaviour that ensures safety functions; those products require one of the Article 25(2) procedures. Part B includes specified protective devices, power-operated interlocking movable guards, safety-function logic units, roll-over protective structures (ROPS), and falling-object protective structures (FOPS). A Part B product may use Module A (internal production control) only when category-specific harmonised standards or common specifications cover all relevant essential health and safety requirements (EHSRs) and were applied in design and construction.

Digital instructions can be used under the Regulation when the access route is marked and the user can print, download, save, and access them during a breakdown. They must remain accessible online for the product's expected lifetime and for at least 10 years after placing on the market. A purchaser can request paper instructions free of charge at the time of purchase, and the manufacturer must supply them within one month. For products intended for, or foreseeably usable by, non-professional users, essential commissioning and safe-use information must be supplied on paper.