EU Machinery Regulation Transition from Directive 2006/42/EC

The corrected Machinery Regulation baseline is 20 January 2027. Article 51 repeals Directive 2006/42/EC with effect from that date, Article 54 makes Regulation (EU) 2023/1230 apply from that date, and Article 52 protects products placed on the market in conformity with Directive 2006/42/EC before that date from being blocked for the aspects covered by the Regulation.

Build the transition register around the placement date, not only the shipment or project date. The Commission machinery page states that machinery placed on the EU market before 20 January 2027 must comply with the current Machinery Directive 2006/42/EC and may also state conformity with Regulation (EU) 2023/1230 on the EU Declaration of Conformity where applicable.

From the Regulation side, manufacturers of machinery and related products must draw up Annex IV Part A technical documentation, run or obtain the relevant conformity assessment, draw up the EU declaration of conformity, and affix CE marking when compliance with Annex III essential health and safety requirements has been demonstrated.

The transition review should therefore compare the Directive file against the Regulation file item by item. Annex IV Part A calls for a complete product description, intended use, risk assessment, applicable EHSR list, protective measures and residual risks, drawings and explanations, applied harmonised standards or common specifications, test and inspection evidence, production conformity measures, instructions, incorporated-product declarations, and software or sensor/autonomous-system information where applicable.

The Regulation adds transition work for digital product records. Instructions for machinery and related products may be provided in digital format, but the file must show how users access them, that users can print, download, save, and access them during breakdowns, and that online access is maintained for the expected lifetime and at least 10 years after placing on the market. Non-professional-user safety information still needs paper-format handling under the Regulation.

Software and data-driven functions also need a documented review. The Regulation defines safety components to include digital components and software, defines substantial modification to include physical or digital changes, requires source code or programming logic for safety-related software in the technical documentation where needed for authority checks, and asks for system characteristics, limitations, data, development, testing, and validation descriptions for sensor-fed, remotely driven, or autonomous machinery where safety-related operations are controlled by sensor data.

A useful transition file should let a reviewer trace one product from scope to market placement to evidence. The minimum review is the product identity, role, market placement date, applicable legal basis, EHSR mapping, standards position, conformity route, declaration wording, instructions format, software and digital-change position, and open actions before 20 January 2027.

For pipeline and legacy products, preserve the reason why the Directive file remains sufficient or why a Regulation update is needed. For new or changed products, close the gaps that affect the Regulation file before release: missing Annex IV evidence, stale standards references, incomplete digital instruction access, unsupported dual conformity statements, absent partly completed machinery assembly instructions, or software evidence that cannot be produced if a competent authority asks for it.