--- title: "Directive 2006/42/EC to Machinery Regulation transition" canonical_url: "https://www.sorena.io/artifacts/eu/machinery-regulation/transition-from-directive-2006-42-ec" source_url: "https://www.sorena.io/artifacts/eu/machinery-regulation/transition-from-directive-2006-42-ec" author: "Sorena AI" description: "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." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Machinery Regulation" - "Regulation (EU) 2023/1230" - "Directive 2006/42/EC transition" - "machinery technical documentation" - "machinery digital instructions" - "machinery declaration of conformity" - "Directive 2006/42/EC" - "20 January 2027" --- **[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) --- # Directive 2006/42/EC to Machinery Regulation transition 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. *Artifact Guide* *EU* ## EU Machinery Regulation Transition from Directive 2006/42/EC Regulation (EU) 2023/1230 repeals Directive 2006/42/EC with effect from 20 January 2027 and applies from the same date. Use this guide to sort machinery and related-product pipeline decisions, update declarations and technical documentation, and review software, cybersecurity, digital instructions, standards, and partly completed machinery records before the changeover. The transition is not a simple certificate refresh. Each machinery model, related product, and partly completed machinery file needs a dated placement decision, a Directive 2006/42/EC or Regulation (EU) 2023/1230 conformity basis, and a record showing whether declarations, instructions, standards references, technical documentation, and software-related evidence are ready for 20 January 2027. ## Set the 20 January 2027 changeover baseline 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. - Classify each model as already placed on the EU market before 20 January 2027, planned for placement before that date, or planned for placement or putting into service from that date. - Keep the Directive 2006/42/EC evidence package for pre-20 January 2027 placement decisions, including the declaration, technical file, instructions, harmonised standards, and any EC type-examination certificate or approval decision. - For products crossing the changeover, record whether the declaration stays Directive-only, includes an additional Regulation (EU) 2023/1230 conformity statement before 20 January 2027, or moves to a Regulation-only conformity basis from 20 January 2027. - Use the corrected 20 January 2027 date consistently across repeal, transitional, application, declaration, standards, and technical-documentation planning. Sources for this answer: - [Regulation (EU) 2023/1230 on machinery](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Grounds the corrected 20 January 2027 repeal, transitional protection, and application baseline for the Directive-to-Regulation changeover. - [European Commission - Machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Grounds the Commission transition note that pre-20 January 2027 EU market placements must comply with Directive 2006/42/EC and may also state Regulation conformity where applicable. ## Update declarations, standards, and technical documentation 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. - Replace copied standards lists with a model-specific list showing each harmonised standard or common specification applied, whether it is applied fully or partly, and what other technical specification fills any gap. - Check whether the file uses Machinery Directive references, Annex ZA language, or declaration wording that must be mirrored, separated, or updated for Regulation (EU) 2023/1230. - For partly completed machinery, prepare Annex IV Part B technical documentation, assembly instructions, and an EU declaration of incorporation instead of treating the file as a finished-machine declaration package. - Keep technical documentation and the relevant declaration available for at least 10 years after placing on the market or putting into service, as applicable. Sources for this answer: - [Regulation (EU) 2023/1230 on machinery](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Grounds manufacturer obligations for Annex III EHSRs, Annex IV technical documentation, conformity assessment, EU declarations, CE marking, and 10-year document availability. - [European Commission - Machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Grounds the transition statement that manufacturers may state Regulation conformity on the EU Declaration of Conformity before 20 January 2027 if applicable. *Recommended next step* *Placement: after implementation section* ## Review your Machinery Regulation transition file Turn each machinery model's Directive 2006/42/EC file into a Regulation (EU) 2023/1230 transition record covering placement date, declaration wording, standards, technical documentation, digital instructions, and software evidence. - [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 product pipeline, technical-file gaps, declarations, standards, and digital-instruction plan. ## Review digital instructions, software, cybersecurity, and autonomous features 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. - Inventory every model with embedded software, downloadable configuration, safety-related software, remote operation, sensor-fed safety operation, autonomous behaviour, or digital updates after placement. - Update the risk assessment and EHSR checklist for digital changes that create a new hazard, increase an existing risk, or alter the protective measures relied on in the technical file. - Keep source-code or programming-logic access procedures ready for reasoned competent-authority requests, while limiting the record to what is necessary to check Annex III compliance. - Use cybersecurity and IT-security standards work as supporting engineering input where relevant, but do not treat cybersecurity references as a substitute for the Regulation's own EHSR, technical-documentation, and conformity-assessment evidence. Sources for this answer: - [Regulation (EU) 2023/1230 on machinery](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Grounds digital instructions, digital declarations, software/source-code access, digital substantial modification, and sensor-fed or autonomous machinery documentation requirements. - [ISO/TR 22100-4:2018](https://www.iso.org/standard/73335.html?ref=sorena.io) - Grounds the availability of machinery-safety guidance on IT-security and cybersecurity aspects related to ISO 12100. ## What to review before freezing the transition file 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. - Confirm whether the product is machinery, a related product, or partly completed machinery, and whether any more specific Union harmonisation legislation covers the same risk. - Compare the Directive 2006/42/EC technical file with the Regulation (EU) 2023/1230 Annex IV file structure and record every missing or changed item. - Check EC type-examination certificates and approval decisions issued under Directive 2006/42/EC for expiry and transition assumptions; Article 52 keeps them valid until they expire. - Review whether digital instructions, digital declarations, QR or internet-address access, translations, paper safety information for non-professional users, and 10-year online availability are implemented for the intended product and user group. - Escalate unresolved standards gaps, notified-body needs, safety-related software evidence, sensor/autonomous validation records, or substantial-modification conclusions before release approval. Sources for this answer: - [Regulation (EU) 2023/1230 on machinery](https://eur-lex.europa.eu/eli/reg/2023/1230/oj?ref=sorena.io) - Grounds Article 52 certificate continuity, Annex IV technical-documentation checks, and digital declaration and instruction review points. - [Directive 2006/42/EC on machinery](https://eur-lex.europa.eu/eli/dir/2006/42/oj?ref=sorena.io) - Legacy legal source for the Directive-side conformity file, declaration, technical documentation, instructions, and harmonised-standards position before the Regulation changeover. ## 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 the 20 January 2027 repeal/application baseline, transitional provisions, manufacturer obligations, declarations, digital instructions, technical documentation, software/source-code evidence, and partly completed machinery requirements. - Quote: "Directive 2006/42/EC is repealed with effect from 20 January 2027." - [Directive 2006/42/EC on machinery](https://eur-lex.europa.eu/eli/dir/2006/42/oj?ref=sorena.io) - Legacy Directive source for pre-20 January 2027 conformity files and declarations. - Quote: "on machinery" - [European Commission - Machinery sector page](https://single-market-economy.ec.europa.eu/sectors/mechanical-engineering/machinery_en?ref=sorena.io) - Commission source for machinery-sector transition context, mandatory application from 20 January 2027, and pre-changeover EU Declaration of Conformity handling. - Quote: "All machinery placed on the EU market before 20 January 2027 must comply with the current Machinery Directive 2006/42/EC." - [ISO/TR 22100-4:2018](https://www.iso.org/standard/73335.html?ref=sorena.io) - ISO source grounding cybersecurity and IT-security as machinery-safety engineering review inputs related to ISO 12100. - Quote: "Guidance to machinery manufacturers for consideration of related IT-security (cyber security) aspects" ## Related 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. - [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. - [What counts as machinery under Regulation (EU) 2023/1230?](/artifacts/eu/machinery-regulation/faq/machinery-definition.md): FAQ on the Machinery Regulation definition of machinery, including assemblies, drive systems, missing components, software, related products, partly completed machinery, safety components, and exclusions. - [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. --- [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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