Short answer
The EU Machinery Regulation (Regulation (EU) 2023/1230) applies from 20 January 2027 and replaces the Machinery Directive 2006/42/EC. Under Article 10(7), manufacturers may supply the instructions for use in digital format, on three conditions: the product says how to reach them, they can be printed, downloaded and saved, and they stay online for the expected lifetime of the product and at least 10 years. A buyer can still ask for a free paper copy at the time of purchase, delivered within one month. For machinery that non-professional users can reasonably use, the essential safety information must still be on paper.
This guide is for technical documentation, product and after-sales teams at machinery and equipment manufacturers and distributors. Every rule below comes from the text published in the Official Journal, with the article number, so you can check it yourself. Where the text is open to interpretation, we say so.
The last section is practical. It covers how to turn the digital manuals you will publish anyway into a searchable AI assistant for customers and service technicians, and what such an assistant cannot do under the Regulation. Heeya, which publishes this blog, is one tool that does this. We describe its limits as plainly as its features.
TL;DR
- Date: the Regulation applies from 20 January 2027 (Article 54, as corrected on 4 July 2023). Machinery placed on the market under the Directive before that date can still be sold (Article 52).
- Digital is allowed: instructions "may be provided in a digital format" (Article 10(7)). The Directive 2006/42/EC never mentioned a digital format.
- Three conditions: mark how to access them, make them printable and downloadable, keep them online for the product's expected lifetime and at least 10 years.
- Paper on request: free of charge, within one month, if the user asks at the time of purchase.
- Paper is still required for the essential safety information when non-professional users can reasonably use the machine.
- Pending change: the Omnibus IV package, which amends the Regulation, was provisionally agreed in June 2026 but is not yet adopted. Check the final text before you freeze your process.
- An AI assistant helps users find answers in your manuals. It does not replace the instructions the law requires.
Table of Contents
When the EU Machinery Regulation Applies
Regulation (EU) 2023/1230 on machinery was adopted on 14 June 2023 and published in the Official Journal on 29 June 2023 (OJ L 165). It is a regulation, not a directive: it applies directly in every Member State, with no national transposition. The full text is on EUR-Lex.
20 January 2027, not 14 January
The version first published said the Regulation would apply from 14 January 2027. A corrigendum published on 4 July 2023 (OJ L 169, p. 35) corrected the dates. Article 54 now reads: "It shall apply from 20 January 2027." The European Commission's machinery page uses the same date (checked October 2026). Some older articles still say 14 January. They are wrong.
Article 51 repeals the Machinery Directive with effect from the same date. A few provisions started earlier, under Article 54: the rules on notified bodies (Articles 26 to 42), the transitional provisions (Article 52), and some Commission and Member State duties, such as the rules on penalties. None of them concern the instructions for use. Article 10(7) applies from 20 January 2027.
Machinery already on the market
Article 52(1), as corrected, says Member States "shall not impede the making available on the market of products which were placed on the market in conformity with Directive 2006/42/EC before 20 January 2027". In practice, a unit placed on the market under the Directive in 2026 can still be sold by a distributor in 2027 with its Directive-era documentation. A unit placed on the market from 20 January 2027 must meet the Regulation.
The United Kingdom and Northern Ireland
The Regulation does not apply in Great Britain. The Supply of Machinery (Safety) Regulations 2008 remain the law there, and the UK government has consulted on a GB update (machinery safety call for evidence, updated February 2026). Under the Windsor Framework, Northern Ireland applies the new EU Machinery Regulation. A UK manufacturer that ships to the EU or Northern Ireland needs the EU rules described here.
What the Machinery Regulation Says About Digital Instructions
The core rule is in Article 10(7), the manufacturer's obligations. It opens with a simple permission:
"Manufacturers shall ensure that the machinery or related products are accompanied by the instructions for use and the information set out in Annex III. The instructions may be provided in a digital format. Such instructions and information shall clearly describe the product model to which they correspond."
The Machinery Directive 2006/42/EC did not mention paper, electronic or digital formats at all. This is the first time EU machinery law sets explicit conditions for digital instructions.
The three conditions for digital instructions
When the instructions are digital, Article 10(7) says the manufacturer shall:
- (a) Mark how to access them "on the machinery or related product, or, where that is not possible, on its packaging or in an accompanying document". A URL or a QR code on the rating plate is the usual answer.
- (b) Make them printable and saveable: "present them in a format that makes it possible for the user to print and download the instructions for use and save them on an electronic device so that he or she can access them at all times, in particular during a breakdown". This also applies when the instructions are embedded in the machine's software.
- (c) Keep them online "during the expected lifetime of the machinery or related product and for at least 10 years after the placing on the market".
Condition (b) matters for anyone tempted by a web-only experience. A help page that works only online, or a viewer that blocks download, does not meet it. The user must be able to keep a copy that works when the machine is down and the network is not there.
Paper copies and safety information on paper
Two sentences in Article 10(7) limit the digital option:
"However, at the request of the user at the time of the purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month."
"In the case of machinery or a related product intended for non-professional users or that can, under reasonably foreseeable conditions, be used by non-professional users, even if not intended for them, the manufacturer shall provide, in paper format, the safety information that is essential for putting the machinery or related product into service and for using it in a safe way."
Recital 40 adds that the manufacturer "should ensure that distributors can provide" the paper instructions at the time of purchase, and "should also consider" giving contact details where users can ask for them by mail.
Languages, declarations of conformity and other operators
- Language (Article 10(7)): the instructions, the safety information and the Annex III information "shall be in a language which can be easily understood by users, as determined by the Member State concerned". Each Member State decides. Digital format changes nothing here.
- Maintenance by specialised staff (Annex III, section 1.7.4): maintenance instructions for specialised personnel mandated by the manufacturer may be in only one official EU language that those staff understand.
- Declaration of conformity (Article 10(8)): it can be replaced by an internet address or machine-readable code in the instructions. A digital declaration must stay online for the expected lifetime and at least 10 years.
- Partly completed machinery (Article 11(7)): the same logic applies to assembly instructions: marking, printable and downloadable, online for at least 10 years, free paper within one month on request at purchase.
- Importers (Article 13(4)) must ensure the product comes with the instructions referred to in Article 10(7). Distributors (Article 15(2)(c)) must check, before selling, that the instructions are there and in a language users of their Member State can easily understand.
| Requirement | What the text says | Where |
|---|---|---|
| Digital instructions | Allowed. Must describe the product model they correspond to. | Art. 10(7) |
| Access | Marked on the product, or on packaging or an accompanying document. | Art. 10(7)(a) |
| Format | Printable, downloadable, saveable. Also for instructions embedded in software. | Art. 10(7)(b) |
| Availability | Online for the expected lifetime and at least 10 years after placing on the market. | Art. 10(7)(c) |
| Paper on request | If asked at the time of purchase: free of charge, within one month. | Art. 10(7) |
| Paper safety information | Mandatory when non-professional users can reasonably use the machine. | Art. 10(7) |
| Language | Easily understood by users, as decided by each Member State. One-language exception for specialised maintenance staff. | Art. 10(7), Annex III 1.7.4 |
| Distributor check | Instructions present and in the right language before sale. | Art. 15(2)(c) |
What the Machinery Regulation Leaves Open, and the Pending Omnibus IV Change
The Regulation is clear on the principle. Several details are not settled by the text alone. The points below are our reading of the published text, not legal advice. Check them with your notified body, your legal team or the market surveillance authority of the country concerned.
Points the text does not settle
- "At the time of the purchase." Article 10(7) gives a right to free paper when the user asks at purchase. It does not say whether a request made weeks later must also be met for free. Many manufacturers will accept late requests anyway, to avoid disputes.
- "Essential" safety information. The text does not list what counts as essential for putting into service and safe use. Your risk assessment and the residual risks listed under Annex III, section 1.7.4.2, are the logical starting point.
- "Reasonably foreseeable" non-professional use. A machine sold for professionals but also bought online by private users may fall under the paper rule. The text covers machinery "even if not intended for them". Where the line sits for your products is a judgement call.
- "Expected lifetime." The Regulation does not give a number. The online period is the longer of the expected lifetime and 10 years, so for a machine designed to run 20 years, plan for 20.
- Which languages. Each Member State decides. For countries with more than one official language, check national rules before you publish.
Omnibus IV: an amendment that is not yet law
In May 2025 the Commission proposed the "Omnibus IV" package on digitalisation and common specifications, COM(2025) 504. It amends several product laws, including Regulation (EU) 2023/1230. For machinery, the Commission's proposal mainly makes the EU declaration of conformity digital: the product would carry an internet address or machine-readable code instead of a paper copy.
The European Parliament's Legislative Observatory file 2025/0134(COD) (checked October 2026) shows a provisional agreement approved in committee on 14 July 2026, a status of "awaiting Parliament's position in 1st reading", and an indicative plenary date of 23 November 2026. In February 2026, machinery industry associations, CEMA among them, reported that Parliament's position would let users ask for paper instructions for longer after purchase. The agreed wording has not been published in the Official Journal yet.
What this means for you: the principle of digital instructions will not go away. The paper-on-request details may change before or soon after 20 January 2027. Build a paper request process that can adapt, and re-read the final text once it is published.
The General Product Safety Regulation, briefly
The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024 to products intended for, or likely to be used by, consumers. For products covered by sector law such as the Machinery Regulation, most of its manufacturer obligations do not apply (Article 2(1)). The distance-sales rule in Article 19 still does: an online offer must show "any warning or safety information" that goes with the product, in a language consumers understand. If you or your distributors sell consumer-reachable machinery online, the product page must carry those warnings. Your digital manual link alone is not enough.
What the Machinery Regulation Changes for Technical Documentation Teams
Digital instructions save print and shipping costs. They also turn the manual into a service you must run for 10 years or more. Here is what that means in practice for a technical documentation team.
Publishing and hosting
- Stable addresses. The URL or QR code printed on a machine in 2027 must still work in 2037 or later. Use a domain and path you control, and never let a website redesign break it.
- One file per model and version. Article 10(7) requires the instructions to "clearly describe the product model to which they correspond". Archive every version that shipped, and make it easy to find the one that matches a serial number or year of construction.
- A real download. Offer a PDF or another format that prints well and opens offline. An HTML portal is fine as an extra, not as the only copy.
- Software-embedded instructions on the machine's control panel must also be printable and downloadable (Article 10(7)(b)).
Paper processes you still need
- A paper request channel for buyers, ideally through your distributors, with a one-month delivery target and no charge.
- A paper safety leaflet for any machine that non-professional users can reasonably use, covering putting into service and safe use.
- A language matrix per country, kept in sync between paper leaflets and digital manuals.
Distributors and after-sales
Distributors must verify the instructions before selling (Article 15(2)(c)). Give them a kit: the access link or QR code per model, the list of languages available, and the paper request process. Your after-sales team is affected too. Once manuals are online, customers and field technicians expect to search them, not to scroll through 180 pages of PDF on a phone. That is where a search layer on top of the manuals becomes useful.
Turning Digital Manuals into a Searchable AI Assistant
Once your instructions are digital, the next step is to make them answerable. An AI assistant built on retrieval-augmented generation (RAG) takes your manuals, splits them into passages, and indexes them. When a user asks "how do I reset the pressure alarm on the X200?", it finds the matching passages and writes a short answer from them. Our guide to retrieval-augmented generation for businesses explains the mechanics.
Where it helps after-sales teams
- On the product page or support site, next to the download link, for customers who want one answer, not a full manual.
- On the page behind the QR code, so a user scanning the rating plate gets both the PDF and a way to ask a question.
- For your own technicians and distributors, who answer the same questions on error codes, maintenance intervals and spare part references every week.
- As a writing backlog: questions the assistant cannot answer show where the manual is unclear or incomplete.
What an AI assistant does not do
Be clear about this with your legal team and your customers:
- It does not replace the instructions for use the law requires. The printable, downloadable manual, the paper safety information and the paper copy on request still have to exist. A chat window is not "the instructions" under Article 10(7).
- Answers come only from the documents you load. If a manual is outdated, or two versions of the same manual are both loaded, the answers will be outdated or mixed. Retrieval reduces invented answers, it does not make them impossible. Our guide to AI chatbot hallucinations and guardrails covers the failure modes.
- It needs a network connection. It cannot replace the saved copy a user needs during a breakdown.
- For safety-critical steps, such as lockout procedures, guard removal or pressure release, configure it to point to the relevant section of the manual rather than rephrase it.
Heeya as one way to do it
Heeya's AI chatbot for product documentation is one way to set this up without a development project. Here is what it does and does not do, based on the product as of October 2026:
- Sources: upload PDF, Word (.docx), PowerPoint (.pptx) and text files, scrape selected pages of your support site, and add question and answer pairs (also from Excel or CSV). The website crawler skips PDF attachments, so you upload manuals as files.
- Text only: Heeya reads the text layer of a PDF. It does not read drawings, exploded views or scanned pages without text. Wiring diagrams and part drawings stay in the manual.
- Languages: French and English only. If your users in Germany, the Netherlands or the Nordics need answers in their own language, Heeya is not the right tool for them today.
- Delivery: a widget you paste on your site, or a full-page assistant link you can put behind a QR code. A contact form tool can collect the user's details when the manual does not answer the question. Heeya is not a helpdesk or a live-chat inbox.
- Review: conversations appear in Analytics, with an answer reliability score that flags replies probably not based on your documents. It is an estimate to guide your reading, not a guarantee.
- Updates: when a manual changes, you replace the file. Nothing syncs on its own.
- Data: Heeya stores conversations and knowledge bases in the EU (OVH, France); message content is sent to AI providers (Google, OpenAI) that may process it outside the EU under standard contractual clauses or the Data Privacy Framework, with no training on your data. A signed processing addendum is available on request.
- Price: Standard at €19 per month (500 AI replies) and Premium at €99 per month (2,500 AI replies), with a 7-day free trial, no credit card. Current details are on the Heeya pricing page.
Before you load anything, prepare the corpus: one current file per model, no retired versions, clear file names with model and edition. Our guide on knowledge base engineering for AI chatbots covers versioning and chunking in detail, and the knowledge base chatbot guide explains how to compare tools. For GDPR questions on chat data, see the GDPR-compliant AI chatbot guide.
| Need | Required by the Regulation? | Covered by an AI assistant? |
|---|---|---|
| Printable, downloadable manual per model | Yes, if digital (Art. 10(7)(b)) | No. You still publish the file. |
| Online access for lifetime and 10+ years | Yes (Art. 10(7)(c)) | No. That is your hosting. |
| Paper safety information for non-professional users | Yes (Art. 10(7)) | No. |
| Quick answers on error codes, settings, maintenance | No | Yes, from the manuals you load. |
| Spotting gaps in the manual | No | Yes, through unanswered questions. |
| Collecting a service request when the manual has no answer | No | Yes, with a contact form. |
FAQ: EU Machinery Regulation and Digital Instructions
When does the EU Machinery Regulation 2023/1230 apply?
It applies from 20 January 2027 under Article 54, as corrected by the corrigendum of 4 July 2023. The first published version said 14 January 2027. From that date it replaces the Machinery Directive 2006/42/EC. Machinery placed on the market under the Directive before 20 January 2027 can still be made available afterwards (Article 52).
Can machinery instructions be supplied only in digital format?
Yes, with conditions. Article 10(7) allows digital instructions if the product shows how to access them, they can be printed, downloaded and saved, and they stay online for the expected lifetime and at least 10 years. Two exceptions remain: a free paper copy on request at purchase, and paper safety information when non-professional users can reasonably use the machine.
Does a buyer have the right to a free paper manual?
Yes, if the user asks at the time of the purchase. The manufacturer must then provide the instructions in paper format free of charge within one month (Article 10(7)). The text does not say whether later requests must also be met for free. The pending Omnibus IV amendment may change these details, so check the final text once it is published.
How long must digital machinery instructions stay online?
During the expected lifetime of the machinery and for at least 10 years after it is placed on the market (Article 10(7)(c)). The Regulation does not define the expected lifetime in years, so the manufacturer sets it. For a machine designed to last 20 years, the instructions must stay online for 20 years.
In which language must machinery instructions be written?
In a language easily understood by users, as determined by the Member State where the machine is made available (Article 10(7)). Distributors must check this before selling (Article 15(2)(c)). Annex III, section 1.7.4, allows maintenance instructions for specialised staff mandated by the manufacturer to be in one official EU language those staff understand.
Can an AI chatbot replace the instructions for use?
No. The Regulation requires instructions that users can print, download and keep, plus paper safety information in some cases. An AI assistant built on your manuals is an extra layer that helps customers and technicians find answers quickly. Its answers come only from the documents you load, so the manuals themselves must stay complete and current.
Does the EU Machinery Regulation apply in the UK?
Not in Great Britain, where the Supply of Machinery (Safety) Regulations 2008 still apply. Northern Ireland applies the EU Machinery Regulation under the Windsor Framework. UK manufacturers who sell into the EU or Northern Ireland must follow the EU rules.
Sources: Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, and its corrigendum, OJ L 169, 4.7.2023; Regulation (EU) 2023/988, OJ L 135, 23.5.2023; Commission proposal COM(2025) 504; European Parliament procedure 2025/0134(COD). All checked October 2026. This article is general information, not legal advice.
