May I supply the instructions for use purely digitally from 2027?
Yes. Under Machinery Regulation (EU) 2023/1230 digital instructions for use are the permitted standard form, but tied to conditions: available online for at least ten years, access via QR code or URL on the machine, downloadable, printable and storable. Buyers can request a printed version free of charge within twelve months, to be supplied within thirty days. For non-professional users, paper remains mandatory.
Which conditions must the digital instructions meet?
Which requirements does the QR code on the machine have to meet?
Do I still have to supply paper instructions?
What changes compared with the Machinery Directive?
| Aspect | Machinery Directive 2006/42/EC | Machinery Regulation (EU) 2023/1230 |
|---|---|---|
| Standard form | Paper | Digital permitted |
| Availability | Not regulated | At least ten years online |
| Access | Enclosed | QR code or URL on the machine |
| Paper on request | Not regulated | Free of charge, for twelve months, delivery within thirty days |
| Consumers | Paper | Paper remains mandatory |
| Safety information | Paper | Paper remains mandatory |
What is the practical benefit for machine manufacturers?
The obvious advantage is that printing and shipping costs fall away. The bigger lever, though, is currency: corrections and additions reach the user immediately, without a reprint having to be delivered.
Against that stands a new continuing obligation. Anyone delivering digitally has to keep the instructions online for ten years, for every machine generation delivered, with a stable URL and without gaps when servers change or the website is relaunched.
Plan that availability like a product characteristic, not like a marketing page. A relaunch of the company website that breaks old URLs is a conformity problem under the Machinery Regulation.
Sources and standards
- Machinery Regulation (EU) 2023/1230, Art. 10(7), digital provision
- Machinery Regulation (EU) 2023/1230, Annex III: instructions for use
- EN ISO 20607: instruction handbook, general drafting principles
Editions of standards and their harmonised status change continuously. Check standard numbers and editions against the current list in the Official Journal of the EU before applying them. This article is a technical classification and does not replace legal advice.
Frequently asked questions
How long do the digital instructions have to be available online?
At least ten years from placing the machine on the market.
Is a link to cloud storage enough?
Technically possible, practically risky. The URL has to stay stable for ten years, and access must not require registration or acceptance of terms of use. Your own permanently controlled address is the safer route.
May I print the QR code on the packaging instead of on the machine?
No. The access has to be attached to the machine itself. Packaging is disposed of; the machine stays in use for decades.
What happens if a customer requests printed instructions after fourteen months?
The claim to a free printed version exists within twelve months of purchase. After that it no longer exists. You may then offer the instructions against payment.
Does this also apply to machinery placed on the market before 2027?
No. What counts is the moment of placing on the market. Machinery placed on the market before 20 January 2027 continues to be documented under the Machinery Directive.
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This article was produced with AI assistance and reviewed for technical accuracy before publication. Editorial responsibility within the meaning of Art. 50(4) of the AI Act (EU) 2024/1689 lies with Heinrich Knutas.
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