Regulation (EU) 2023/1230 allows machinery instructions for use in digital format for the first time. The conditions are in Art. 10(7). We go through them one by one here; the general comparison with the old directive is in the article Directive vs Regulation: the differences.
What Art. 10(7) says
When instructions are supplied in digital format, the manufacturer must:
- indicate on the machine or product, or in an accompanying document, how to access the digital instructions;
- provide them in a format that allows the user to download them, save them on an electronic device and print them;
- keep them accessible online during the expected lifetime of the machine and for at least 10 years after it is placed on the market.
At the user's request at the time of purchase, the manufacturer supplies the instructions in paper format free of charge within one month.
The QR code: one way to indicate access
The Regulation does not require a specific tool. A QR code on the machine is a practical way to show where to find the instructions: whoever works on the machine scans it with a smartphone and opens the documents for that model.
The 10 year problem
A QR code pointing to a PDF on a company website works as long as the website stays the same. Changes of domain, site structure or provider can break the link. That is why it helps if the QR stays stable over time and the content can be updated without reprinting the label.
How QRcube® handles it
QRcube® is a container for files of any type, with preview and folder navigation, reachable from a QR. It can be distributed as public or private, with expiry and password. When a document is updated a new version is created and previous ones remain stored and restorable. QRcube® supports the management and storage of the digital documentation provided for by the Regulation; responsibility for the content remains with the manufacturer.
Sources
- Regulation (EU) 2023/1230, Art. 10(7) and Annex III, point 1.7.4
- European Commission, machinery sector page
For the declaration of conformity and the technical file, read EU declaration and technical file in digital form.
