For more than fifteen years, machinery manufacturers have worked under Directive 2006/42/EC. From 20 January 2027 it is replaced by Regulation (EU) 2023/1230. This article compares the two texts. For a full overview of the Regulation, see the Machinery Regulation guide.
From directive to regulation
A directive must be transposed by each Member State through national law; in Italy Directive 2006/42/EC was transposed by Legislative Decree 17/2010. A regulation applies directly throughout the Union, without transposition. Recital 4 of the Regulation gives the reason: avoiding divergent implementation between Member States.
Key dates
- 29 June 2023: publication in the Official Journal of the European Union, OJ L 165.
- 19 July 2023: entry into force (Art. 54).
- 20 January 2027: general application and repeal of Directive 2006/42/EC (Arts. 52 and 54). Some provisions, for example on notified bodies and national penalties, apply earlier.
Point by point comparison
| Topic | Directive 2006/42/EC | Regulation (EU) 2023/1230 |
|---|---|---|
| Legal form | Transposed through national laws | Directly applicable |
| Instructions for use | Normally on paper | Digital format allowed (Art. 10(7)) |
| Paper copy | No request mechanism | Free of charge, within one month, if requested at the time of purchase |
| Online access | Not regulated | For the expected lifetime and at least 10 years after placing on the market |
| Substantial modifications | Not defined in the text | Whoever makes them is considered a manufacturer (Art. 18) |
| High risk machinery | Annex IV | Annex I, parts A and B |
| Structure | 29 articles, 12 annexes | 54 articles, 11 annexes |
Digital instructions: the most visible change
Art. 10(7) allows instructions to be supplied in digital format. The manufacturer must indicate how to access them, make them downloadable and printable, and keep them accessible online for the expected lifetime and at least 10 years. The practical details, including the QR code on the machine, are in the article on digital instructions and QR codes.
Substantial modifications
Art. 18 states that anyone who makes a substantial modification to a machine is considered a manufacturer and takes on the obligations of Art. 10. Anyone working on machines already in service should therefore keep track of every intervention and its documentation.
What about machines already on the market?
The Regulation covers products placed on the market or put into service from 20 January 2027. Machines placed on the market earlier under the Directive do not need to be recertified, unless substantially modified.
Sources
- Regulation (EU) 2023/1230, official text on EUR-Lex
- Directive 2006/42/EC, official text on EUR-Lex
- European Commission, machinery sector page
For the concrete steps to take before the deadline, read the manufacturer checklist.
