Digital instructions under the Machinery Regulation: what applies from 20 January 2027 and why your website becomes part of the machine

On 20 January 2027, Regulation (EU) 2023/1230 replaces the Machinery Directive. One of its most visible changes concerns not the design but the binder that used to come with every machine: the instructions for use may now be provided digitally. For machine builders that sounds like lower printing costs, faster translations and fewer versions in circulation.

The regulation attaches a condition to this that appears in no printing budget, though. Anyone who prints an address on a machine has to make sure it works for that machine’s entire lifetime, for at least ten years. That makes the company website part of product compliance, across every future relaunch, system migration and domain change. This article sets out from when digital instructions are allowed, what Germany’s implementing act says about language and fines, and what follows for the website and its operation.

From when may instructions for use be digital?

For machinery placed on the market or put into service from 20 January 2027. On that day the regulation applies and Directive 2006/42/EC is repealed (Article 51(2) and Article 54, each as amended by the corrigendum of 4 July 2023). The first publication in the Official Journal still read 14 January 2027; the corrigendum moved the date to 20 January. Whatever is placed on the market before then falls under the old law, instructions included.

The Directive requires in Annex I section 1.7.4 that all machinery be accompanied by instructions in the official language of the Member State where it is placed on the market or put into service, as “Original instructions” or as a “Translation of the original instructions”, which then has to be accompanied by the original. It does not expressly regulate digital provision. On its machinery page, the European Commission is explicit: all machinery placed on the EU market before 20 January 2027 must comply with the Directive. Manufacturers may only state in addition on the declaration of conformity that the machine also conforms with the regulation.

Germany adds a naming trap: the national transposition of the Directive is also called Maschinenverordnung, the Ninth Ordinance to the Product Safety Act of 12 May 1993. Under Article 2 of the Act reorganising machinery law it expires at the end of 19 January 2027. Machinery that complies with it and is placed on the market before then may continue to be made available (section 11 MaschinenDG).

In practice the cut-off attaches to the individual machine, not the catalogue. Anyone switching their documentation at the turn of the year needs to know which machines will still be placed on the market before 20 January, which usually means delivered. For those, instructions accompanying the machine remain mandatory.

What three conditions does Article 10(7) set?

They apply together, and none can replace another. Under the second subparagraph of Article 10(7), a manufacturer providing the instructions digitally has to:

1. indicate how to access the instructions, on the machine itself, and only where that is not possible on its packaging or in an accompanying document. The regulation prescribes no particular means. A QR code is the obvious choice, but a short address on the rating plate meets the wording just as well. The text mentions a machine-readable code expressly only for the declarations of conformity and incorporation.
2. provide a format that allows printing, downloading and saving, so the user can access the instructions at all times, in particular during a breakdown of the machine. This expressly also applies to instructions embedded in the machine’s software. Help on the control panel without an export function, or an online viewer without a download, does not meet the condition.
3. keep the instructions accessible online during the expected lifetime of the machine and for at least ten years after it is placed on the market. Under Article 3(34), lifetime runs until disposal and includes the phases foreseen by the manufacturer, such as transport, assembly, dismantling, decommissioning and physical or digital modification.

On top of that comes a requirement from the first subparagraph that is easy to miss: the instructions must clearly describe the product model to which they correspond. Anyone revising instructions over the years therefore needs an archive in which every machine finds the version that belongs to it, not just the latest one.

A worked example shows how long the third condition really is. The period runs for each machine individually from its placing on the market. A manufacturer who ships a series from 2027 to 2035 and expects a lifetime of twenty years is promising that the instructions for the last machine remain available until about 2055.

When do the instructions still have to be on paper?

In two cases. If the user asks for paper at the time of purchase, the manufacturer must provide it free of charge within one month (third subparagraph of Article 10(7)). And for machinery intended for non-professional users, or that can be used by them under reasonably foreseeable conditions, the safety information essential for putting the machine into service and using it safely always has to be on paper (fourth subparagraph).

Both rules have a subtlety. The right to paper is tied to the time of purchase; anyone asking two years later has, on the wording, no right to a free paper copy, though they do have the online version. For the safety information, by contrast, it is not the sales target group that decides but foreseeable use, expressly even where the machine is not intended for non-professionals. A workshop machine freely available in retail can therefore cross that threshold even if no brochure addresses private buyers.

Recital 40 adds an organisational expectation: the manufacturer should make sure that distributors, too, can provide a free paper copy on request at the time of purchase, and should consider giving contact details for ordering one by post. Anyone selling through distributors therefore needs a process that starts at the distributor and a print master ready for every version shipped.

What language do instructions have to be in for Germany?

German. The regulation leaves the language to each Member State (last subparagraph of Article 10(7)). Germany has set it in section 2 of the Act implementing the Machinery Regulation (Maschinenverordnung-Durchführungsgesetz, MaschinenDG): the instructions together with the Annex III information, the safety information and the EU declaration of conformity must be drawn up in German. Where the instructions are provided digitally, the same applies to the notice on the machine explaining how to access them.

The MaschinenDG is Article 1 of the Act reorganising machinery law of 2 December 2025, promulgated on 5 December 2025 in Federal Law Gazette 2025 I No. 302 and in force since 6 December 2025. Like the fines, the language rule only applies from 20 January 2027 (section 12).

The regulation itself contains one exception: maintenance instructions intended for specialised personnel mandated by the manufacturer or its authorised representative may be supplied in only one official language of the Union which those personnel understand (Annex III section 1.7.4). It does not cover anything the operator and its staff read.

One simplification is easy to miss. The regulation no longer knows the “Original instructions” label or the duty to enclose the original with a translation; the term appears in neither the German nor the English official text. For exporters that does not mean fewer languages. Each Member State sets its own, importers must ensure the instructions accompany the machine (Article 13(4)), and distributors check before selling that they are in the language of the country (Article 15(2)(c)).

What does a breach cost? The fines under the MaschinenDG

Up to 10,000 euros per administrative offence, for example when the German instructions, the safety information or the German declaration of conformity are missing. Section 9(2) MaschinenDG provides for up to 100,000 euros in only three cases, and none of them concerns documentation: failure to take corrective action, and machinery that an importer places on the market or a distributor makes available even though it considers it non-conforming or has reason to. The fines apply from 20 January 2027.

Section 10 turns these three cases into a criminal offence where an intentional act is persistently repeated or endangers life, health or third-party property of significant value: imprisonment of up to one year or a fine. From the cut-off date, market surveillance authorities must also check by means of samples (section 4).

What is missing from the list is worth noting. The duty to keep the digital instructions online and the right to paper at purchase sit in the second and third subparagraphs of Article 10(7). Section 9, however, only covers the first sentence of the first subparagraph and the fourth subparagraph, meaning the accompanying German instructions and the safety information. A switched-off instructions page is still not without consequence. In our reading it is an unmet administrative requirement under Article 10 and thus a formal non-compliance under Article 46(1)(g). The authority then requests a remedy; if the shortcoming persists, it can restrict or prohibit making the machine available and order a recall (Article 46(3)). On the same reading Article 10(9) applies: a manufacturer who knows its instructions can no longer be retrieved must take corrective action without delay, and failing to do so is the offence carrying up to 100,000 euros. In that scenario the measure itself would cost more than any fine.

May the EU declaration of conformity be digital too?

Yes. Under Article 10(8), instead of enclosing the declaration, the manufacturer may give the internet address or a machine-readable code where it can be accessed, in the instructions; Annex III section 1.7.4.2(c) then lists that information expressly as content of the instructions. The digital declaration must remain online for the expected lifetime of the machine and in any event for at least ten years after it is placed on the market or put into service, in German for Germany (section 2(1) no. 3 MaschinenDG).

Two details belong in every implementation. Under Article 21(2) the declaration must be kept up to date at all times, and under paragraph 3 a machine subject to several EU acts requiring a declaration of conformity gets a single declaration covering all of them. For partly completed machinery, assembly instructions and declarations of incorporation follow the same pattern (Article 11(7) and (8)), with one difference in wording: there the regulation requires ten years from placing on the market, with no reference to a lifetime.

Why your website becomes part of the machine

Because the address on the machine has to work for as long as the machine itself, regardless of what happens to the website, the domain, the content management system and the company in the meantime. Each of these changes can break a printed address, and so far none of them appears in the requirements for technical documentation.

The breaking points are familiar from website projects. Until now their consequences were a marketing matter: a lost ranking, a dead link in a brochure. From 2027 the same cause can breach an obligation under Article 10.

A case from our own operations shows how different the standards are. In September 2026 we renamed one of our service pages and permanently redirected the old address. For search engines that is enough. For an address stuck on a machine, “permanent” means something else: the redirect has to survive every future relaunch, so it belongs in the specification of every successor project.

A simple rule for management follows from this: the access address for instructions belongs not to marketing but to product responsibility. It is set like an article number and changed like a released drawing, never in passing. If a relaunch is due anyway, that is the right moment to fix the path. What a relaunch costs and how long it takes is covered in our article on the cost of a B2B website; how we deliver such projects is described on our page on web design and development for mid-sized companies.

What changes with the Cyber Resilience Act from December 2027?

For machinery with digital elements a second clock starts on 11 December 2027. Under Article 13(18) of the Cyber Resilience Act, Regulation (EU) 2024/2847, the manufacturer must provide the information and instructions to the user set out in Annex II in paper or electronic form and keep them available for at least ten years after placing on the market or for the support period, whichever is longer. Where they are provided online, they must be accessible, user-friendly and available online for the same period.

That means two clocks are running. The Machinery Regulation counts the lifetime of the machine and at least ten years, the CRA ten years or the support period for security updates. Anyone planning a portal plans it for the longer of the two. How the two regulations interact at the interface is covered in our article Machinery Regulation meets Cyber Resilience Act.

Digital or paper: what should the decision rest on?

First, a clarification: the regulation allows the digital format, it does not require it. Staying with paper breaches nothing. In our assessment, four questions help with the decision per product line.

• How many languages and variants do you ship? The more countries and versions, the bigger the gain, because a change is published once instead of being carried into every print run.
• How often do your instructions change? For machinery with regular software updates, paper ages faster than the machine. When an update itself becomes a substantial modification is covered in our article on software updates under the Machinery Regulation.
• Can non-professional users get hold of your machines? Then part of the documentation stays on paper anyway, and the advantage shrinks.
• Who will run the portal in fifteen years? If nobody has an answer, paper is the more honest solution until someone does.

The roadmap to 20 January 2027

1. Decide and record per product line whether instructions come digitally, on paper or both from the cut-off date, and which machines will still be placed on the market before it.
2. Fix the access address: a dedicated domain or subdomain, stable identifiers per model and version, independent of the website’s content management system.
3. Design the access notice: on the machine itself, in German and in the languages of the destination countries, with the address in plain text next to a QR code.
4. Check the format: a complete download, printable and storable; instructions embedded in the control panel need an export function.
5. Set up the paper route: requests at purchase, including through distributors, printing and dispatch within one month, safety information on paper for machinery that non-professional users can use.
6. Include the declaration of conformity: enclosed or accessible via address or code, in German, one declaration for all applicable acts.
7. Organise operation for decades: a responsible owner, automated checks of every printed address, domain renewal, a plan for a change of name or a sale, and for machinery with digital elements the support period under the CRA.

What is still open as of 14 October 2026

Three points are unsettled, and they belong in any honest advice. First, there is no Commission application guide to the regulation yet; on 14 October 2026 its machinery page still lists only guides to the Directive, including the application guide edition 2.3 of April 2024. Second, the wording does not say whether registration may be required before access. We advise against it, because the instructions must be reachable at all times and especially during a breakdown, and forgotten login details are one more obstacle in a fault situation. Third, our classification of a switched-off instructions page as formal non-compliance is an interpretation; there can be no enforcement practice before the cut-off date. Anyone who sets up a stable path today and documents it is prepared for each of these answers.

Frequently asked questions about digital instructions