From 14 January 2027 it is no longer the Directive that applies.
Regulation (EU) 2023/1230 replaces the Machinery Directive on 14 January 2027, and the two regimes do not overlap. Most people get round to reading it when the first customer asks what they are doing about it. Here is what changes — and what you can check yourselves, without hiring anyone.
The Machinery Directive applies up to and including 13 January 2027. There is no overlap.
Three things worth knowing before anyone asks.
Each point carries its source. What binds is the text of the Regulation itself — we do not put requirements in print that we cannot point you to.
The two regimes do not overlap
The Machinery Directive applies up to and including 13 January 2027. The day after, the Regulation applies to new machinery. There is no year in which you may choose between the two, as other changeovers have allowed. The Regulation does have transitional provisions, but they concern machinery already placed on the market, not a choice for new machinery.
Source: Regulation (EU) 2023/1230, Article 54 (applies from 14 January 2027), Article 51(2) (repeal of Directive 2006/42/EC) and Article 52 (transitional provisions).
The machines you already have are not affected
What matters is when the machine was placed on the market. If that happened before 14 January 2027, it does not have to be re-certified because the Regulation takes effect. EC type-examination certificates issued under the Directive remain valid until they expire.
Source: Guidance on the Machinery Regulation, Danish Safety Technology Authority.
Software and rebuilds are now in scope
Software that affects safety counts as a safety component, and digital risks are written in. A substantial modification of a machine — including a change to its control system — can make it a new machine in the Regulation’s sense. Instructions may be supplied digitally.
Source: Regulation (EU) 2023/1230, as reported by the Danish Safety Technology Authority and Pilz.
The paperwork is rarely the problem.
When a machine causes trouble at an inspection or a customer audit, it is almost never because the risk assessment is missing. It exists. It was made when the machine was installed, and it sits where it is supposed to sit.
The problem is that the machine has become a different machine since. A guard was moved because it was in the way. The control system was updated during a service visit. A pallet lifter was bolted on because it made sense that week. None of it went through change control, because there was no change control to go through.
The Regulation makes that gap more expensive. A substantial modification can make the machine a new machine, and then the responsibility is yours — not the builder’s. This is not a documentation task. It is a question of whether anyone notices that something has changed.
It is the same pattern as everything else we work on: the system exists on paper but is not carried by the operation. The difference here is that this one comes with a date.
Five questions you can ask yourselves today.
They need no consultant and take a morning. The answers tell you more about where you stand than reading the Regulation does.
When was the risk assessment last changed, and what prompted the change?
Passed: There is a date, and there is an occasion: an incident, a rebuild, a new operator. A risk assessment untouched since the machine was installed is a document, not an assessment.
The Regulation tightens the requirements on documentation. But what goes wrong in practice is not that the assessment is missing — it sits on a drive. It is that reality moved on without it.
Who notices when a machine has been rebuilt?
Passed: You can point to a person and a routine. “We would hear about it” is not a pass.
A substantial modification can make the machine a new machine in the Regulation’s sense. That rarely happens through a decision anyone writes down — it happens because someone solved a problem on the floor on a Friday.
Does the technical documentation match the machine standing there now?
Passed: Spot-check one machine: the drawing, the control software version and the safety functions described match what you can see and measure on the machine.
The documentation usually describes the machine you bought. Everything that has happened since is rarely written down anywhere. That gap is the first thing an inspector or a customer runs into.
If the instructions go digital, who maintains them?
Passed: A name, and a date of last update that falls after the most recent change to the machine.
Being allowed to supply instructions digitally is an option, not a relief. A paper folder is at least noticed when it goes out of date. A link can sit unchanged for years without anyone feeling it.
What happens at your site when the control system gets new software?
Passed: A routine exists, it has been used at least once, and the last update can be traced: who did it, when, and what was verified afterwards.
Software that affects safety is now a safety component. In most places a software update is still something a supplier does during a visit, without leaving a trace with you.
Fail more than two of them and the Regulation is not your job right now. Change control is. The anchoring protocol measures exactly that: whether a routine is still there when nobody is looking.
What we do not do
We do not CE-mark, we are not a notified body, and we do not write your technical documentation. For that you need someone who does precisely that.
We work on what sits underneath: that changes get noticed, that routines get used, and that what is written down matches what happens. That is what makes the rest possible — and that is what tends to be missing.
Operational problems are usually behavioural problems. The system shapes the behaviour.
We only write when there is something new to say.
If guidance, harmonised standards or clarifications change the picture before 14 January 2027, we update this page and write to you. No more often than that.
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About the sources: what binds is the text of Regulation (EU) 2023/1230. The dates and changes on this page follow the guidance of the Danish Safety Technology Authority and European trade sources (Pilz, TÜV Rheinland), which agree on them. The page was last checked against its sources on 29 September 2026. If you find something that does not hold, tell us — we will correct it and say when.