Tools · Updated July 2026

Does the manual hold up under the Machinery Regulation?

Eighteen checks drawn from Regulation (EU) 2023/1230, which replaces Machinery Directive 2006/42/EC on 14 January 2027. Answers stay in the browser and are still there on your next visit.

From 14 January 2027 the instructions for use are not an attachment to the declaration of conformity: they are an integral part of it under the essential requirements of Annex III. Without compliant instructions there is no valid declaration, and without a declaration there is no CE marking.

This list lines up the checks the regulation places on the manual, one per row, with the reference beside it. It shows where the current text fails to cover a requirement: the conformity assessment remains an act of the manufacturer, and the person who signs it is a person.

An information tool, not legal advice and not a conformity assessment. The references are the ones cited entry by entry; the text that counts is the official one.

How it works

Tick the entries your manual already covers; the counter at the bottom keeps score.
Answers stay in this browser: on your next visit the list is as you left it.
The print button produces a copy to attach to an internal record, with the ticked entries.

The tool runs in the browser: what you tick stays on your device, it never reaches us.

Copy printed from csidia.com/en/tools/machinery-regulation-checklist

Content of the instructions

Annex III, point 1.7.4 (1.7.4.1 and 1.7.4.2)

The manual identifies the manufacturer with legal name and contact details.
The minimum content of the instructions is set by Annex III, point 1.7.4: manufacturer identification is the first item on it.
The description of the machine and its intended use are written in the manual.
Annex III, point 1.7.4: description and intended use bound what the machine was assessed for.
Reasonably foreseeable misuse is listed, not banned in one generic line.
Annex III, point 1.7.4 asks for reasonably foreseeable misuse alongside the intended use.
Assembly, commissioning, use and maintenance each have their own instructions.
These are the phases listed in Annex III, point 1.7.4: a manual that covers use but not maintenance stays incomplete.
Residual risks are declared in the manual.
Annex III, point 1.7.4: the risks that remain after the protective measures must be communicated to whoever uses the machine.

Language, format and availability

Article 10(7)

The instructions are in the language set by the member state of use and understandable to end users.
Article 10(7) ties the language to the member state of use and to comprehension by whoever operates the machine, not to the manufacturer’s own language.
If the instructions are digital only, they stay online for the machine’s whole expected lifetime and in any case for at least ten years from placing on the market.
This is the condition Article 10(7) attaches to the exclusively digital format.
Online publication continues even if the manufacturer ceases trading: the party and the archive are identified.
Article 10(7) keeps the duty alive even if trading stops: it is documentary continuity to design in advance.
There is a procedure to supply a free paper copy within one month when the buyer asks for it at the time of purchase.
Article 10(7): the request is made at the time of purchase, delivery follows within one month and at no cost.
For non-professional users, safety information is on paper regardless.
Article 10(7): for non-professional users, digital only is not allowed for safety information.

Control software, cybersecurity, self-evolving logic

Annex III, points 1.1.9 and 1.2.1

Connecting the machine to another device, including remotely and over the internet, cannot create a hazardous situation.
Annex III, point 1.1.9, protection against corruption: a requirement that did not exist in Directive 2006/42/EC.
Hardware, software and data relevant to safety are protected against accidental or intentional corruption.
Annex III, point 1.1.9: the protection covers unintended alteration and deliberate alteration alike.
The control system withstands malicious external attempts, and the manual accounts for it where relevant.
Annex III, point 1.2.1: the safety of control systems includes attacks, not only faults.
If the machine has self-evolving behaviour or logic, the additional requirements are verified; if an AI system acts as a safety component subject to third-party assessment, it is treated as high-risk.
Annex III, point 1.2.1 for the additional requirements. Annex I, Section A of Regulation (EU) 2024/1689 lists 2023/1230 among the harmonisation legislation: the high-risk classification follows from there.

Supply chain and circulation of the document

Articles 11, 13, 15 and 16

For partly completed machinery, assembly instructions exist for whoever integrates it into a larger installation.
Article 11 governs manufacturers of partly completed machinery and the related assembly instructions.
Before placing the product on the market, the importer verifies that conformity assessment, technical file, declaration, manual and CE marking are all in place.
Article 13: if even one of these is missing, the importer cannot place the product on the Union market.
The distributor checks that CE marking, EU declaration and instructions genuinely accompany the product, with model, type, year of construction and manufacturer or importer details legible.
Articles 15 and 16: responsibility for the manual is not exhausted by the manufacturer.
The circulation perimeter of the manual is defined: who receives it, through which channel, where it is stored.
The manual holds know-how. Protection as a trade secret (Legislative Decree 63/2018, arts. 98-99 of the Italian Industrial Property Code) requires measures reasonably adequate to keep it secret.

Where you stand

0/18 checked

Nothing checked yet: all 18 points remain to be clarified before conformity can be declared.

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The note behind it EU Machinery Regulation: no CE marking without compliant manuals from 14 January 2027 The solution that covers it Assisted document compliance

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