Machinery Regulation from 20 January 2027: what manufacturers switch by the date

The date counts per machine, not per series

Placing on the market means the first making available of a product on the Union market (Article 3). A series that runs across January therefore changes its law in the middle of production.

The Commission writes on this: before the date, machinery has to comply with the Directive. You may add in the declaration that it also complies with the Regulation, if that is true. Switching early does not replace the Directive.

Eight points belong on your switch list

Digital instructions are only one of them. The details are in the guide on digital instructions for use. The list names what you check per machine type.

On harmonised standards the position is open

The list of standards under the Directive is running out. Implementing Decision (EU) 2026/2015 repeals Decision 2023/1586 with effect from 20 January 2027. The presumption of conformity under Article 20 of the Regulation requires that the reference of a standard has been published in the Official Journal.

On 3 November 2026 we found no decision in the EUR-Lex database that names standards under the Regulation. This mainly affects machinery in Annex I, Part B: module A there requires harmonised standards or common specifications that cover all the relevant requirements (Article 25(3)).

• Look in the Official Journal before every declaration, not in the old list.
• Talk to your notified body if you rely on module A for Part B.
• Describe other specifications in the documentation if a reference is missing (Annex IV, Part A, point (f)).

The new declaration has ten points

Annex V, Part A sets the content. Create the template once and reuse it for every type. Your test: if it still cites the Directive, it does not belong to a machine from the date onwards.

• The machinery: product, type, model, batch or serial number. Name and address of the manufacturer and, where applicable, the authorised representative.
• For lifting machinery that is permanently installed and can only be assembled at the place of use: the address of that place.
• The sentence on sole responsibility, the object of the declaration, the Union harmonisation legislation it conforms to.
• Harmonised standards or common specifications with the date of the reference, or other technical specifications with their date; for partial application, the parts applied.
• Notified body or the note on module A, additional information, place, date, name, function, signature.

Three questions for your development team

Sections 1.1.9 and 1.2.1 of Annex III are newly worded requirements for connected machinery and its control system. The Annex does not prescribe in detail how you meet them technically. So start with these questions. If one applies, the answer belongs in the risk assessment.

• Can a connected device or remote access lead to a hazardous situation?
• Does the machine show the safety software installed on it, and does it collect evidence of interventions in software and hardware?
• Is the tracing log of intervention data and of uploaded versions of safety software enabled for five years after the upload, for a reasoned request from the authority?

Backwards plan to the date

The interim dates are our suggestion, not legal deadlines. Only the last two are fixed.

• By 20 November 2026: list machine types, assign them to Annex I, assess use by non-professional users.
• By 4 December 2026: check software and control system against Annex III, report gaps to development.
• By 18 December 2026: declaration template, technical documentation, appointment with the notified body.
• By 15 January 2027: rating plate, accompanying sheet and online address finished, print released.
• 19 January 2027: last day for placing on the market under the Directive.
• 20 January 2027: the first machine under the Regulation leaves the building.

Example: a band saw across the date

The invented company Muster Holztechnik GmbH builds band saws with manual loading. They are listed in Annex I, Part B, point 4. Machine 412 goes to a distributor on 18 January 2027; it runs under the Directive. Machine 413 leaves on 21 January 2027. It needs the new declaration and the conformity route under Article 25(3).

From January the company therefore records, per serial number, the date of first making available and the version of the declaration. It can then answer an authority’s question with one line.

Germany and Austria directly, Switzerland with its own text

In Germany and Austria, as in every Member State, the Regulation applies directly (Article 54). Member States lay down the penalties themselves and had to notify them by 20 October 2026 (Article 50). We have not checked the national rules.

Switzerland is adapting its Machinery Ordinance. The Federal Council opened the consultation on 19 September 2025. We found no decision on entry into force or on updating the agreement with the EU. If your Swiss company supplies the EU, check the position with SECO.

What the Regulation does not regulate

It does not prescribe how you prove the date of placing on the market. It contains no duty to retrofit machines in the field. Only a substantial modification turns the person who carries it out into a manufacturer (Article 18). The product passport module covers the documents, not the conformity assessment.

Frequently asked questions