Machinery Regulation: digital instructions from 20 January 2027, QR code, paper on request

Three conditions for digital instructions

Art. 10(7) ties the digital format to three duties of the manufacturer.

• Access: mark how to reach them on the machine, or if that is not possible on the packaging or an accompanying document
• Format: printable, downloadable and savable on a device, so they are available during a breakdown. This also covers instructions embedded in the machine’s software.
• Duration: online for the expected lifetime and at least ten years after placing on the market

A QR code is allowed but not required

The Regulation does not prescribe a QR code for the instructions. It requires you to state how to access them. A QR code or short address on the type plate does that. What matters is that the code still works in ten years, including after a website relaunch.

Art. 10(7) also requires the instructions to describe the product model clearly, so the code has to lead to the right model, not a general download page.

Paper: when and for whom

If the user asks for paper at the time of purchase, you supply it free of charge within one month. The text names the time of purchase explicitly.

For machinery intended for non-professional users, or that they can use under reasonably foreseeable conditions, there is no choice. The safety information essential for putting into service and safe use comes on paper. That covers power tools sold in DIY stores, for example. The Member State determines the language.

Declaration of conformity: include it or link it

The EU declaration of conformity accompanies the machine. Alternatively, the instructions give the internet address or machine-readable code where it can be accessed (Art. 10(8)). So here a code is named explicitly. A digital declaration stays online for the expected lifetime and at least ten years.

Technical documentation and declaration are kept for market surveillance for at least ten years (Art. 10(3)). Importers keep a copy of the declaration for ten years and ensure the instructions accompany the machine (Art. 13(4) and (8)).

Partly completed machinery: same pattern, other documents

Partly completed machinery gets assembly instructions under Annex XI rather than instructions for use, and an EU declaration of incorporation rather than a declaration of conformity. Both may be digital (Art. 11(7) and (8)) on the same conditions, online for at least ten years. The person incorporating the machine may ask for paper at purchase.

What about machines placed before the date?

The Machinery Directive 2006/42/EC is repealed on 20 January 2027 (Art. 51(2)). What was placed on the market under it before then may still be made available (Art. 52(1)). Machines placed on the market from that date fall under the new Regulation. Plan your print runs and type plates for the first series after that day.

Example: cordless drill and saw line

A cordless drill also reaches home users (invented example). Its instructions may be digital, but the essential safety information goes in the box in print. A saw line for industrial plants only reaches professionals, so everything may be digital unless the buyer asks for paper at purchase.

What to do by 20 January 2027

• Sort your machines: professionals only, or non-professional use possible.
• Separate the essential safety information from the rest of the instructions.
• Set an address per model and language that stays stable for ten years.
• Set up a route for paper requests and record the one-month period.
• Change the type plate or accompanying document so that access is stated.

Frequently asked questions