Digital instructions under the EU Machinery Regulation

What changes in January 2027

Regulation (EU) 2023/1230 on machinery replaces the Machinery Directive 2006/42/EC. As a regulation, it applies directly in every Member State, without national transposition. It was published in June 2023 and, after a corrigendum that corrected its dates, it applies from 20 January 2027. The original text said 14 January 2027, which is why you will still see that date in older articles.

For documentation teams, the biggest change is that instructions for use no longer have to be printed by default. Article 10(7) says that the instructions “may be provided in a digital format”, and sets the conditions. It also keeps two paper obligations, which are easy to miss.

What Article 10(7) allows

Under Article 10(7), machinery and related products must be accompanied by the instructions for use and the information in Annex III. Where the manufacturer provides the instructions digitally, the manufacturer must:

1. Show how to access them, on the machinery or related product, or where that is not possible, on its packaging or in an accompanying document.
2. Provide them in a format the user can print, download and save on an electronic device, including where the instructions are embedded in the product’s software.
3. Keep them accessible online for the expected lifetime of the product and for at least 10 years after it is placed on the market.

The instructions must also clearly identify the model they apply to, and be clear, understandable and legible, in a language users can easily understand, as determined by the Member State concerned. A different language version per market is therefore still needed, even if all of them sit behind one code.

What still has to be on paper

Digital instructions do not remove paper altogether. Two obligations stay:

Paper on request, free, within one month

If a user asks at the time of purchase, the manufacturer must provide the instructions for use “in paper format free of charge within one month”. In practice you need a way for buyers and distributors to request a printed copy, a print-ready file per language, and someone responsible for sending it.

Essential safety information for non-professional users

For machinery intended for non-professional users, or which they could reasonably be expected to use, the manufacturer must still provide “in paper format, the safety information that is essential” for putting the product into service and using it safely. Garden machinery, DIY power tools and similar consumer products therefore still ship with a printed safety leaflet; the full instructions can be digital.

Showing users how to access the instructions

The Regulation leaves the method of access to the manufacturer. A QR code next to the rating plate, on the packaging or on the safety leaflet is the obvious choice, because any phone camera reads it. A short web address printed beside it covers the cases where the code can’t be scanned.

• Point the code to a stable address that you control for at least ten years, not to a file name or a redirect that depends on a subscription.
• Make sure the page clearly names the model, so the user knows these are the right instructions.
• Keep the instructions downloadable as a file (usually PDF) that prints properly, not only as a web page.
• Plan for products you stop selling: their instructions must stay online after the last unit is sold.

Print size and placement are covered in our QR size and placement guide.

A checklist for manufacturers

Where ItemDocs helps, and where it doesn’t

ItemDocs hosts product pages with downloadable documents behind a permanent QR code. That covers part of what Article 10(7) asks for, but not all of it, and it does not make a product compliant. Here is an honest breakdown.