MACHINE BUILDING
I
n less than a year, the new EU Machinery Regulation 2023/1230 (MR) supersedes the Machinery Directive 2006/42/EC (MD) on 20 January 2027. Machine builders must be prepared, including manufacturers of series machines already in production. There is no transition period – the change will, in effect, be overnight. While some machine builders will only need to revise their paperwork, others may have to go much further. The new MR has additional essential health and safety requirements (EHSRs), such as those relating to cybersecurity. Any machine with a USB or network port will require an assessment. Machinery linked to networks or the internet, or that is capable of autonomous operation, will probably need assessing by competent IT professionals.
It is imperative that machine builders study the new MR and understand the implications. A new risk assessment might be needed for the whole machine or just certain aspects. Depending on the outcome, changes to the design, software or hardware could be required.
Annex I machinery (formerly Annex IV) built to harmonised standards will need a Notified Body Type Approval until the standards are updated and harmonised to the MR. It could be months or years until these are all harmonised.
INSTRUCTIONS
Instructions for use no longer have to be in ‘hard copy’, as the MR allows them to be provided digitally. However, a hard copy must be supplied free of charge if requested when the machine is ordered. Machine builders can potentially save money by not including a printed set of instructions with every machine but they need procedures for
36
WHY YOU NEED TO UPDATE YOUR MACHINERY CE MARKING PAPERWORK
By Derek Coulson, Hold Tech Files
providing printed copies on request. For partly completed machinery, the assembly instructions may be provided digitally, with customers able to request a free printed copy.
DECLARATION OF CONFORMITY From 20 January 2027, the EU Declaration of Conformity (DoC) (previously an EC Declaration) must refer to the Machinery Regulation 2023/1230 instead of the Machinery Directive 2006/42/EC. A number of minor revisions must be made to the DoC; Annex V Part A of the MR states what the DoC must contain. Previously, a machine might have been accompanied by more than one DoC for different Directives or Regulations. Under the new MR, a single DoC can list all of the laws with which conformity is being claimed.
For partly completed machinery, the changes to the DoI are similar to those for the DoC (Annex V Part B). Many existing standards are not yet harmonised to the MR, so these should not be listed on Declarations. Machine builders can now choose to provide an internet address or machine-readable code (eg QR code) from where the EU Declaration of Conformity can be accessed.
QUALITY ASSURANCE PAPERWORK The only revisions to quality assurance paperwork are likely to stem from changes necessary for complying with new EHSRs, such as those relating to cybersecurity.
TECHNICAL DOCUMENTATION In the old MD, the term ‘technical file’ was used when referring to machinery, whereas ‘technical
Summer 2026 UKManufacturing
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48
