Regulation (EU) 2023/1230 becomes mandatory on 20 January 2027. For an exporting team, the practical task is not to place every product under one generic certificate. It is to establish the product scope, risk assessment, technical documentation, conformity-assessment route and EU Declaration of Conformity as one traceable file for each model.
This reference page is based on the European Commission machinery page and the current EUR-Lex text of Regulation (EU) 2023/1230, checked on 21 August 2026. It is a documentation-planning framework. It does not promise CE marking, platform acceptance, customs treatment or any regulatory outcome.
1. Separate the transition period from the application date
Regulation (EU) 2023/1230 was adopted on 14 June 2023 and replaces Machinery Directive 2006/42/EC. The European Commission states that the new Regulation applies on a mandatory basis from 20 January 2027. Machinery placed on the EU market before that date remains subject to the Machinery Directive as applicable at the time. A manufacturer may state conformity with the new Regulation in an EU Declaration of Conformity where that is applicable, but the new date does not automatically convert an old file into a new one.
| Situation | Record first | Do not assume |
|---|---|---|
| Before 20 January 2027 | First placing-on-the-market date, applicable Directive requirements, standards and document version | That every machine has already moved to one uniform 2027 regime |
| From 20 January 2027 | Regulation scope, essential health and safety requirements and the applicable conformity route | That the year or an HS code proves conformity |
| New model, configuration or substantial modification | Model identity, intended use, software/control changes and the effect on risk assessment | That a supplier file for an earlier model can be reused without review |
2. Start the scope analysis with the product, not the marketing channel
The Regulation covers machinery and several related products, including interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, removable mechanical transmission devices and partly completed machinery. It also contains exclusions and interfaces with other Union product legislation. Descriptions such as “industrial equipment”, “electrical product” or “exported to the EU” are not enough to settle the legal scope.
Create a scope card for each model. Capture the product function, moving parts and drive system, intended use and reasonably foreseeable misuse, whether it is supplied as a complete machine or incorporated into another assembly, the first placing-on-the-market date, software and safety-control functions, and any other Union legislation that may apply. An HS or CN code can support customs classification, but it does not replace a product-scope analysis under machinery legislation.
Where a product uses software for a safety function, connected control or a system with partially self-evolving behaviour, the product-level assessment should address the relevant software, data, control logic and cybersecurity risks. The Commission describes the new Regulation as covering AI-powered safety functions and cybersecurity for compliance-relevant software data and safety control systems. That does not mean that every AI-enabled or connected product automatically falls into one high-risk machinery category.
3. Technical documentation should explain the decision
Before placing machinery or a related product on the market or putting it into service, the manufacturer establishes the technical documentation and applies the relevant conformity-assessment procedure. Annex IV, Part A, calls for a complete description of the machinery or related product and its intended use, the risk-assessment documentation, the applicable essential health and safety requirements, the protective measures taken and any residual risks. This is more than a folder of certificates.
| File layer | Evidence to retain | Review question |
|---|---|---|
| Product and configuration | Model/series, key specifications, critical components, drawings, control system and software version | Does each document identify the actual model and configuration? |
| Risk and safety | Intended use, foreseeable misuse, hazards, risk estimation, risk-reduction measures, residual risks and warnings | Does the assessment cover the relevant phases of installation, use, maintenance, transport and disposal? |
| Conformity basis | Applicable-requirements list, harmonised standards or other technical solutions, test and verification records | Does each report match the product, sample, method and scope rather than only the laboratory name? |
| Identification and use | Product marking, instructions, maintenance information, warnings, EU Declaration of Conformity and access method | Do paper or digital instructions match the model and the required language information? |
Do not turn laboratory accreditation, a supplier’s statement or an arbitrary fixed report-validity period into a universal machinery-law test. The relevant question is whether the applicable requirements are addressed through the applicable conformity route, and whether the evidence covers the actual product and version. For applicable machinery or related products, the manufacturer must keep the technical documentation and EU Declaration of Conformity available for at least 10 years after the machinery or related product has been placed on the market or put into service, as required by the Regulation.
4. Conformity assessment, notified bodies and CE marking are connected steps
Article 25 sets out different conformity-assessment routes depending on whether a category is listed in Annex I and whether it falls within Part A or Part B. Machinery outside Annex I follows the internal production-control route. Certain listed categories may involve EU type-examination, full quality assurance or unit verification. A notified body is not automatically required for every machine, and a generic third-party certificate is not a substitute for the procedure required by the Regulation.
After conformity with the applicable essential health and safety requirements has been demonstrated, the manufacturer draws up the EU Declaration of Conformity and affixes the CE marking in accordance with the Regulation. The European Commission warns that voluntary certificates issued outside a notified body’s legally notified scope are not, by themselves, a recognised means of proving compliance with EU harmonisation legislation. If a third-party route is required, verify the body and its scope in the NANDO information system rather than relying on a logo or scanned certificate.
For an online sales page, model identity, manufacturer information, warnings, instructions, access to the EU Declaration of Conformity and the final product configuration should be consistent. That consistency is an evidence-control task; this page does not turn any marketplace upload, review or delisting process into a statutory step under Regulation (EU) 2023/1230.
5. A six-step preparation checklist for exporters
- Build the model list: separate complete machinery, related products and partly completed machinery, and record configuration, software version and first placing-on-the-market date.
- Create a scope card: compare the product with the scope and exclusions of Regulation (EU) 2023/1230 and check other potentially applicable Union product legislation.
- Document the risk assessment: state intended use, foreseeable misuse, hazards, risk-reduction measures, residual risks and warnings instead of treating “tested” as a substitute for analysis.
- Assemble the technical file: connect drawings, specifications, critical components, control systems, test or verification evidence, instructions and change records to the model.
- Confirm the conformity route: use Annex I and Article 25 to decide whether a notified body is needed, then verify its notification scope in NANDO where relevant.
- Run a pre-release readback: confirm that the EU Declaration of Conformity, CE marking, manufacturer or responsible-operator information, page copy and instructions still describe the final product.
6. Source boundary and official references
“Applicable in 2027” is a date boundary, not a finding that a particular SKU is compliant. “Technical file exists” is not the same as completing conformity assessment. The product, model, intended use, risks, applicable legislation, standards and placing-on-the-market date still need to be reviewed together. The European Commission also notes that its pages provide general guidance; binding legal interpretation belongs to the Court of Justice of the European Union.
- European Commission: Machinery — legislation, the 20 January 2027 application date, AI safety functions, digital instructions and notified-body information.
- EUR-Lex: Regulation (EU) 2023/1230 — scope, essential health and safety requirements, technical documentation, conformity assessment and CE-marking provisions.
- NANDO Information System — a source to check a notified body’s legal notification and scope when a third-party assessment is relevant.
Greenark Certification (Shenzhen) Co., Ltd. recommends mapping product scope, regulatory version, risk assessment, technical documentation and declarations before deciding whether additional testing or third-party assessment is needed. Missing evidence should remain a documented review item, not be rewritten as an approval claim or a promise of platform clearance.
