What the EU Machinery Regulation 2023/1230 changes about instruction manuals

The dates

Regulation (EU) 2023/1230 was adopted on 14 June 2023 and replaces Directive 2006/42/EC. The original Official Journal text gave 14 January 2027 as its main application date; a corrigendum published on 4 July 2023 corrected that to 20 January 2027, and the European Commission's page says the same:

Some articles applied earlier, and the corrigendum moved those dates too. Products placed on the market in conformity with the Directive before the main date can still be made available after it; the transitional provisions say exactly how.

Unlike the Directive, it is a regulation, so the same text applies everywhere in the EU without each country writing its own version:

Instructions may be digital, with conditions

The Commission describes one of the changes as clarifying "conditions under which the instructions for use and the declaration of conformity can be provided in a digital format". The rule is in Article 10(7):

If the instructions are digital, the same article says the manufacturer shall:

1. "mark on the machinery or related product, or, where that is not possible, on its packaging or in an accompanying document, how to access the digital instructions";
2. "present them in a format that makes it possible for the user to print and download the instructions for use and save them on an electronic device so that he or she can access them at all times, in particular during a breakdown of the machinery or related product" (this also applies to instructions embedded in the machine's software);
3. "make them accessible online during the expected lifetime of the machinery or related product and for at least 10 years after the placing on the market of the machinery or related product."

Paper is still available on request

And where the machine may be used by non-professional users, the safety information essential for putting it into service and using it safely must be supplied on paper regardless. The instructions, safety information and Annex III information must also be in a language easily understood by users, as determined by the Member State concerned.

What the instructions must contain

The content requirements are in Annex III, section 1.7.4. Section 1.7.4.2 lists what the instructions shall contain "where applicable, at least": a long list of items. Several are about drawings, which is where illustration work comes in:

• (d) "a general description of the machinery or related product";
• (e) "the drawings, diagrams, descriptions and explanations necessary for the use, maintenance and repair of the machinery or related product and for checking its correct functioning";
• (i) "assembly, installation and connection instructions, including drawings, diagrams and the means of attachment ...";
• (t) "the specifications of the spare parts to be used, when these affect the health and safety of operators".

The same list covers intended use, foreseeable misuse, residual risks, protective measures, transport, maintenance and noise, among others. Read the full list in the Annex rather than this extract.

What this means for the way manuals are produced

• A digital manual has to be printable and downloadable, and stay online for the machine's expected lifetime and at least ten years. A PDF the user can save and print is the simplest way to let them "print and download"; an interactive viewer on its own needs more thought. Plan where the files will live for that long.
• Paper can't be dropped entirely: there must be a way to supply it free within a month when asked at the time of purchase.
• Instructions must "clearly describe the product model to which they correspond". If drawings are shared across models, make the model each one shows unambiguous.
• Drawings are named content, not decoration: (e) and (i) ask for the drawings needed for use, maintenance, repair and assembly.

Selling in Great Britain or Northern Ireland

In Great Britain, machinery is covered by the Supply of Machinery (Safety) Regulations 2008, and GOV.UK publishes separate guidance on those regulations for Great Britain and for Northern Ireland. Which rules apply to a given product depends on the market it's placed on. If you sell into more than one of GB, Northern Ireland and the EU, get professional advice on each.

Where to go next

• Read Article 10 and Annex III of the regulation itself on EUR-Lex, with the corrigendum alongside it.
• Talk to whoever does your conformity assessment, or a specialist adviser, before you change how you supply instructions.
• For the craft of writing the instructions, see how to make assembly instructions from CAD.