The European Union's Machinery Regulation (EU) 2023/1230 replaces Machinery Directive 2006/42/EC and applies from 20 January 2027. The move from a directive to a regulation means the rules will apply directly and uniformly everywhere, without being transposed into member states' national law.
For Turkish manufacturers exporting machinery to the EU, and for the subcontractors supplying them with chassis, frames and welded structures, the months before 2027 are a preparation period.
Key Changes
| Topic | Directive 2006/42/EC | Regulation 2023/1230 |
|---|---|---|
| Legal form | Directive (transposed into national law) | Regulation (directly applicable) |
| Instructions for use | Printed | Digital format accepted; printed copy provided on request |
| High-risk machinery | Annex IV list | Annex I list; mandatory third-party assessment for some categories |
| Substantial modification | No clear definition | Anyone who substantially modifies a machine afterwards is deemed the manufacturer |
| Cybersecurity and software | Limited | Requirements for protection against corruption and for software with safety functions |
| Artificial intelligence | None | Additional requirements for systems with self-evolving behaviour |
Why Does It Matter to Welded Fabrication Suppliers?
The regulation is addressed to the manufacturer placing the machine on the market; however, much of the evidence in the manufacturer's technical file comes from the supply chain. Load-bearing chassis, booms and arms, protective guards and pressure-bearing components are all part of the documentation showing that the machine meets the essential health and safety requirements.
- Material traceability: EN 10204 3.1 certificates and batch-level records are referenced in the technical file.
- Evidence of weld quality: For load-bearing and safety-critical joints, the WPS, welder certificates and NDT reports are requested.
- Revision discipline: Controlled management of drawing changes becomes even more important because of the "substantial modification" concept.
- Digital document delivery: The digital instructions and technical file approach raises the expectation that suppliers will also deliver documents in a digital, searchable format.
Note: This article is for general information only. For your product's classification and conformity assessment route, refer to the official text of the regulation and your notified body.
Pre-2027 Preparation Checklist
- Review your product portfolio against the new Annex I (high-risk machinery) list.
- Compare your harmonised standard references (e.g. EN ISO 12100) against the current list.
- Update your technical file template for digital instructions and cybersecurity requirements.
- Define in writing the scope of the documentation package from your critical welded component suppliers.
- Verify your suppliers' EN ISO 3834-2 and, where required, EN 1090-2 certificates.
- Prepare your EU declaration of conformity template in line with the new regulation for products to be placed on the market after 2027.
Relationship to CE Marking
The CE mark shows that the machine complies with all relevant EU legislation. For welded structural components, EN 1090 may also apply, and for pressure-bearing parts, regulations such as the PED. For the overall framework, read our article on CE marking in welded fabrication.
At ArmaWeld, we deliver welded components to our machine-builder customers with a traceable documentation package consisting of material certificates, WPS references, NDT and dimensional inspection reports.
Frequently Asked Questions
When does the new Machinery Regulation come into force?
Machinery Regulation (EU) 2023/1230 applies from 20 January 2027 and replaces Machinery Directive 2006/42/EC on the same date.
Can instruction manuals now be supplied digitally?
Yes. The regulation allows instructions to be provided in digital format; however, if the user requests it, a printed copy must be supplied free of charge within a set period.
Do subcontractors need to carry out CE marking?
Under the Machinery Regulation, responsibility lies with the manufacturer placing the machine on the market. The subcontractor provides the material, welding and inspection evidence that goes into the manufacturer's technical file; separate regulations such as EN 1090 may apply to structural components.
A Documentation Package That Fits Your Technical File
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