Regulation (EU) 2023/1230, Article 25
You build machines. What does the Machinery Regulation ask of you?
- In scope?
- Yes, if you place machinery, a related product or partly completed machinery on the EU market.
- Which route?
- Module A, unless your category is in Annex I. Part B makes it conditional, Part A removes it.
- From when?
- 20 January 2027, when it replaces Directive 2006/42/EC.
What do you place on the market?
Three tiers, not two
Not listed in Annex I
Internal production control, module A. Article 25(4).
Annex I Part B
Module A only where harmonised standards or common specifications cover all the relevant requirements; otherwise a notified body. Article 25(3).
Annex I Part A
EU type-examination with production conformity, full quality assurance, or unit verification. Module A is not on the list. Article 25(2).
Part B is the tier that is misread, because it resembles the old Directive's bargain without being it. Both lists are below, in the Annex's own wording.
The six categories in Annex I Part A
- 1Removable mechanical transmission devices including their guards
- 2Guards for removable mechanical transmission devices
- 3Vehicle servicing lifts
- 4Portable cartridge-operated fixing and other impact machinery
- 5Safety components with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions
- 6Machinery that has embedded systems with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions that have not been placed independently on the market, in respect only of those systems
The nineteen categories in Annex I Part B
- 1Circular saws (single- or multi-blade) for working with wood and material with similar physical characteristics or for working with meat and material with similar physical characteristics, of the following types:
- 2Hand-fed surface planing machinery for woodworking
- 3Thicknessers for one-side dressing having a built-in mechanical feed device, with manual loading and/or unloading for woodworking
- 4Band-saws with manual loading and/or unloading for working with wood and material with similar physical characteristics or for working with meat and material with similar physical characteristics, of the following types:
- 5Combined machinery of the types referred to in points 1 to 4 and in point 7 for working with wood and material with similar physical characteristics
- 6Hand-fed tenoning machinery with several tool holders for woodworking
- 7Hand-fed vertical spindle moulding machinery for working with wood and material with similar physical characteristics
- 8Portable chainsaws for woodworking
- 9Presses, including press-brakes, for the cold working of metals, with manual loading and/or unloading, whose movable working parts may have a travel exceeding 6 mm and a speed exceeding 30 mm/s
- 10Injection or compression plastics-moulding machinery with manual loading or unloading
- 11Injection or compression rubber-moulding machinery with manual loading or unloading
- 12Machinery for underground working of the following types:
- 13Manually loaded trucks for the collection of household refuse incorporating a compression mechanism
- 14Devices for the lifting of persons or of persons and goods involving a hazard of falling from a vertical height of more than 3 m
- 15Protective devices designed to detect the presence of persons
- 16Power-operated interlocking movable guards designed to be used as safeguards in machinery referred to in points 9, 10 and 11 of this Part
- 17Logic units to ensure safety functions
- 18Roll-over protective structures (ROPS)
- 19Falling-object protective structures (FOPS)
Regulation (EU) 2023/1230, Annex I and Article 25, read from the Official Journal with its corrigenda. It applies from 20 January 2027.
What the Directive did not ask for
Annex III carries requirements that had no counterpart in Directive 2006/42/EC: connecting a device must not create a hazardous situation, software and data critical to safety must be protected against corruption, the machine must be able to say what safety software it is running, and intervention in that software must leave evidence. A file reused from the Directive does not contain them.
See the technical fileOne machine, one file
Machinery technical file pack, €2,000
Seven documents for one machine or related product, drawn up from your answers, in PDF and DOCX.
See what it coversQuestions people ask
- We CE marked under the Directive. Does that carry over?
- No. Regulation (EU) 2023/1230 applies from 20 January 2027, and its Annex III adds requirements the Directive did not have, so a file assembled for the Directive is missing them rather than merely out of date.
- Our machine is built entirely to harmonised standards. Can we still self-assess?
- It depends which part of Annex I lists your category. Not listed: yes, module A. Part B: yes, but only where those standards cover all the relevant essential health and safety requirements. Part A: no, and applying every standard does not change it.
- We supply partly completed machinery. What do we owe?
- A declaration of incorporation and assembly instructions, not a declaration of conformity, and no CE marking for the partly completed machinery itself.
- Is the date 14 or 20 January 2027?
- 20 January 2027. The Official Journal's original text of Article 54 says 14 January in all six language versions and was corrected; a page still quoting 14 January is quoting the uncorrected text.