EU Machinery Regulation Digital Instructions: What to Check in Your Manual Package

From 20 January 2027, Regulation (EU) 2023/1230 replaces the Machinery Directive. Manufacturers may provide instructions for use digitally, subject to the conditions in Article 10(7). Some information must still be supplied on paper.

This article turns those conditions into checks you can run on your own instruction package before that date. It does not assess whether a product complies with the regulation. That depends on the machine, the market, and the people who sign the declaration of conformity. Several of the checks below are working methods I suggest, not conditions written in the regulation, and they are marked that way.

What Article 10(7) asks for

When the instructions are provided digitally, the manufacturer has to:

mark on the machine how to access the digital instructions, or on the packaging or an accompanying document if marking the machine is not possible;
present them in a format the user can print, download, and save on an electronic device, so they can be read at any time, in particular during a breakdown of the machine;
keep them accessible online during the expected lifetime of the machine and for at least 10 years after it is placed on the market.

The same paragraph also requires:

a paper copy, free of charge within one month, if the user asks for one at the time of purchase;
the safety information essential for putting the machine into service and using it safely, on paper, if the machine is intended for non-professional users or can be used by them under reasonably foreseeable conditions;
instructions in a language users can easily understand, as determined by each Member State.

The instructions must clearly describe the product model they correspond to. The print, download, and save requirement also applies when the instructions are built into the machine's software.

Start with one list per product line

Before checking links or files, it helps to put the facts for each model in one table. The regulation does not require this table. It is a working list that keeps the later checks consistent. Columns that cover the checks below:

model, as marked on the machine
countries where it is sold, and the languages needed there
revision of the instructions in each language
access path marked on the machine, packaging, or accompanying document
date each unit is placed on the market, and the expected lifetime
whether paper safety information is needed, and in which languages
where a request for a paper copy is received
who maintains the links

Match models and languages

The instructions have to include the designation shown on the machine itself, except the serial number (Annex III 1.7.4.2(1)(b)). For each language version, check:

that a version exists for each language required in the countries where the machine is sold;
that each version names the same models as the marking on the machine;
that each version corresponds to the same content. Matching revision numbers across languages is one practical way to see this, though the regulation does not require a shared numbering scheme.

One exception: maintenance instructions meant for specialised personnel mandated by the manufacturer or its authorised representative can be supplied in a single official EU language those personnel understand (Annex III 1.7.4).

Follow the access path

Scan the code or type the address marked on the machine, the packaging, or the accompanying document, and check:

whether it leads to the instructions for this model or to a general page where the user has to search;
if the same code is printed on several models, whether the page makes clear which document belongs to which model;
if access requires an account, whether the user can still reach the document when the machine is stopped.

Save, print, and open during a breakdown

The regulation asks for a format the user can print, download, and save on a device. Setups that make this hard include a web viewer with no file to download, a PDF whose security settings block printing or saving, and a help system inside the machine's software with no way to export the content.

As a check of your own: download the instructions as a user would, save them on a phone or laptop, and open them with the network off. If the instructions exist in more than one form, such as HTML on a portal and a PDF, confirm that the downloadable form matches the revision shown online.

Paper that still ships or is sent

Two cases need paper:

A paper copy for a user who asks at the time of purchase. Check that there is a way to receive the request and to deliver within a month. If older models stay in stock after a revision, check that the paper copy sent matches the unit being sold.
For machines intended for non-professional users, or that they could use under reasonably foreseeable conditions, the essential safety information for putting the machine into service and using it safely. Check that it is supplied on paper with the machine, in the languages required in each country, and that it agrees with the digital version.

Keep the documents online for the required period

The requirement runs per machine: online during its expected lifetime, and for at least 10 years after that unit is placed on the market. For a product line, use the latest applicable end date among the units covered by those instructions.

These are ways an instruction link could stop serving the right file over time:

The website is redesigned and old paths are not redirected.
A new revision replaces the old file at the same address, and machines already sold no longer reach the instructions that match them.
The product line is sold, renamed, or discontinued, and its pages are removed.

For each product line, check whether the address marked on the machine is one you control and expect to keep for that period, whether machines sold earlier still reach the revision that matches them after a revision, and who checks the links after the product is discontinued.

If the instructions point to a digital EU declaration of conformity by address or code, check that link as well. Article 10(8) sets its own period: the expected lifetime, and at least 10 years after placing on the market or putting into service.

A browser tool for the file checks

I made a free Instruction Package Checker for the file-level part of this list. It reads the PDFs in your browser without uploading them. Language and model checks cover the first 600 pages of each file. It estimates the language of each page from common words and reports which of the languages you select it could not detect in any file. It also reports whether each model designation you enter appears in each file, and whether a PDF blocks printing or needs a password to open. It lists strings on the first two and last two pages that look like revision numbers or dates, so you can compare language versions yourself. It does not check links, how long documents stay online, or paper copies.

What these checks do not cover

Annex III 1.7.4.2 lists what the instructions must contain, from residual risks to noise emission values. Whether the content meets that list is a technical and legal assessment that these checks leave to the people responsible for the declaration of conformity.

Sources: Regulation (EU) 2023/1230 on EUR-Lex, and the corrigendum that sets the application date to 20 January 2027.