Regulation (EU) 2023/1230 sets out explicit conditions for the digital instruction manual: access to the instruction manual is indicated on the machine, the instruction manual can be printed, downloaded and saved, it remains online for at least ten years after the machine is placed on the market and for the entire intended lifetime of the machine, and the user who requests it at the time of purchase receives it free of charge on paper within one month. For machines intended for non-professional users, the essential safety information is provided on paper. The requirements of the regulation on the instruction manual (Article 10, Annex III) apply from 20 January 2027; certain provisions, including Article 52, already apply (Article 54). For each machine (each copy) placed on the market before 20 January 2027, Directive 2006/42/EC applies.
In short
- The date The requirements of the notice on the label (Article 10, Annex III) apply from January 20, 2027, the date on which Directive 2006/42/EC is repealed (Article 51 §2); some provisions, including Article 52, already apply (Article 54). It is the date of placing on the market of each individual copy that counts.
- The format The digital notice is an option, not an obligation. The regulation subjects it to four conditions, and requires paper on request when purchasing and, for non-professional users, for essential safety information (Article 10 §7).
- Declaration of conformity : under the regulation, the declaration EU accompany the machine, or the instruction manual provides the internet address or machine-readable code leading to it (Article 10(8); Annex III, 1.7.4.2 c)).
From when: January 20, 2027
The requirements of Regulation (EU) 2023/1230 on the label (Article 10, Annex III) apply from 20 January 2027; some provisions, including Article 52, already apply (Article 54). Directive 2006/42/EC is repealed with effect from 20 January 2027 (Article 51(2)).
Article 52 §1 regulates the passage: Member States do not prevent the making available on the market of products that have been placed on the market in accordance with the directive before January 20, 2027. Therefore, every machine (every copy) placed on the market before that date under the directive, with its instruction manual written in accordance with the directive, can still be made available afterwards.
It is the copy that counts, not the model. A model launched in 2026 whose copies are put on the market after January 20, 2027 falls under the regulations for those copies.
One clarification, because the error is still circulating: the original text published in the Official Journal read «14 January 2027». A correction of 4 July 2023 (JO L 169/35) replaced it with «20 January 2027». That is the correction that counts.
The digital notice: an option, subject to four conditions
Article 10(7) requires manufacturers to ensure that the machine is accompanied by its instructions and the information in Annex III. These documents can be provided in digital format, and they clearly describe the model of machine they correspond to. The regulation sets out explicit conditions for the digital instruction manual.
- Access is indicated. The manufacturer indicates on the machine how to access the manual. If this is not possible, it indicates it on the packaging or in an accompanying document.
- The notice is printed, downloaded, and saved. It is presented in a format that allows the user to access it at any time, especially during a failure. The condition also applies when the manual is integrated into the machine’s software.
- She remains online. The manufacturer makes it available online at least ten years after each unit has been placed on the market, and for the entire expected lifetime of the product.
- Paper upon request. At the request of the user at the time of purchase, the manufacturer provides the manual on paper free of charge within one month.
The text cites the failure: this is when the manual comes into play, and when the machine’s screen may no longer display anything.
The paper: when it remains unpaid
The regulation imposes the use of paper in two cases.
Upon request, at the time of purchase. This is the fourth condition above: free for one month.
For non-professional users. For machines intended for them or likely to be used by them under reasonably foreseeable conditions, the manufacturer shall provide on paper the safety information essential for the safe commissioning and use of the machine.
The criterion does not stop at the target clientele: the text also applies to machines that «may be used by them».
The language: «easily understood by users»
Under Directive 2006/42/EC (Annex I, point 1.7.4): «Each machine must be accompanied by an instruction manual in the official language(s) of the Member State in which the machine is placed on the market and/or put into service.» The directive distinguishes between the «Original Notice» and the «Translation of the original notice».
Under Regulation (EU) 2023/1230 (Article 10 §7), the notice, the safety information and those of Annex III are written in a language easily understood by users, determined by the Member State concerned. They are clear, understandable and readable. The term «original notice» does not appear in the French text of the regulation.
Before fixing the languages of a notice, check what the Member State of destination has determined.
The EU Declaration of Conformity: attached, or accessible via a link
Under the directive, In point 1.7.4.2(c) of Annex I, the notice contains «the EC declaration of conformity or a document presenting the content of the EC declaration of conformity, indicating the characteristics of the machine, without necessarily including the serial number and the signature».
Under the regulation, The machine is accompanied by the declaration EU compliance (Annex V, Part A), or the notice and information in Annex III provide the internet address or machine-readable code that allows access to it (Article 10(8); Annex III, point 1.7.4.2(c)). A declaration provided in digital form remains accessible online for the entire intended lifetime of the machine, and for at least ten years after its placing on the market or putting into service.
The link is therefore not a shortcut: as with the digital brochure, it obliges the manufacturer to keep the page online.
The content: almost the same list
The content of the notice remains fixed at point 1.7.4.2 (Annex I of the directive, Annex III of the regulation), and the regulation reproduces points a) to u) of the directive by adding three more. The details are in our article Machine instruction sheet: what it should contain, and how to prepare it
Before choosing the format of your notices, please read Article 10 of the regulation, which is public and available free of charge on EUR-Lex. This article helps you to use it; it does not replace it.
Writing the content with Optima Doc Creation
Paper or digital, the notice is written first. The application is complete Optima Doc Creation Write the datasheet from the machine’s documentation, assign each value to the document from which it is derived, mark what your documents do not say, and export the datasheet in Word. What it produces is read back: your engineering office compares it with the machine, corrects it, and completes it. The datasheet remains the manufacturer’s one.
What Optima Doc Creation does not do: upload the notice to the online platform, host it, generate the EU declaration of conformity or a QR code, or judge the notice to be compliant.
The online trial starts with the documents from your machine (supplier’s notice, risk analysis, plans) and then produces a first draft of the notice in six parts: identification, description, safety, installation, use, and maintenance.
Frequently asked questions
Should a machine put on the market in 2026 comply with the regulations?
No: a machine (one copy) placed on the market before January 20, 2027 falls under Directive 2006/42/EC, and may continue to be made available after that date (Article 52(1)). The requirements of Regulation (EU) 2023/1230 on the information sheet (Article 10, Annex III) apply from January 20, 2027, the date on which the directive is repealed (Article 51(2)); certain provisions, including Article 52, already apply (Article 54). A model launched in 2026 with copies placed on the market after January 20, 2027 falls under the regulation for those copies. The original text read «January 14, 2027»: the July 4, 2023 amendment replaced it with «January 20, 2027».
Can the instruction manual be provided solely in PDF format?
Under Regulation (EU) 2023/1230, the notice can be provided in digital format, under conditions (Article 10(7): access is indicated on the machine, or, failing that, on the packaging or an accompanying document; the notice can be printed, downloaded and saved; it remains online for at least ten years after the machine is placed on the market and for the entire intended lifetime of the machine; it is provided free of charge on paper, if requested by the user at the time of purchase. For machines intended for non-professional users, or likely to be used by them, the essential safety information is provided on paper.
Is a QR code sufficient for the EU declaration of conformity?
Yes, for the declaration: Regulation (EU) 2023/1230 allows the notice to provide an internet address or a machine-readable code that provides access to the EU declaration of conformity (Article 10(8); Annex III, point 1.7.4.2(c)), provided that the declaration remains online for the entire intended lifetime of the machine and for at least ten years after its placing on the market or putting into service. For the declaration itself, the manufacturer indicates on the machine how to access the digital declaration (Article 10(7)(a)); the text does not mention the QR code. Under Directive 2006/42/EC, the declaration contains «the EU declaration of conformity or a document presenting the content of the EU declaration of conformity, indicating the characteristics of the machine, without necessarily including the serial number and the signature» (Annex I, point 1.7.4.2(c)).
Will the paper notice disappear?
No. The digital format is an option provided by Regulation (EU) 2023/1230, not an obligation. And the regulation imposes the paper format in two cases (article 10 §7): at the request of the user at the time of purchase, free of charge and within one month; and, for machines intended for non-professional users or likely to be used by them, for the safety information essential for commissioning and safe use.
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