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Machinery Regulation instead of Machine Directive – is it really just a cosmetic change?

Prologue

For several weeks now, I have been intensively analyzing the topic of the new Machinery Regulation 2023/1230, which will replace the Machinery Directive 2006/42/EC that has been in force for years. This is a document that – although it seems to have passed almost unnoticed – brings with it significant changes and a lot of work for manufacturers, system integrators and teams dealing with technical documentation.

Silence before the storm?

I was surprised by how little is being said about this change. In the media, social media, and industry portals, the topic is practically going unnoticed. Yet the Regulation was published on 29 June 2023 and came into force on 19 July 2023, although full enforcement will not begin until 14 January 2027 – which means we have a period of vacatio legis that allows for proper preparation.

And this is where the crux of the matter lies. This time must be used wisely, because although at first glance the changes may seem cosmetic, in practice they entail a series of obligations and modifications to existing documentation processes.

What is changing?

Here are three key aspects worth knowing:

  1. The necessity to update references from MD to those that will direct to MR – this means reviewing and editing every document that contains legal references. For companies with extensive technical documentation, this amounts to weeks of work.
  2. The possibility of introducing an electronic version of the user manual – this is a revolution that opens up new opportunities in the field of document publishing, but it also requires careful consideration of access paths, content structure, and compliance with specific formal requirements.
  3. Enabling producers to reduce costs associated with instructions – provided that the transformation process is implemented in accordance with the requirements and does not expose the company to legal liability.

Epilogue

From my point of view, it is not just a matter of changing document numbers or updating formats. It is a transformation process that requires knowledge, team coordination, and often also a change of tools and habits.

Implementing the Machinery Directive is not just a change in regulations – it is a change in the approach to documentation as a product element. And although it sounds dry, I know from experience that a well-executed adaptation can bring real benefits – greater clarity of content, better accessibility of documentation, and long-term cost reduction.

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