Machinery Regulation 2023/1230: memo for 2027
The new European Union Machinery Regulation will come into force in January 2027. It is therefore high time to prepare for the change with this short five-point memo.
The Groupement des équipementiers du process et du packaging des industries alimentaires et non alimentaires (GEPPIA) has issued a timely reminder that the new Machinery Regulation 2023/1230, which replaces Directive 2006/42/EC, will come into force on 20 January 2027. This new text thoroughly modernises the regulatory framework for machinery in Europe, taking into account technological advances and new risks that have emerged over the last twenty years.
It can be consulted in full on the website of the Official Journal of the European Union, but as you may not have the time to read 102 pages in one go, here are the main changes brought about by the new regulations, summarised in five points.
- A broader scope:
- The scope of the Machinery Regulation 2023/1230 now covers not only machinery, but also partly completed machinery (not yet fully assembled), safety components, interchangeable equipment, mechanical transmission devices, safety-critical software and lifting accessories (chains, cables, straps, etc.).
- Better consideration of new digital technologies:
- The regulation explicitly recognises the new risks associated with digital technologies used in machinery. In particular, it introduces specific requirements for machinery incorporating artificial intelligence, critical software or autonomous functions. It also requires protection against cyber attacks that could affect safety, guarantees for software updates and better control of the risks associated with the autonomous decision-making of machinery.
- Software is now recognised as a safety component, its updates must be controlled and traceable, and manufacturers must anticipate the risks associated with autonomous decision-making, data interpretation and possible unexpected behaviour of the machine.
- Independent testing for high-risk machines:
- This marks the end of self-assessment for this category of machines, which is divided into six subcategories by the new regulation (autonomous and self-learning control systems, portable motor-powered chain saws, lifting machines for persons with a risk of falling from a height of more than 3 m, lifting machines for loads with vertical guidance and persons exposed, manually loaded mechanical and hydraulic presses, and manually loaded woodworking machines with moving blades). These machines must now undergo mandatory assessment by a third-party body, even if they comply with harmonised standards.
- Introduction of the concept of ‘substantial modification’:
- When a company (user, integrator, etc.) modifies a machine in such a way (particularly through software modifications) that its operation or safety performance is changed, it is now considered to be a manufacturer, with the obligations associated with this status: obligation to carry out a complete conformity assessment, assumption of legal responsibility in the event of a problem, drafting of a new declaration of conformity and affixing of the CE marking.
- Promotion of digital documentation:
- In order to reduce costs and facilitate access to technical information, the new regulation authorises and even encourages the provision of documents in digital format (instruction manuals, EU declarations of conformity, maintenance or safety information, etc.). However, if the user requests it, a paper version may be provided at no extra cost.
There is no doubt that compliance with this new regulation will be at the heart of discussions in the aisles (and conference rooms) of the next ALLFORPACK EMBALLAGE PARIS trade show (24-26 November 2026), where, as in every edition, processing industry players will play a major role alongside representatives from the show’s three other sectors (packaging, printing and logistics).
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