Machinery Regulation transition: from Directive 2006/42/EC to Regulation 2023/1230
On 20 January 2027, Regulation (EU) 2023/1230 replaces Machinery Directive 2006/42/EC. There is no parallel period in which a manufacturer picks either law for a given unit. What matters is when each individual unit is placed on the market. This page covers the switch itself: which law applies, what happens to stock and certificates, what to change in the declaration, where standards stand, and what to do in the time left. For the content of the Regulation, see our Machinery Regulation summary.
Key dates
| Date | What happened or happens | Provision |
|---|---|---|
| 19 July 2023 | Regulation enters into force. Article 52 applies from this date. | Article 54 |
| 20 January 2024 | Notified body rules apply | Articles 26 to 42, Article 54 |
| 20 October 2026 | National penalty rules apply and were to be notified to the Commission | Article 50, Article 54 |
| 19 January 2027 | Last day to place a unit on the market under the Directive | Articles 51, 52 and 54 |
| 20 January 2027 | Regulation applies generally and the Directive is repealed | Articles 51 and 54 |
What decides which law applies
The test is the date of placing on the market, which Article 3(12) defines as the first making available of a product on the Union market. Making available means any supply for distribution or use on that market in the course of a commercial activity (Article 3(11)). Three points follow.
- The test runs unit by unit. The Blue Guide applies placing on the market to each individual product, not to a type. A model launched in 2020 is not "grandfathered": a unit first supplied on 20 January 2027 needs to meet the Regulation.
- Manufacture date is not the test. A machine built in December 2026 but first supplied in February 2027 falls under the Regulation.
- Earlier sale of the design does not help. Only units actually supplied by the deadline are covered.
The Commission machinery page says that machinery placed on the EU market before 20 January 2027 must comply with the Directive, and that the Regulation applies on a mandatory basis from that date. It also says that manufacturers may state on an EU Declaration of Conformity that such machinery also conforms with the Regulation, if applicable. That is an extra statement on a Directive product, not a way of leaving the Directive early.
Worked examples
| Scenario | Governing law |
|---|---|
| Press built and delivered to an EU distributor on 12 January 2027, sold on in March 2027 | Directive. It was placed on the market in January. The distributor may sell it on. |
| Press finished on 12 January 2027, kept in the EU manufacturer's own warehouse, first supplied on 2 February 2027 | Regulation. On our reading, no supply took place before the date. |
| Machine ordered in 2026, shipped and delivered to the customer on 25 January 2027 | Most likely the Regulation, if the first supply falls on or after 20 January. Take advice on the contract terms if the order was complete and the product already made. |
| Used Directive-marked machine resold in the EU in 2028, unchanged | No new placing on the market. Article 52(1) protects it. |
| Machine in service substantially modified in 2027 | The modifier is treated as the manufacturer for the Regulation (Articles 3(16) and 18). |
| Machine built by a company for its own use, first used in February 2027 | On our reading, the Regulation, because Article 52 protects only products placed on the market. Confirm with your authority, as guidance is pending. |
Late cases around the deadline are fact-specific. Keep dated evidence of supply, such as delivery notes and invoices.
Stock already on the market
Article 52(1) stops Member States from impeding the making available of products placed on the market under the Directive before 20 January 2027. Distributors and dealers may therefore sell those units after the date, and no re-marking or new declaration is needed. Market surveillance continues: Chapter VI of the Regulation applies to those products in place of Article 11 of the Directive, and has done since 19 July 2023.
Stock is safe only if it has passed out of the first supply stage. Importers and manufacturers should treat units not yet supplied by 19 January 2027 as Regulation products. Where an EU importer already holds imported units, whether they have been placed on the market depends on the facts of the supply, so check before relying on the date. For planning, assume that anything not delivered onward by the deadline needs a conforming route. See importer obligations and distributor obligations.
Certificates and approvals
Article 52(2) provides that EC type-examination certificates and approval decisions issued under Article 12 of Directive 2006/42/EC remain valid until they expire. No reissue is triggered on 20 January 2027. Three cautions apply.
- Validity is not conformity. The certificate examined the design against Directive requirements. A unit placed on the market from 20 January 2027 must meet Annex III of the Regulation, including its new requirements. Ask your Notified Body how it treats your certificate for new units.
- Expiry dates matter. Diarise them. A new assessment under the Regulation is needed once a certificate lapses.
- Check your body's status. A body must be notified under the Regulation to issue Regulation certificates. Do not assume that a body notified under the Directive has moved across. Check NANDO, and the CE number lookup for a quick identification. TÜV SÜD announced its notification in September 2024, and others have followed.
Routes also change. Under Article 25, Annex I Part A products must use Module B + C, H or G. Part B products may use Module A only where harmonised standards or common specifications covering all relevant essential requirements were applied. Other machinery uses Module A. Compare your product with the new Annex I rather than old Annex IV.
Declaration of Conformity wording
The declaration has to match the law that governs the unit.
| Placed on the market to 19 January 2027 | From 20 January 2027 | |
|---|---|---|
| Act cited | Directive 2006/42/EC | Regulation (EU) 2023/1230 |
| Basis | Directive Annex II 1.A | Article 21 and Annex V Part A |
| Partly completed machinery | Declaration of incorporation, Directive Annex II 1.B | EU declaration of incorporation, Article 22 and Annex V Part B |
| Delivery | Copy accompanies the machine | With the product, or by web address or machine-readable code (Article 10(8)) |
| Essential requirements | Directive Annex I | Regulation Annex III |
- Have two templates ready and tie the choice to the supply date, not the document date. Our declaration generator gives a starting draft.
- From the date, update lists of other acts as well, and cite standards only with a presumption under the Regulation or as other technical specifications. Check Annex V Part A itself for the required content.
- Article 51(2) reads references to the Directive as references to the Regulation under the correlation table in Annex XII. That helps with other laws and contracts. We would not rely on it to carry a Directive declaration over to a new unit.
- Article 21 also requires the declaration to be kept up to date and translated as the Member State requires. The technical file and declaration are kept for at least ten years (Article 10(3)).
Standards status
Article 20 gives presumption of conformity with Annex III only for harmonised standards whose references are published in the Official Journal. Listing under the Directive does not itself give presumption under the Regulation.
As of late October 2026:
- The list under the Directive is Implementing Decision (EU) 2023/1586, last amended on 4 September 2026 according to the Commission harmonised standards page. Trade sources identify that amendment as Implementing Decision (EU) 2026/2015. The Commission page says that 20 January 2027 is the end of legal effect for that list.
- The same page says that a new implementing decision listing standards under the Regulation is in preparation, and that the first list can be expected before the end of the year. We found no such publication by 31 October 2026.
- Reports of a Commission answer of 6 August 2026 (E-002354/2026) say that it plans to re-cite most existing standards in the fourth quarter of 2026, and that standards on cyber safety and AI have not been delivered. We could not open the answer itself, so treat this as reported.
- Industry reporting expects possible restrictions where a re-cited standard does not cover new requirements.
- The final standardisation request was adopted in January 2025, and new standards are still in work.
- The Commission's guide to the Regulation is reported as due in the fourth quarter of 2026, and draft chapters appeared in October 2026. Drafts are not final, and the guide will not be legally binding.
Why this matters. Without a usable cited standard, you can still comply by showing that Annex III is met another way, but you carry the full burden of proof. For an Annex I Part B product, losing the cited standard also closes Module A and means a Notified Body. Check the Official Journal for each standard you rely on, including its restrictions, and see harmonised standards.
Readiness checklist
- Inventory. List every model, safety component, lifting accessory and partly completed machine you make, import or sell into the EU.
- Set a cut-off. Name the last delivery date for Directive units, allowing for logistics and customs. Plan production so that nothing unplanned is left in the first supply stage on 20 January.
- Classify again. Check each product against the Annex I Parts A and B and the Article 3 definitions, including standalone safety software.
- Run a gap analysis. Compare each design with Annex III. Focus on protection against corruption (1.1.9), control systems (1.2.1) and any self-evolving behaviour.
- Update the risk assessment to Annex III's general principles.
- Book a Notified Body if needed. Confirm that it is notified under the Regulation for your category, and ask about capacity.
- Review certificates. Record expiry dates and how each will be handled.
- Map standards. Note which ones you use, their status, and what you will do if one is not listed by the deadline.
- Rebuild the technical file to Annex IV of the Regulation, and plan for the ten-year retention.
- Prepare declarations and marking. Set up two templates, update labels, and check the Article 10 marking details.
- Decide on instructions. Digital instructions are allowed under Article 10(7) with conditions, including a free paper copy on request at purchase, and paper safety information for non-professional users.
- Tell the supply chain. Ask suppliers of partly completed machinery and safety components for Regulation documents. A final machine placed on the market from 20 January 2027 must meet the Regulation even if a part was bought earlier under the Directive.
- Brief importers and distributors on documents, cut-off dates and how to tell the two regimes apart.
- Check other laws. The transition does not change the other acts that apply, such as the Cyber Resilience Act and the AI Act.
Frequently asked questions
When does the Machinery Regulation apply?
From 20 January 2027. Directive 2006/42/EC is repealed with effect from the same date. The last day to place a unit on the market under the Directive is 19 January 2027.
Has the January 2027 date been postponed?
We found no postponement as of 31 October 2026. Industry groups have asked for delay on some cybersecurity provisions, and the Commission page still gives 20 January 2027. Check the Official Journal if you are reading this later.
Why do some copies of the Regulation say 14 January 2027?
The original Official Journal text had clerical errors in its dates. A corrigendum of 4 July 2023 corrected them, and 20 January 2027 is the correct date. Use the corrected or consolidated text.
Can I keep selling Directive machinery after 20 January 2027?
Yes, for units placed on the market under the Directive before that date. Article 52(1) stops Member States from impeding their making available. Units first supplied on or after 20 January 2027 must meet the Regulation.
Can I apply the Regulation early?
Machinery placed on the market before 20 January 2027 must still comply with the Directive. The Commission says that manufacturers may also state on the declaration that it conforms with the Regulation, if applicable.
Do EC type-examination certificates lapse on 20 January 2027?
No. Under Article 52(2), they remain valid until they expire. That does not remove the need for new units to meet the Regulation, so ask your Notified Body how it will treat them.
Do existing harmonised standards work under the Regulation?
Not automatically. Presumption of conformity under Article 20 needs a reference published in the Official Journal under the Regulation. The Commission says that a first list is being prepared for the end of 2026. Check it when it appears.
Sources
- Regulation (EU) 2023/1230 on machinery, OJ L 165, 29.6.2023, p. 1, as corrected: EUR-Lex. Article text was read from a reproduction of the corrected Official Journal text at ai-resources.eu, because EUR-Lex would not load for us. Check the official text before relying on the wording.
- Corrigendum to Regulation (EU) 2023/1230 of 4 July 2023, as described by BAuA and the Commission machinery page.
- Directive 2006/42/EC: EUR-Lex.
- European Commission: Machinery and Harmonised standards for machinery.
- Commission Notice, Blue Guide 2022, section 2.3: EUR-Lex.
- IBF: Status of harmonised standards and News on the guide (October 2026).
- Foresight: report of Commission answer E-002354/2026 (August 2026). The answer did not load for us.