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Machinery Regulation transition: from Directive 2006/42/EC to Regulation 2023/1230

Last reviewed: October 2026 · Sources listed at the end of this page.

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.

At a glance. Machinery placed on the EU market up to and including 19 January 2027 follows Directive 2006/42/EC. From 20 January 2027, the Regulation applies and the Directive is repealed (Articles 51 and 54). As of 31 October 2026 we found no postponement. Units already placed on the market may continue to be sold (Article 52(1)). EC type-examination certificates stay valid until they expire (Article 52(2)). As of late October 2026, no list of harmonised standards under the Regulation had appeared in the Official Journal: the Commission says that the first one is being prepared for the end of 2026. A Notified Body is needed only for Annex I categories, as explained below.

Key dates

DateWhat happened or happensProvision
19 July 2023Regulation enters into force. Article 52 applies from this date.Article 54
20 January 2024Notified body rules applyArticles 26 to 42, Article 54
20 October 2026National penalty rules apply and were to be notified to the CommissionArticle 50, Article 54
19 January 2027Last day to place a unit on the market under the DirectiveArticles 51, 52 and 54
20 January 2027Regulation applies generally and the Directive is repealedArticles 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 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

ScenarioGoverning law
Press built and delivered to an EU distributor on 12 January 2027, sold on in March 2027Directive. 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 2027Regulation. On our reading, no supply took place before the date.
Machine ordered in 2026, shipped and delivered to the customer on 25 January 2027Most 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, unchangedNo new placing on the market. Article 52(1) protects it.
Machine in service substantially modified in 2027The 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 2027On 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.

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 2027From 20 January 2027
Act citedDirective 2006/42/ECRegulation (EU) 2023/1230
BasisDirective Annex II 1.AArticle 21 and Annex V Part A
Partly completed machineryDeclaration of incorporation, Directive Annex II 1.BEU declaration of incorporation, Article 22 and Annex V Part B
DeliveryCopy accompanies the machineWith the product, or by web address or machine-readable code (Article 10(8))
Essential requirementsDirective Annex IRegulation Annex III

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:

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

  1. Inventory. List every model, safety component, lifting accessory and partly completed machine you make, import or sell into the EU.
  2. 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.
  3. Classify again. Check each product against the Annex I Parts A and B and the Article 3 definitions, including standalone safety software.
  4. 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.
  5. Update the risk assessment to Annex III's general principles.
  6. Book a Notified Body if needed. Confirm that it is notified under the Regulation for your category, and ask about capacity.
  7. Review certificates. Record expiry dates and how each will be handled.
  8. Map standards. Note which ones you use, their status, and what you will do if one is not listed by the deadline.
  9. Rebuild the technical file to Annex IV of the Regulation, and plan for the ten-year retention.
  10. Prepare declarations and marking. Set up two templates, update labels, and check the Article 10 marking details.
  11. 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.
  12. 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.
  13. Brief importers and distributors on documents, cut-off dates and how to tell the two regimes apart.
  14. 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