Machinery Directive vs Machinery Regulation: the Comparison
On 20 January 2027 Machinery Regulation (EU) 2023/1230 replaces Machinery Directive 2006/42/EC. This page is intended as a working reference for the transition: the complete comparison table of all references based on the official correlation table (Annex XII of the Regulation), the deadlines, the transitional rules, an interactive Part A/Part B check and a gap-analysis checklist as a free PDF, without registration.
All deadlines of the Regulation at a glance
Publication in the Official Journal
Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, p. 1. Corrigenda: OJ L 169, 4.7.2023 (date corrections) and OJ L, 2025/90297, 1.4.2025 (German language version).
Entry into force
Start of the roughly 42-month transition period. The transitional provisions (Article 52) and the criteria for adapting the high-risk list (Article 6(7)) have applied since this day.
Notified bodies
Articles 26 to 42 apply: conformity assessment bodies have been able to seek notification for the Regulation since then. The scope per body can be looked up in the NANDO database.
Penalty provisions
Article 50(1) applies: the member states lay down rules on penalties for infringements and notify them to the Commission.
Cut-over date: the Regulation applies, the Directive is repealed
From this day all machinery newly placed on the market or put into service must comply with the Regulation (Article 54); Directive 2006/42/EC is repealed with effect from this day (Article 51(2)). There is no sell-off period for new products under the Directive.
The comparison table: every reference, Directive to Regulation
The table follows the official correlation table in Annex XII of the Regulation and adds what changes in substance. You may use and link to it freely; a link to this page is sufficient as the source.
| Topic | Directive 2006/42/EC | Regulation (EU) 2023/1230 | What changes |
|---|---|---|---|
| Legal form | EC directive, national transposition required (in Germany, among others, the 9. ProdSV) | EU regulation, directly applicable in all member states | National transposition laws fall away; the wording applies uniformly across the EU. |
| Manufacturer obligations | Article 5 | Article 10 (machinery), Article 11 (partly completed machinery) | Catalogue of obligations considerably more detailed; technical documentation and Declaration of Conformity to be kept for at least 10 years (Article 10(3)). |
| Essential requirements (EHSRs) | Annex I | Annex III | New, among others: protection against corruption (section 1.1.9), extended control system requirements including self-evolving behaviour (section 1.2.1) and requirements for autonomous mobile machinery (Chapter 3). |
| High-risk list | Annex IV (23 categories) | Annex I, split into Part A (6) and Part B (19) | Part A: notified body always mandatory, even with full application of standards; two new categories for machine-learning-based safety functions. |
| Conformity assessment procedures | Article 12 | Article 25 | Structure retained; new is unit verification (Module G) as a fourth route. |
| Internal production control | Annex VIII | Annex VI (Module A) | Carried over in substance, now named as the classic Module A. |
| Type-examination | EC type-examination, Annex IX | EU type-examination, Annex VII (Module B), followed by Annex VIII (Module C) | Certificates are valid for a maximum of 5 years (Annex VII No 6.1); under the Directive a five-yearly review was sufficient. |
| Full quality assurance | Annex X | Annex IX (Module H) | Carried over in substance. |
| Unit verification | not provided for | Annex X (Module G) | New: examination of the individual product by the notified body, relevant for special-purpose machinery built in a quantity of one. |
| Declaration of Conformity | Annex II Part 1 Section A | Annex V Part A | May be provided digitally via an internet address or machine-readable code (Article 10(8)); standard references with the OJEU publication date and, where applied in part, the parts applied. |
| Declaration of Incorporation (partly completed machinery) | Annex II Part 1 Section B | Annex V Part B | New, among others: the date of the standard or common specification. |
| Technical documentation | Annex VII (Parts A/B) | Annex IV (Parts A/B) | New, among others: source code or programming logic of safety-relevant software on reasoned request by the authority (Part A point (m)) and descriptions of sensor-driven and autonomous functions (point (n)). |
| Instructions | Annex I section 1.7.4 | Annex III section 1.7.4 in conjunction with Article 10(7) | Digital form expressly permitted; paper version free of charge on request at the time of purchase, within one month; for non-professional users the essential safety information still on paper. |
| Assembly instructions (partly completed machinery) | Annex VI | Annex XI | Extended mandatory content; digital provision possible (Article 11(7)). |
| List of safety components | Annex V | Annex II | New, among others: software performing safety functions (No 18). |
| CE marking | Article 16, Annex III | Articles 23 and 24 | Rules follow the uniform EU legal framework (Regulation (EC) No 765/2008). |
| Notified bodies | Article 14, Annex XI | Articles 26 to 42 | Already applicable since 20 January 2024 so that bodies can be notified for the Regulation in time. |
| Substantial modification | not regulated (national interpretation, in Germany the BMAS interpretation paper) | Article 3(16) (definition), Article 18 (manufacturer obligations) | Defined EU-wide for the first time; whoever substantially modifies a machine (including digitally) becomes the manufacturer in law. |
| Penalties | Matter for the member states | Article 50 (applies from 20 October 2026) | Member states must lay down effective, proportionate and dissuasive penalties; criminal sanctions possible for serious infringements. |
Basis: Annex XII of the Regulation (correlation table) and the text of the Regulation, OJ L 165, 29.6.2023, p. 1, corrected by OJ L 169, 4.7.2023, p. 35 and OJ L, 2025/90297, 1.4.2025. References checked against the official full text on 18 August 2026.
Quick check: Part A or Part B?
The commercially most important switch in the Regulation is Annex I: for the six categories in Part A, a notified body must always be involved from 20 January 2027; for the 19 categories in Part B only if the relevant harmonised standards are not applied in full. Check in two steps where your product stands:
The standards situation under the Regulation: the often overlooked bottleneck
The presumption of conformity applies only to harmonised standards whose references are published in the Official Journal of the EU under the Regulation (Article 20(1) of the Regulation). And exactly this list is still empty as of 18 August 2026: there is as yet no implementing decision with standard references under the Regulation; all citation decisions so far (most recently Implementing Decision (EU) 2026/546 of 12 March 2026) belong to the Machinery Directive.
What is planned: The Commission issued the standardisation request for the Regulation on 20 January 2025 (Implementing Decision C(2025) 129). The body of standards under the Directive is to be carried over largely unchanged insofar as the standards cover the same requirements; an updated list of standards is expected from the Expert Group on Machinery for October 2026, and a first citation decision under the Regulation by the end of 2026.
What this means in practice: Anyone who wants to use self-assessment under Article 25(3) of the Regulation for a Part B machine needs standards with a citation under the Regulation on the cut-over date. Watch the Commission's list of references and document the state of the standards per project. For the new requirements (cybersecurity under Annex III sections 1.1.9 and 1.2.1, AI, autonomy) no harmonised standards exist yet; industry associations are therefore calling for a postponement of the cybersecurity requirements, but nothing has been decided. Plan without a postponement.
The Regulation provides two fallbacks: common specifications adopted by the Commission (Article 20(3) and (6) of the Regulation) and, specifically for the cybersecurity requirements, the presumption of conformity from certification under a scheme of the Cybersecurity Act (EU) 2019/881 (Article 20(9) of the Regulation). Neither yet replaces the missing standards across the board. How the Regulation's cybersecurity requirements relate to the Radio Equipment Directive and the Cyber Resilience Act is explained in Cybersecurity for machinery.
The Commission's official guide to the Regulation (successor to the guide to the Machinery Directive) has also not yet been published as of 18 August 2026; the drafting groups have been working since the start of 2025, and a first edition is expected around the turn of the year 2026/27.
Gap-analysis checklist Directive to Regulation (free PDF)
The checklist guides you through the transition in 10 fields of action, each check item with its reference in the text of the Regulation. It is free, requires no registration and may be shared within your company and with customers. The PDF is currently available in German; the ten fields of action are listed here in English.
- 1Clarify deadlines and whether you are affected
- 2Determine the Annex I classification (Part A or Part B) and the procedure
- 3Extend the risk assessment to the new requirements
- 4Convert the technical documentation
- 5Adapt the Declaration of Conformity and CE marking
- 6Prepare the instructions (digital provision)
- 7Settle obligations in the supply chain
- 8Partly completed machinery: Declaration of Incorporation and assembly instructions
- 9Monitor and document the standards situation
- 10Organisation, training and schedule
5 pages · 0.3 MB · as of 18 August 2026
Transitional rules: what happens on the cut-over date to existing stock, warehouse and certificates
Article 52 of the Regulation governs the transition and has been in force since 19 July 2023. Three situations need to be distinguished:
Placed on the market before 20 January 2027
Products conforming to the Directive that were placed on the market before the cut-over date may continue to be made available, sold and put into service (Article 52(1)). Sell-off through the distribution chain remains permitted. What counts is the individual unit, not the product line.
Not yet placed on the market on the cut-over date
Finished machines still in the manufacturer's warehouse on 20 January 2027 and first supplied only afterwards are not covered by the transitional rule: they must comply with the Regulation. Anyone delivering around the cut-over date should document the placing on the market per unit cleanly (contract, delivery, transfer of risk).
Certificates from the Directive regime
EC type-examination certificates and approvals under Article 12 of the Directive remain valid until they expire (Article 52(2)). For placing on the market from the cut-over date, however, they alone do not suffice: then the conformity assessment procedure under Article 25 of the Regulation is decisive.
FAQ
Frequently asked questions about the transition from the Directive to the Regulation
Where is it officially stated which annex of the Directive corresponds to which annex of the Regulation?
May I still sell machinery under the Machinery Directive after 20 January 2027?
Do EC type-examination certificates under the Directive remain valid under the Regulation?
Can I voluntarily declare conformity with the Regulation before 20 January 2027?
Are there already harmonised standards under the Machinery Regulation?
Does the Machinery Regulation also apply to existing machinery already in operation?
What happens to the German Machinery Ordinance (9. ProdSV)?
Sources
- Regulation (EU) 2023/1230 on machinery, OJ L 165, 29.6.2023, p. 1: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1230
- Consolidated version of the Regulation (with the corrigenda of 4.7.2023 and 1.4.2025): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02023R1230-20230629
- Directive 2006/42/EC on machinery, OJ L 157, 9.6.2006, p. 24: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006L0042
- References of harmonised standards for machinery (European Commission): https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/machinery-md_en
- Notified bodies (formerly NANDO, now the European Commission's Single Market Compliance Space): https://webgate.ec.europa.eu/single-market-compliance-space/#/home
- DGUV Test: transition to the EU Machinery Regulation (FAQ and flowcharts, in German): https://www.dguv.de/dguv-test/prod-pruef-zert/konform-prod/maschinen/eu-maschinenverordnung/index.jsp
A note on our own behalf: CE-Copilot tracks the Annex I classification, the choice of procedure under Article 25 of the Regulation and the Declaration of Conformity under Annex V automatically in the project, under the Directive today and under the Regulation from the cut-over date. To see what that looks like, take a look at the free sample dossier or go straight to the free trial.