Machinery Regulation 2023/1230: Translated Instructions, Warnings and CE Documentation from January 2027
From 20 January 2027, the Machinery Regulation 2023/1230 replaces Directive 2006/42/EC. Instructions for use, safety information and warnings must be in a language users easily understand, as determined by each Member State, and may be supplied digitally under strict conditions. The EU declaration of conformity must be translated for each market. DEMA Solutions helps machinery manufacturers prepare and maintain this documentation in every language.
Who this guide is for
This guide is for technical documentation, localization and quality managers and technical writers at manufacturers of packaging and process machinery, lifting equipment, HVAC systems and automation lines, who export to many EU markets and manage manuals in Word, InDesign, FrameMaker or DITA.
The sections below answer their practical questions, from digital instructions to partly completed machinery, with references to Regulation (EU) 2023/1230 so you can check them yourself.
From Directive 2006/42/EC to Regulation (EU) 2023/1230
Regulation (EU) 2023/1230 repeals the Machinery Directive 2006/42/EC with effect from 20 January 2027 (Article 51) and applies from the same date (Article 54). The original publication said 14 January; a corrigendum published in the Official Journal in July 2023 moved the dates to 20 January, so older summaries quoting 14 January are out of date.
The new EU machinery regulation applies directly in every Member State, without national transposition; what each country still decides is the language users must receive. The transition follows the date a machine is placed on the market, not when it was designed. Under Article 52, Member States may not impede the making available of products placed on the market in conformity with the Directive before 20 January 2027. A machine placed on the market from that date must comply with the Regulation, documentation included, even if its design and manual have not changed for years.
The language rule has also been reworded. The Directive required instructions in the official language or languages of the Member State where the machine was placed on the market or put into service. The Regulation requires instructions, safety information and Annex III information “in a language which can be easily understood by users, as determined by the Member State concerned” (Article 10(7)). Most countries will still expect their national language or languages, but it is worth reviewing your market list against the new wording.
One familiar convention disappears from the legal text. Under the Directive, the verified language version carried the words “Original instructions” and every other version “Translation of the original instructions”. Annex III of the Regulation does not repeat that wording. Keeping a clearly identified source version remains good practice for change control, and the harmonised standards or customer requirements you work to may still expect it, but the Regulation’s emphasis is elsewhere: Article 10(7) requires the instructions to clearly describe the product model they correspond to, in every language.
Which documents must reach users in their language
The language obligations are spread across several articles and annexes. Read together, they define a documentation set.
Instructions for use. Article 10(7) requires machinery to be accompanied by instructions for use and the Annex III information, clear, understandable and legible, in a language users can easily understand. Annex III, section 1.7.4.2 lists the minimum content: manufacturer details, intended use, installation, putting into service, residual risks, protective measures and protective equipment, adjustment and maintenance, safety-relevant spare parts, noise emissions and rescue procedures, among others. Section 1.7.4.1 adds that instructions must cover reasonably foreseeable misuse, and that for non-professional operators the wording and layout must suit the general education and acumen they can reasonably be expected to have.
Information and warnings on the machinery. Annex III, section 1.7.1 prefers readily understandable symbols or pictograms, but any written or verbal information and warnings must be in a language users can easily understand, as determined by the Member State. Section 1.7.1.1 requires visual display units and other interactive means of communication between operator and machine to be easily understood, which brings HMI strings, alarm texts and on-screen help into scope. Section 1.7.3 requires the machine to bear the information essential for safe use, under the same language rule.
Identification and contact details. Article 10(5) requires the model, series or type designation, year of construction and any serial or batch number on the machine. Under Article 10(6), the manufacturer’s name, postal address and digital contact must appear too, in a language easily understood by users and market surveillance authorities. Importers have the same obligation for their own details under Article 13(3).
The EU declaration of conformity. Article 21(2) requires the declaration to follow the model in Annex V, Part A, to be continuously updated and to be translated into the language or languages required by the Member State where the machine is placed on the market, made available or put into service. Where several EU acts each require a declaration, Article 21(3) requires one single declaration covering all of them. Under Article 10(8), the declaration either accompanies the machine or the instructions give an internet address or machine-readable code to access it, and a digital declaration must stay online for the machine’s expected lifetime and at least 10 years.
Sales literature. Under Annex III, section 1.7.5, brochures must not contradict the instructions on health and safety and must repeat the same emission information, even when another team translates them.
One narrow exception exists. Under section 1.7.4, maintenance instructions for specialised personnel mandated by the manufacturer or its authorised representative may be supplied in a single official EU language those personnel understand. Maintenance instructions for the customer’s own technicians follow the general rule.
Digital instructions and the right to a paper copy
Digital instructions are the most visible change, and the most often misread as permission to stop translating. Under Article 10(7), when instructions are digital the manufacturer must mark how to access them on the machine, or where that is not possible on the packaging or an accompanying document. Users must be able to print, download and save them, so they are available at all times and in particular during a breakdown, including when the instructions are embedded in the machine’s software. They must stay online for the machine’s expected lifetime and at least 10 years after it is placed on the market.
Two limits apply. If the user asks at the time of purchase, the manufacturer must supply the instructions on paper, free of charge, within one month. And where machinery is intended for non-professional users, or can reasonably be used by them, the safety information essential for putting it into service and using it safely must always be supplied on paper.
None of this reduces translation: the language rule applies to digital and paper alike. What digital delivery changes is visibility. When every language version sits online for a decade, a German manual two revisions behind the Italian one is no longer hidden in a drawer; anyone can download both and compare them.
Partly completed machinery: assembly instructions and declaration of incorporation
For partly completed machinery sold to integrators, such as a conveyor module or a robotic cell without its guarding, the language logic shifts from the user to the person who incorporates the equipment. Under Article 11(7), partly completed machinery must be accompanied by the assembly instructions set out in Annex XI, in a language easily understood by the person who incorporates it, as determined by the Member State concerned. The same digital option applies, with an online period of at least 10 years and a free paper copy within one month on request at the time of purchase. Annex XI covers the conditions for correct incorporation, foreseeable misuse, installation, stability, transport and maintenance, and requires a clear description of the version of the assembly instructions that corresponds to the model.
The declaration of incorporation follows Annex V, Part B, and under Article 22(2) must be continually updated and translated into the language or languages required by the Member State where the equipment is placed on the market or made available. Distributors must check both under Article 16(2). Because your assembly instructions become source material for the integrator’s own manual, the terminology you fix now travels into their documentation too.
Technical documentation and requests from authorities
The technical documentation in Annex IV, Part A does not normally have to be translated into every market language. It contains the machine description, risk assessment, drawings, standards applied, test reports and a copy of the instructions for use, and under Article 10(3) it must be kept available, with the declaration, for at least 10 years.
The language question arises when an authority asks. Under Article 10(10), following a reasoned request from a competent national authority, the manufacturer must provide the documentation needed to demonstrate conformity in a language that authority can easily understand. Such requests come with deadlines, usually after something has gone wrong, so a risk assessment that exists only in the source language becomes urgent work.
CE marking for machinery and the documentation set behind it
The CE marking is the visible end of a documentation chain. Under Article 10(2), the manufacturer draws up the technical documentation, carries out the conformity assessment, draws up the EU declaration of conformity and affixes the CE marking, visibly, legibly and indelibly under Article 24, before the machine is placed on the market. The translated part of that chain usually comes down to a set of files that travel together:
- instructions for use, digital or paper, plus paper safety information where non-professionals may use the machine
- warnings, labels, markings and pictogram explanations on the machine
- HMI and display texts, alarm messages and embedded help
- the declaration of conformity, or the declaration of incorporation and assembly instructions
- manufacturer and importer contact details and the access marking for digital instructions
- sales literature that mentions safety or emissions
Treated as separate jobs ordered by different departments, these files produce a declaration naming one model, a manual describing another and a display using a third word for the emergency stop.
Who is responsible: manufacturers, importers, distributors and modifiers
The manufacturer carries the main obligations, but the Regulation checks them along the supply chain. Importers must ensure the machinery is accompanied by the instructions and information required by Article 10(7) (Article 13(4)). Distributors must verify, before making it available, that it carries the CE marking and is accompanied by the declaration and by instructions in a language easily understood by users as determined by the Member State concerned (Article 15(2)). In practice, a missing language version is more likely to stop a shipment at a distributor than to be found by an authority.
Others can become manufacturers. Under Article 17, that happens to an importer or distributor selling machinery under its own name or modifying it in a way that might affect compliance. Under Article 18, whoever carries out a substantial modification is considered the manufacturer for that machine. Article 3(16) defines a substantial modification as a physical or digital change, not foreseen or planned by the manufacturer, that affects safety by creating a new hazard or increasing an existing risk, and requires new guards or protective devices involving the safety control system, or additional measures for stability or mechanical strength. If you rebuild or retrofit lines for customers, that can leave you responsible for instructions, warnings and a declaration in the customer’s language.
Safety warnings: where translation errors matter most
Most translation errors in a manual are an inconvenience. Errors in safety information are a liability. The text that needs most care is also the shortest: hazard statements where a missing negation reverses an instruction, torque values, pressures, temperatures and load limits where a decimal separator or unit changes the meaning, residual risks, and the words on labels and displays, which must match the manual exactly.
These errors usually come from process, not language skill: a warning translated separately for the manual, the label and the HMI comes back three ways. The remedy is one approved glossary, a translation memory that reuses only approved wording, a second qualified linguist checking numbers, units and negations against the source, and reused text checked again in safety content.
Machine translation can help with large, repetitive documentation, especially when it runs on your own glossary and memory. For warnings and safety information, the safe route is human translation or a full post-edit by a qualified technical linguist, followed by revision. Our guide to post-editing for technical documentation explains where that line falls.
What changes for translation workflows
The Regulation mainly raises the cost of inconsistency.
Editions become public. With digital instructions online for at least ten years and declarations continuously updated, every language version carries an edition identity anyone can check. Translation has to be triggered by change control, so a design change releases all affected languages together.
The documentation set becomes one job. Instructions, labels, HMI texts, declarations and sales literature must agree, which argues for one shared terminology and memory across them. Companies working with several suppliers will find practical advice on managing translation across multiple vendors and markets.
Outputs multiply. Print, downloadable PDF and software-embedded text must come from the same translated source. Translations often run longer than the source, and shrinking type to fit undermines the legibility the Regulation requires. Solving expansion in the original InDesign, FrameMaker or XML files is the work of multilingual desktop publishing.
How to prepare before January 2027, step by step
Manufacturers who find January 2027 uneventful will be those who treated it as a documentation project with a deadline, not a translation order placed in December.
Build a market and language matrix. For every Member State you sell into, record the languages required for instructions, safety information, markings and the declaration, including countries with more than one official language. Confirm it with distributors and importers and keep it in your quality system.
Inventory the documentation set per product family. List instructions, safety information, labels, HMI and alarm texts, declarations, assembly instructions and safety-related sales literature, with the format and owner of each. HMI strings in a software repository and manuals in a content management system rarely share a workflow today.
Decide digital, paper or both, model by model. Digital instructions need an access marking, hosting that will last at least ten years, printable files in every language and a way to post a paper copy within a month. Decide early, because it shapes layout and output work.
Fix terminology first. Approve names for components, controls and hazards in each language. Our article on keeping technical terminology consistent across translators and suppliers explains how to build that glossary.
Make your translation memory work, and make sure it is yours. Approved sentences should be reused in every update, so a changed warning is translated once and everything else stays as approved. Contracts often leave ownership open, so settle who owns your translation memory before you sign.
Connect translation to change control. Give every language the same edition identifier and model description as the source, release them together, and update declarations to cite the Regulation for machines placed on the market from 20 January 2027. Decide too which language your technical file will be available in if an authority asks.
Review your suppliers. Ask who revises each translation, how numbers and units are checked, whether reused text is checked again and whether you receive memory and glossary in portable formats. A practical list of ten questions is in our guide to choosing a technical translation company.
Machinery that is also a medical device
Patient lifts, sterilisers and surgical tables can be both machinery and medical devices, and where a relevant hazard exists the EU Medical Device Regulation also applies the more specific machinery requirements. The medical side, with its own label content and a much narrower allowance for electronic instructions, is covered in our guide to EU MDR labeling requirements and languages. For instructions across EU product legislation more generally, our article on user manual translation is a useful companion.
How DEMA Solutions helps machinery manufacturers
We have translated machinery documentation for manufacturers for more than 20 years, with teams in Italy, Serbia and Spain. Our technical translation services follow an ISO 17100 certified process, with a second qualified linguist revising every translation and systematic checks on terminology, numbers and units. In safety-related projects, translations reused from the memory are checked again.
We cover the whole set described above: instructions and safety information, labels and markings, HMI texts, declarations of conformity and incorporation, assembly instructions and the sales literature that must agree with them. Your glossary and translation memory are built or cleaned first and stay yours, delivered in portable TMX and TBX formats. Our in-house DTP team works in your original files for print and digital output, and can make legacy PDFs editable when sources are lost.
Our page for manufacturing companies shows how we support a complete documentation programme, and the industrial manufacturer case study follows one Italian equipment maker that runs it through a single managed process.
Where TUBE fits
For manufacturers who update documentation with every product release, TUBE keeps the language of each edition under your control. Your glossary and translation memory control machine translation, every approved translation goes into a memory you own and can export, and leverage reporting shows how much of each update comes from text you have already approved.
Frequently asked questions
From 20 January 2027, when Directive 2006/42/EC is repealed. A 2023 corrigendum moved the date from the originally published 14 January. Machinery placed on the market in conformity with the Directive before that date may still be made available.
No. It requires a language easily understood by users, as determined by the Member State concerned. Check each market's national rule and record it in a language matrix.
Yes, if the manufacturer marks how to access them, makes them printable, downloadable and savable, and keeps them online for the expected lifetime and at least 10 years. Users can still request a free paper copy at purchase, within one month, and essential safety information for machinery non-professionals may use must be on paper.
That wording came from Directive 2006/42/EC and is not repeated in the Regulation's Annex III. A clearly identified source version is still good practice, and some standards and customers still expect the labels, but the Regulation focuses on each version clearly describing the product model it covers.
Yes, into the language or languages required by the Member State where the machinery is placed on the market, made available or put into service, and kept continuously updated. The declaration of incorporation follows the same principle.
Not into every language as a rule. On a reasoned request from a competent national authority, the documentation must be provided in a language that authority can easily understand.
Whoever carries out the substantial modification is considered the manufacturer for that machine, including for instructions and the declaration of conformity. A non-professional user modifying a machine for their own use is excluded.
Get your documentation ready for 20 January 2027
If you ship machinery into several EU markets, tell us which documents and languages you need to prepare. We will review your instructions, warnings and declarations against the Regulation and plan translation and layout around your markets and release calendar.
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