Going Paperless

Going Paperless: The Shift to Digital Instructions and Declarations Under Machinery Regulation (EU) 2023/1230

For decades, the machinery sector has been burdened by the heavy administrative and environmental costs of printing massive, multi-language paper manuals. With the transition from the old Machinery Directive 2006/42/EC to the new Machinery Regulation (EU) 2023/1230, the European Union has officially modernized its documentation requirements.

For safety managers, engineers, and manufacturers, this represents a major administrative shift: the legal allowance of digital instructions for use and digital EU Declarations of Conformity. Here is your comprehensive guide to going paperless while maintaining strict regulatory compliance.

The New Standard: Digital Instructions for Use

Under the new Regulation, manufacturers are no longer strictly bound to provide a physical, printed manual with every piece of equipment. The instructions for use may now be provided in a digital format.

However, simply putting a PDF on a hidden webpage is not enough. To legally provide documentation online, safety professionals must ensure their digital deployment strategy meets the following strict regulatory criteria:

• Clear Access Instructions: You must clearly mark on the machinery or related product—or, if that is not possible, on its packaging or in an accompanying document—exactly how the user can access the digital instructions.
• Offline Accessibility: The digital instructions must be presented in a format that makes it possible for the user to print and download them. Crucially, users must be able to save the manual on an electronic device so they can access it at all times, especially during a machine breakdown when internet access might be unavailable. This requirement also applies if the instructions are embedded directly into the machine's software.
• 10-Year Minimum Availability: You cannot delete the manual when you stop selling the model. The digital instructions must remain accessible online for the expected lifetime of the machinery, and for at least 10 years after the machinery or related product was placed on the market.

The "Paper Copy on Demand" Rule

While the shift to digital is a massive win for efficiency, the Regulation ensures that users who require physical documents are not left behind. Safety and sales teams must be prepared to fulfill the "paper copy on demand" requirement.

If a user requests a paper format at the time of purchase, the manufacturer is legally obligated to provide it free of charge within one month.

Furthermore, there is a critical exception for consumer products. If the machinery or related product is intended for non-professional users (or could reasonably be used by them), the manufacturer must provide the essential safety information required for putting the machinery into service and using it safely in a physical paper format. You cannot rely entirely on digital documentation if your product might end up in the hands of a consumer.

Digital EU Declarations of Conformity

The paperless shift also applies to the most critical compliance document: the EU Declaration of Conformity.

Previously, a physical declaration had to accompany the machine. Now, manufacturers have a choice. You can ensure the machinery is accompanied by the EU declaration of conformity, or alternatively, you can provide the internet address or a machine-readable code (such as a QR code) where the EU declaration of conformity can be accessed. This link or code must be included in the instructions for use and the required safety information.

Just like the user manuals, these digital EU declarations of conformity must be made accessible online for the expected lifetime of the machinery, and in any event for at least 10 years after the product is placed on the market or put into service.

Rules for Partly Completed Machinery (PCM)

If your company manufactures Partly Completed Machinery (PCM), the digital rules apply to you as well.

Manufacturers of PCM can provide digital assembly instructions. You must provide clear access instructions on the PCM or packaging, allow the integrator to download and print the file, and keep it online for at least 10 years. Similarly, the integrator can request a free paper copy of the assembly instructions at the time of purchase, which must be provided within one month.

Additionally, the EU Declaration of Incorporation for partly completed machinery can also be digitized. You may provide the internet address or a machine-readable code to access the declaration within the assembly instructions, provided it remains accessible online for at least 10 years.

Action Plan for Safety Professionals

The shift to digital documentation under Regulation (EU) 2023/1230 offers immense opportunities to reduce printing costs, ensure users always have the most updated safety information, and shrink your environmental footprint. To prepare for the 2027 enforcement deadline, safety managers should:

1. Audit your current manuals to ensure they are highly legible, downloadable, and printable.
2. Establish a secure online repository capable of hosting manuals and Declarations of Conformity for a minimum of 10 years.
3. Update machine labels and packaging to include clear URLs or QR codes directing users to the documentation.
4. Create an internal workflow to quickly print and mail free paper manuals within the one-month legal window for users who request them at the time of purchase.