The new Machinery Regulation. What changes as of January 20, 2027.
2027 from January 20
What changes
Four changes, straight from the text.
On January 20, 2027, Regulation (EU) 2023/1230 takes the place of Directive 2006/42/EC. These are the changes that matter to anyone who builds control panels, writes machine software or carries out revamping.
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Arts. 51 and 54
One law, the same across the entire EU.
It is a regulation, not a directive: it applies as written in every Member State, with no national transposition laws. Directive 2006/42/EC is repealed as of January 20, 2027.
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Art. 3
Software counts as a safety component, too.
A safety component can be physical or digital, “including software.” And a substantial modification can also be made by digital means.
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Annex III, point 1.1.9
The machine is protected against corruption.
Software and data critical to safety must be protected against accidental or intentional corruption. A connected device, even a remote one, must not create a hazardous situation.
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Annex III, point 1.2.1
Safety software versions leave a trail.
The control system must make it possible to log interventions and the versions of safety software uploaded after the machine is put into service, for five years.
The question that matters
Who is the manufacturer? It depends on what is done to the machine.
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Case 01
A new machine.
The manufacturer is whoever places it on the market and signs the EU declaration of conformity.
With us, that is settled at the start. If we are the manufacturer, the CE marking is ours; if it is you or whoever builds the mechanical side, we deliver the electrical side with all of its documentation.
Custom machines -
Case 02
A revamping that doesn’t change the risks.
The PLC, the operator panel or the control panel is replaced, but the machine has no new hazards and no increased risks. As a rule, that is not a substantial modification: the risk assessment confirms it, case by case.
With us, the scope is written down first: what stays, what changes, what gets reviewed.
Revamping -
Case 03
A substantial modification.
The work creates a new hazard or increases a risk, and it calls for new guards or protective devices that affect the safety control system. Whoever carries it out is considered the manufacturer of that machine (Art. 18), even if all they changed was the software.
With us, if our work counts as one, you’ll know before we start.
Which version, and when.
Keeping track of versions is nothing new for us. Every job has its own folder, and the PLC, HMI and drive backups in it carry a date: since 1996, we haven’t thrown out a single one.
What’s in the folderQuestions
What people ask us about 2027.
Do machines that are already installed have to be CE-marked again?
No. The Regulation applies to machinery placed on the market from January 20, 2027. Machinery placed on the market before then in accordance with Directive 2006/42/EC can continue to be made available (Art. 52). The Regulation comes back into play if one of those machines undergoes a substantial modification (Art. 18).
Can a software update be a substantial modification?
Yes, if the conditions are met: the definition covers modifications made “by physical or digital means” (Art. 3). What counts is the effect on safety, not whether you changed a wire or a line of code.
Who decides whether a modification is substantial?
The risk assessment for the job, case by case. If one of our jobs is a substantial modification, you’ll know before we start.
The first step
Have a machine to upgrade? All it takes is the PLC nameplate and two photos.
We’ll tell you what can be done and whether the work affects safety. An engineer reads your request, and you get a reply within 1–2 business days.
Source: Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, with the corrigendum that set the dates to January 20, 2027. This is a summary: it does not replace the official text or legal advice.