What does the new Machinery Regulation mean for your manuals?
From 20 January 2027, every language version of your operating and maintenance instructions carries the same standing as the version you verified. Here is what changes, and what to check before then.
If you exhibit at trade shows, you know the autumn rhythm. The machine leaves on a lorry weeks before you do. Somebody spends a fortnight on the stand graphics. Then, on the second morning, a buyer stops, asks a question you have answered a hundred times, and this time it turns into a sales enquiry.
This year the timing matters more than usual. That enquiry becomes an order in the spring, and the machine you ship against it will go out under new rules. If the instructions were written under the old ones, that is a problem.
Regulation (EU) 2023/1230, the new Machinery Regulation, applies from 20 January 2027 and replaces the Machinery Directive (2006/42/EC). Plenty has been written about its effect on safety functions and software. Far less has been written about its effect on the instructions supplied with the machine, which is the part we work on every day as translators for the manufacturing sector.
What happens to "original instructions" and "translation of the original instructions"?
Under the Directive, each translated version of your instructions was labelled as such. The version you had verified carried the words “original instructions”. Every other language version carried “translation of the original instructions”.
If a translation was ever questioned, an original existed, and the original was the version that counted.
Neither phrase appears in the new Regulation.
From January 2027, the German-language instructions are not treated as a translation of a governing original. They are the instructions supplied for that market, and they carry the same weight as the version you signed off.
Great Britain is different. The Supply of Machinery (Safety) Regulations 2008 keep the English-language requirement and retain the “original instructions” wording. So if you sell into both Great Britain and the European Union, from January you will be maintaining two labelling conventions from one source file.
There is no legal conflict in that, but there is a version control problem, and somebody in your business needs to own it.
What does the Machinery Regulation require of your distributor?
This is the one to deal with first.
Article 15 requires a distributor to check, before making your machine available, that the instructions are in a language the users can easily understand, as determined by the destination member state. If the distributor decides they are not, the Article requires them to withhold the machine from the market until that has been put right.
So a distributor who says they cannot take delivery until the documentation is compliant is not being awkward. They are following an instruction the Regulation has given them.
The consequences go further. A failure in the instructions counts as non-compliance under Article 46, which obliges the member state to see the product recalled or withdrawn.
Can a machine really be withdrawn from the market over its manual?
Yes, and it already happens.
In July 2025, the Belgian authorities ordered a manufacturer to withdraw a range of electric scooters from the market. Safety Gate alert OR/00151/25 gives the reason plainly: “The user manual of the product is not available in all national languages.” The alert then explains why that mattered. Without the safety information in their own language, users “may disregard these restrictions and safety measures, which exposes them to a high risk of injury”.
There was nothing wrong with the machine. It was withdrawn over its manual.
Croatia and Slovenia took the same measure against the same product.
What are the language rules for partly completed machinery?
Conveyors, drive systems and sub-assemblies do not leave with a Declaration of Conformity. They leave with a Declaration of Incorporation and a set of assembly instructions, and those instructions have their own language rule.
The wording is worth reading twice, because it does not name the reader you would expect. Under Article 11(7), the assembly instructions have to be understood by “the person who incorporates the partly completed machinery”.
Not the operator. Not the end user. The integrator: the business that builds your sub-assembly into the finished machine or line.
The integrator often works in a different language from the end user, and needs a document separate from the instructions that go with the finished line. In our experience, the assembly instructions are the ones most often overlooked.
Do safety symbols mean you no longer need to translate warnings?
We are asked this often, usually in hope. If we put good safety symbols on the machine, do we still have to translate the warnings?
By safety symbol we mean a standardised graphic on the machine that gives a warning, a prohibition or an instruction without words: the lightning bolt in a triangle, the crossed-out hand, the sign telling an operator to wear eye protection. The Regulation calls these pictograms, which is the word you will find in Annex III. It does not mean the technical illustrations and exploded diagrams inside your manual, and those carry no language rule of their own.
The Regulation is kinder here than people expect. Annex III says warnings should preferably be given as symbols or pictograms. It then says any written or verbal warning must be in a language the user can easily understand.
So well-chosen safety symbols reduce the amount of text your machine has to carry. They do not remove the requirement to translate the written warnings that remain.
Can you supply machinery instructions digitally?
You can now supply the instructions digitally, through a code on the machine rather than a printed folder in a bag.
There are conditions attached, set out in Article 10(7). You mark on the machine how the instructions are reached, and you present them so the user can print them, download them and keep them. They must remain accessible at any time, and the Regulation names a breakdown of the machinery in particular. They must stay online for at least ten years. And if a buyer asks for a paper copy at the time of purchase, you supply one free of charge within a month.
Digital supply changes where the translations sit, and it requires every language version to stay reachable for a decade. It does not reduce the number of translations you need.
What should manufacturers do before January 2027?
The enquiries you pick up this autumn become orders in the first half of next year. Those are machines shipping under the new Regulation. The instructions you are quoting against right now are the ones you will be handing over afterwards.
The priority between a September stand and a January deadline is therefore a review rather than a translation project. Go through the operating, installation, maintenance and assembly instructions you already hold, establish which languages and which markets each of them covers, and identify which meet the new language test and which do not.
That takes days rather than months, and it is considerably less uncomfortable than hearing it first from a distributor.
Which set of instructions would you rather a buyer did not check this year? That is usually the one to start with.
How can Anglia Translations help?
If you would like help with that review, send us the operating, installation, maintenance and assembly instructions you supply with the machine, together with the markets you sell into. We will tell you which of them already meet the new requirements and which need work before January.
Find out more about our document translation services for manufacturers, or get in touch with a member of our team today.
Correct as at 27 August 2026. Regulation (EU) 2023/1230 applies from 20 January 2027 and this article reflects the text as consolidated at 29 June 2023. Please verify against the current text before relying on it. This is general information about documentation requirements and not legal advice on your own conformity assessment.
