Machinery Regulation 2027: What Changes in Your Suppliers’ Declarations
We examined 20 declarations of conformity and declarations of incorporation from suppliers — the kind that arrive at every machinery manufacturer’s door. Twelve of them had at least one deficiency: repealed directives, standards without presumption of conformity, missing mandatory particulars. On 20 January 2027, new mandatory particulars will be added, and the declaration may then be provided as a link rather than on paper. Anyone who includes these documents in their technical file and must retain them for ten years should know what to look for now.
The Date — and Why There Are Two
Regulation (EU) 2023/1230 applies from 20 January 2027. On the same date, Machinery Directive 2006/42/EC is repealed (Art. 51(2) and Art. 54). Anyone reading the text in the Official Journal of 29 June 2023 will, however, find the date of 14 January. A corrigendum of 4 July 2023 shifted all deadlines six days later, because the Regulation did not enter into force until 19 July 2023. Both dates are in circulation; the correct one is 20 January.
There is no transitional period, but there is a grandfathering provision (Art. 52): Products placed on the market before 20 January 2027 under the Directive may continue to be made available. The declaration under 2006/42/EC for a gearbox that your supplier delivered in 2025 remains valid. For the same gearbox, delivered in February 2027, a declaration under the Regulation will be required.
What Must Now Appear in the Declaration
The Regulation sets out the structure of the declaration in Annex V — Part A for machinery, Part B for partly completed machinery. Compared with the current template, the following are the main changes for the recipient:
| Particulars | Previously (Directive) | New (Regulation) |
|---|---|---|
| Statement of responsibility | Not required | Mandatory: “This declaration of conformity is issued under the sole responsibility of the manufacturer.” |
| Applicable legislation | “Conforms to all relevant provisions of this Directive” | List of the harmonisation legislation that the product complies with, with references to the Official Journal |
| Harmonised standards | References, if applied | References with the date of publication in the Official Journal; where standards are partly applied, the parts applied |
| Conformity assessment | Notified body only for type-examination or comprehensive QA | Statement of the module (A, B and C, G or H); for Module B, the notified body and certificate |
| Authorised representative for the technical file | Name and address mandatory | No longer included in the new template |
| Declaration of incorporation: requirements | “Which” essential requirements from Annex I | “Which” requirements from Annex III, documentation pursuant to Annex IV Part B |
| Declaration of incorporation: responsibility | Not required | Mandatory: statement of sole responsibility |
Two things remain as they were — and are nonetheless frequently absent in practice. The declaration of incorporation must state which essential requirements are met, not merely “the relevant” ones as a blanket statement. And it must specify how the manufacturer will transmit the special documentation to the authorities.
The Declaration May Now Be Provided Digitally
New is Art. 10(8): The manufacturer may accompany the product with the declaration, or may indicate in the instructions for use a web address or a machine-readable code at which it can be accessed. The same applies to declarations of incorporation. The digital declaration must remain available online for at least ten years.
This has one consequence for the recipient: under the Regulation, the declaration must be “kept up to date at all times”. What appears under the QR code today may be a different version in three years’ time. Anyone who must demonstrate at an audit which declaration was in effect at the time of delivery needs their own copy with a retrieval date — not merely the link.
What Is Already Missing from 20 Publicly Available Declarations
The 20 declarations were taken from manufacturer websites: drives, switchgear, sensors, power supplies, dampers, motors, pumps, and one scan from a set of operating instructions. We checked them against the wording of the Directive and the Regulation — once manually and once using a prototype that reads the declaration and compares the particulars against the mandatory requirements and the list of harmonised standards.
The findings, without names, because this is not about individual manufacturers:
- 12 of 20 declarations had at least one deficiency under the wording of the applicable legal basis.
- 3 declarations cited repealed directives, including 98/37/EC and 73/23/EEC. All three are still available online today.
- Of eight declarations of incorporation, two cited not a single number from Annex I, referring only to “the relevant requirements”. Three did not state how the documentation would be transmitted.
- Standards with expired presumption of conformity appeared in three declarations that cited the current Directive; the Official Journal list had replaced the edition of the standard years earlier.
- For declarations under the Low Voltage and EMC Directives, it was not possible to check the currency of the standards against a machine-readable list. The Commission publishes these lists only as consolidated lists, last updated in 2024 and 2022 respectively.
The manual review took an average of 13 minutes per document, and 9 minutes after familiarisation. The sample was deliberately mixed; two declarations are over 15 years old. The rate says nothing about what arrives in your inbox. It shows what kinds of errors occur.
And Switzerland?
For Swiss manufacturers supplying into the EU, the Regulation applies directly from 20 January 2027. For the Swiss market, the Federal Council opened a consultation on 19 September 2025 on the total revision of the Machinery Ordinance (MaschV, SR 819.14). It adopts the EU Regulation by reference, including the transitional provision, and is intended to enter into force on the same date: 20 January 2027. For the Mutual Recognition Agreement (MRA) to continue to apply, its machinery chapter must be updated by then; the explanatory report notes that Swiss exporters must meet EU obligations even without an MRA update. For supplier declarations, this means: everything set out above also applies to parts that a Swiss supplier delivers after 20 January 2027.
As at 30 October 2026: The consultation closed on 19 December 2025; the results report and the Federal Council’s decision are still pending. On Fedlex, the MaschV version of 20 January 2024 remains the version in force; a version with a 2027 commencement date has not yet been published. Anyone needing declarations for the Swiss market at the end of 2026 should therefore plan around the EU date and keep an eye on Fedlex.
What You Can Do Now
- Take stock. Which suppliers will continue to deliver machinery or partly completed machinery to you from 2027 onwards? New declarations are only required for those.
- Ask rather than wait. Ask those suppliers when their declarations under the new template will be available. Anyone delivering in February 2027 must have them by then.
- Check cited directives. 98/37/EC, 73/23/EEC, 89/336/EEC, 2006/95/EC, and 2004/108/EC have been repealed for years. If any of these appears in a current declaration, that is grounds for a conversation with the supplier.
- Secure digital declarations. From 2027, a link will suffice. Download the declaration as a PDF upon goods receipt and record the retrieval date alongside it.
- Check declarations of incorporation for “which” and “how”. These two words are what separates a useful declaration of incorporation from one that is of no help when carrying out the risk assessment for the overall machine.
We Are Looking for Conversation Partners
Talent Factory builds and maintains inspection-process software for machinery manufacturers. We are currently investigating how machinery manufacturers check their suppliers’ declarations today: who does it, how long it takes, and what the outcome is. To that end, we are speaking with five companies until December — 30 minutes each by video call, eight questions, no sales pitch. If you work with these documents in quality, goods receipt, CE, or technical documentation, please get in touch at raffaele.senften@talent-factory.ch or on LinkedIn. You will afterwards receive the anonymised summary of all conversations.
Sources
- Regulation (EU) 2023/1230 on Machinery, OJ L 165, 29.6.2023, Arts. 10, 11, 21, 22, 51, 52, 54, Annex V. Accessed 29.10.2026.
- Corrigendum to Regulation (EU) 2023/1230, OJ L 169, 4.7.2023, p. 35. Shifts the deadlines in Arts. 51, 52 and 54 from 14 to 20 January 2027. Accessed 29.10.2026.
- Directive 2006/42/EC on Machinery, Annex II. Accessed 29.10.2026.
- List of harmonised standards for the Machinery Directive, standardsdrift.com, CC BY 4.0. As at 20.10.2026.
- European Commission consolidated lists for Low Voltage and EMC. Accessed 28.10.2026.
- Federal Council, press release of 19.09.2025: Machinery: maintaining simplified access to the EU internal market and Explanatory report on the total revision of the MaschV. Accessed 29.10.2026.
- Fedlex, consultation 2025/44 total revision of the MaschV, status “Closed – awaiting results report”, and MaschV, SR 819.14, current version of 20.01.2024. Accessed 30.10.2026.
- SECO, Machinery. Accessed 29.10.2026.
This article reproduces the legislative texts and does not constitute legal advice.