Digital instructions for use from 2027

From 20 January 2027, Regulation (EU) 2023/1230 applies. It replaces the Machinery Directive 2006/42/EC. In service that date feels distant, until someone has to rebuild the instructions for use and finds that a PDF on the website is not an answer. The regulation allows digital instructions. It allows them under conditions. Those conditions are in the regulation, not in a blog. A blog can only name the questions you should put to the text before a project flattens them onto a slide.

Regulation (EU) 2023/1230 is of 14 June 2023 and was published in the Official Journal of 29 June 2023. Individual articles on notified bodies and on administration apply earlier. The duties for placing the machine on the market, the ones service meets day to day, apply with the application date. If you are planning instructions now that should still hold in 2027, read the regulation, not only a summary.

What digital does not mean

Digital does not mean the file sits on the intranet and the customer is told to call when they need it. Under the duties publicly explained for Article 10(7), it has to be clear how the user reaches the digital instructions. How to access them is indicated on the machine, on the packaging, or in an accompanying document. The file has to be downloadable and printable, so it is still there when the machine has no network, or when the network is why the line is down. It has to stay available for the expected lifetime of the machine and for at least 10 years after placing on the market.

A paper copy is provided on request, free of charge. For non-professional use, essential safety information for putting into service and safe use stays on paper. Many food and packaging machines are built for commercial operation, so that rule does not catch them at first glance. It does catch them if a machine could reasonably be used outside that setting, or if a national authority draws the line more tightly. That question belongs to your documentation, not to a marketing page.

Commission guidance is not decisive. At the time of this text it is not what settles a dispute. If you need a deadline, the wording on a plate, or the reach of the paper duty, work from the regulation and with the person who owns conformity. A blog does not decide conformity, and it cannot replace that person.

The spare-parts drawing is a different sheet

The exploded view helps someone order a wear part. The instructions for use say how the machine is installed, run, and maintained safely. Both can be digital. They are not the same document, and one does not fulfil the duty of the other. The exploded-view drawing is not the safety manual. Put the drawing online and treat it as the instructions, and you have not provided the instructions. Put the instructions online and never maintain a drawing, and you still have not told service which position to order.

A position still has to stay a position. What changes is how the documents reach the customer. Instructions you cannot print do not help a fitter on a wet line. A drawing that will not open from the serial number does not help either. One of those failures sits in the documentation the regulation cares about. The other sits in the spare-parts process. They need separate work.

What service can take from this

Keep the date, and treat the slides as light. 20 January 2027 is a date in the Official Journal, not a reason to promise the instructions, the spare-parts catalogue, and the ERP in one sentence. Conformity owns the instructions. Service owns the catalogue. They talk, because the customer needs both on the same machine. They do not sign for each other.

Check three things, and keep them separate from the drawing. Is the way to the digital instructions visible on the machine? Can the file be opened without a login you never explained? Does a paper copy on request have a path other than "call us and we will see"? Then, on its own list, check that the exploded view for that series can be found. What you hand to a supplier, and what you change yourselves, comes after those lists, not before.

Two files, two owners

Instructions and the spare-parts drawing often share a folder, sometimes one PDF, with the drawing as an annex. That is easy to ship and careless about the duty. The instructions describe safe use: residual hazards, intended use, and what the operator must know before the first run. The exploded view names a part someone wants to order. It is a bill of materials drawn as a picture. An annex does not turn that picture into safety information, and a missing back page does not make the instructions complete because the cover is right.

The person who signs conformity owns the instructions: the language, how they are reached, and the paper copy on request. Service owns the drawing, the revision for that series, and release of the assembly. They may share a cabinet. They should not share a release procedure, because one file carries a legal duty and the other is a way to order a part. A mistake on the drawing is a wrong part. A mistake in the instructions can be a mistake in conformity. The weight differs, even when both files are called documentation.

What a link does not do

A link to a homepage, with the customer left to search, does not meet the publicly explained duty if the machine does not say how to find the file. The note is a place to look, not a search to survive. An account you never created for that customer is not enough either. The file has to reach the person at the machine, even when that person is not on your customer record. The regulation, read with the person who owns conformity, decides whether your setup does this. A blog does not decide it.

Printing is not a courtesy. On the line the network is sometimes the reason the instructions are needed, and then the network is gone. A file that can be saved and printed still ends up in the cupboard beside the machine. The 10 years after placing on the market, and the lifetime before that, are a filing question for both documents: which sheet belonged to which series, and can you still find it when the type is no longer built. The answers may be organised differently. Someone should have them.

What you should not derive from the regulation

Do not derive a shop. The regulation does not talk about prices or baskets. Do not derive a duty to give every screw a position. Do not decide that the exploded view can replace a printed safety card where paper is still required. Do not take deadlines from secondary sources that the regulation itself does not state. The application date used here is 20 January 2027. If a slide shows another day, go back to the Official Journal before you build a plan on it.

Until then the step is small. The instructions have a path the customer can reach and print, explained on the machine. The drawing for the series opens by serial number, and it does not claim to be the instructions. The customer at the machine needs both, on different days, for different reasons.