Guide to application of the Machinery Regulation (EU) 2023/1230

The first meeting of the editorial group for the new guide took place on 28 January 2025. During this meeting, the first details of the organisational structure were also defined: the work will be carried out by a main editorial group and five subgroups for specific topics, such as AI-based safety functions, autonomous mobile machines or cyber security.

These subgroups will then prepare the detailed content (i.e. new and revised content compared to the MRL guide), after which the main editorial team will review the content and submit it to the EU Commission's expert group on machinery for formal approval.

This division was announced at the end of March 2025 as part of a call for expressions of interest. This calls on interested parties to contribute to the new guide, with a deadline for feedback set for 25 April 2025. Details can be found in the publication of the editorial group on the website of the EU Commission.

The next meeting is scheduled for 4 April 2025.
 

Since the process has only just begun, a final publication is not expected before 2026 (one year before the new Machinery Regulation comes into force). However, the first drafts could possibly be available as early as the end of 2025.

By comparison: The Machinery Directive 2006/42/EC was published in the EU Official Journal in June 2006, and the first edition of the associated guide followed in December 2009. If the guide to the Machinery Regulation follows a similar cycle, a planned publication date for the first edition would be December 2026.
 

Detailed insights into the content changes of the new Guide will probably only be possible with the publication of the first draft documents (possibly at the end of 2025).

In their call for participation on 26 March 2025, however, the first details were published regarding the organisational structure and the focus on which these so-called subgroups are to specialise:

Group A will, among other things, review the suitability of the current Guide to application of the Machinery Directive with regard to the essential health and safety requirements (EHSRs) amended in the MR, the topic of ‘substantial modification’, and machine-specific provisions of the New Legislative Framework.

Group B focuses on functional safety and deals with the topics of AI-powered safety functions and software as a safety component. In this context, a close interrelationship with the new EU regulation on artificial intelligence is to be expected.

Group C covers the topics of autonomous mobile machines, the risk of contact with overhead power lines, and seats (e.g. safety belts).

Group D deals with the topic of cybersecurity, which has been newly included in the MVO. Here, too, overlaps with another EU regulation are to be expected, namely the new Cyber Resilience Act.

Group E is responsible for digital operating instructions and other information (e.g. the declaration of conformity).
 

Following publication of the Machinery Regulation in the EU Official Journal in June 2023, a revision of version 2.2 of the Guide to the MD was initiated in order to communicate changes regarding the form of the instructions at an early stage.

Therefore, version 2.3 of the Guide to Application of the Machinery Directive already includes the amended sections § 255 (Form of the operating instructions), § 261 (Inclusion of the EC declaration of conformity in the operating instructions), § 264 (Assembly, installation and connection), § 382 (The EC declaration of conformity for a machine), § 384 (The Declaration of Incorporation for partly completed machinery) and § 390 (Assembly instructions for partly completed machinery). For these sections, compliance with the provisions of the Machinery Regulation with regard to the new format of the documents also means compliance with the corresponding provisions of the Machinery Directive.

Details can be found in our article on the new version 2.3 of the Guide to Application of the Machinery Directive.
 

The future guide to the Machinery Regulation and other guides play an important role in interpreting the legal requirements of the MVO and are valuable sources of knowledge in practice – however, these accompanying documents of the EU Commission are not legally binding like EU regulations or directives!
 

As soon as a final edition of the guide is published by the EU Commission, we will provide the full-text PDF as a data set on the live server and prepare the individual contents of the guide promptly for the Safexpert Knowledge Base.

This provides Safexpert users with the advantage that the respective explanations are displayed parallel to the corresponding sections of the Machinery Directive in the StandardsManager.