Machinery compliance in Europe and the UK is entering a new phase. From 20 January 2027, the EU Machinery Directive 2006/42/EC will be replaced by Regulation (EU) 2023/1230 on machinery. This change will affect manufacturers, importers, distributors, integrators and suppliers placing machinery on the EU market. It will also have important consequences for businesses supplying machinery into Great Britain and Northern Ireland.
The EU Machinery Regulation will apply directly from 20 January 2027, with Annex III covering the essential health and safety requirements, Annex IV covering technical documentation, and Annex V covering the EU Declaration of Conformity and Declaration of Incorporation.
What is changing in the EU?
The new EU Machinery Regulation keeps the same basic principle: machinery must be designed and manufactured safely, risks must be assessed, technical documentation must be prepared, and the correct conformity assessment route must be followed before CE marking.
However, the new regulation modernises the legal framework. It gives more attention to digital technologies, connected machinery, software, autonomous systems, cybersecurity and artificial intelligence used in safety-related functions. It also clarifies the responsibilities of manufacturers, importers and distributors.
One important point is that some machinery categories may require more careful third-party conformity assessment. The old “Annex IV machinery” approach under the Machinery Directive is replaced by the new Annex I structure under Regulation (EU) 2023/1230. Manufacturers should therefore review whether their products fall into higher-risk categories before assuming that the previous conformity assessment route is still suitable.
The regulation also allows instructions to be provided in digital format, provided they remain understandable and accessible to users. Manufacturers still need to ensure that declarations, instructions and technical documentation are available in the correct form and language for the relevant market.
UK development: new draft machinery regulations
The UK Government has now laid a draft statutory instrument called The Supply of Machinery (Safety) (Amendment etc.) and the EU Machinery Regulation (Enforcement etc. in Northern Ireland) Regulations 2026. The draft states that it is intended to come into force on 20 January 2027, the same date as the EU Machinery Regulation becomes applicable.
This draft regulation is important because it separates the treatment of Great Britain and Northern Ireland.
For Great Britain, meaning England, Wales and Scotland, the Supply of Machinery (Safety) Regulations 2008 will continue to be the main machinery safety framework, but they will be amended. The draft makes clear that Part 2 applies to England, Wales and Scotland only.
For Northern Ireland, the position is different. Under the Windsor Framework, the EU Machinery Regulation will apply directly in Northern Ireland from 20 January 2027. The UK draft legislation provides the enforcement structure for that position.
What does this mean for Great Britain?
The key development for Great Britain is that machinery meeting the relevant requirements of the EU Machinery Regulation may be placed on the GB market under the amended UK machinery framework. The draft regulation explains that regulations 12A, 12B and 12C of the 2008 Regulations are being replaced so that machinery products meeting the relevant EU Machinery Regulation requirements can be placed on the GB market.
In practical terms, this suggests that CE-marked machinery compliant with Regulation (EU) 2023/1230 may continue to have a route into Great Britain, subject to the specific UK requirements being met. This is especially important for manufacturers and importers supplying both EU and UK customers.
However, this does not mean UK compliance can be ignored. Businesses still need to check the destination market, applicable marking, declaration wording, technical documentation, language requirements, responsible person details and conformity assessment route.
What does this mean for Northern Ireland?
Northern Ireland will follow the EU Machinery Regulation more directly. Machinery placed on the Northern Ireland market will need to meet the requirements of Regulation (EU) 2023/1230 from 20 January 2027.
Where a UK conformity assessment body is used for Northern Ireland, the product may need the UK(NI) indication placed next to the CE marking. The draft regulation states that the UK(NI) indication must be affixed where a UK notified body has carried out the relevant conformity assessment procedure and CE marking has been applied.
This means manufacturers must be careful when choosing their conformity assessment body. A product intended for the EU market, Northern Ireland market, or Great Britain market may need different conformity assessment and marking considerations.
Transitional arrangements
The draft UK regulation also includes transitional provisions. Machinery or partly completed machinery placed on the market before the new rules come into force may continue to be made available on the market, provided it met the applicable requirements at the time it was first placed on the market.
This is important for distributors and importers holding existing stock. The focus is not only whether the product is sold after January 2027, but when it was first placed on the relevant market.
What should manufacturers and importers do now?
Manufacturers should not wait until January 2027. The best approach is to start reviewing technical files and conformity assessment procedures now.
Key areas to review include:
- Product classification under the new EU Machinery Regulation
- Whether the product falls under Annex I higher-risk categories
- Risk assessment against the new Annex III essential health and safety requirements
- Technical documentation against Annex IV
- Instructions for use, including digital format and language requirements
- EU Declaration of Conformity or Declaration of Incorporation
- CE, UKCA and UK(NI) marking requirements
- Importer, distributor and authorised representative responsibilities
- Cybersecurity, software, AI and connected machinery risks
- Test reports and evidence supporting compliance
Conclusion
The 2027 machinery compliance changes are not just an EU issue. They will affect the UK market as well, especially where products are supplied into Great Britain, Northern Ireland and the EU at the same time.
The EU will move from the Machinery Directive to Regulation (EU) 2023/1230. Northern Ireland will follow the EU regime under the Windsor Framework. Great Britain will continue with its own machinery safety regulations, but the UK draft legislation creates a route for machinery compliant with the new EU Machinery Regulation to be placed on the GB market.
For manufacturers, importers and machinery suppliers, the message is clear: 2027 should be treated as a compliance transition project. Technical files, risk assessments, declarations, instructions, marking and supply chain responsibilities should be reviewed early to avoid market access issues later.
To ensure your machinery compliance process is ready for the new 2027 regulatory framework, contact us for support with risk assessment, technical documentation, CE and UKCA, and conformity assessment.