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Digital instructions for use: the four conditions

Digital is allowed. But the permission comes with a period longer than most content management systems live.

The manufacturer ensures the machine is supplied with the instructions for use and the information under Annex III. The instructions may be provided digitally. They must clearly describe which product model they apply to.

Art. 10(7)Annex III 1.7.4

The four conditions

ConditionBasis
On the machine — or, where that is not possible, on the packaging or in an accompanying document — it states how to access the digital instructionsArt. 10(7)(a)
The format allows printing, downloading and saving on an electronic device, including if the machine fails and even where the instructions are embedded in the softwareArt. 10(7)(b)
They remain accessible online for the expected lifetime, at least ten years after placing on the marketArt. 10(7)(c)
On the user's request at purchase: free on paper within one monthArt. 10(7)

A non-negotiable exception

For machines intended for non-professional users — or that may be used by them under reasonably foreseeable conditions —, the manufacturer provides on paper the safety information essential for safe putting into service and use. Digital alone is then not enough, however good the portal.

Ten years is the real problem

The access detail is affixed to the machine, often as a QR code on the nameplate. The nameplate cannot be changed afterwards; the URL behind it must therefore stay stable for ten years or more — across site relaunches, domain changes and migrations. The same period applies to the digital EU declaration of conformity (Art. 10(8)) and to the assembly instructions of partly completed machinery (Art. 11(8)).

Two new contents in the instructions

Compared with Directive 2006/42/EC, added to the minimum contents are: information on the precautions, devices and means necessary for the immediate and gentle rescue of persons; and, where emissions of hazardous substances are possible, the characteristics of the collection, filtering or extraction device, where it is not supplied with the machine. For products with digital elements, the information under Annex II of the Cyber Resilience Act is added — including the single point of contact for vulnerability reporting and the end date of the support period.

The technical file for your machine

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Sources. References from the versions published in the OJ: Regulation (EU) 2023/1230; Regulation (EU) 2024/2847. The official text prevails; normakte is a drafting aid, not legal advice.