normakte / Directive and Regulation compared
What stays, what is new and where the old annexes are now – point by point, with the reference in the official text.
| Topic | Directive 2006/42/EC | Regulation (EU) 2023/1230 | Reference |
|---|---|---|---|
| Legal form | directive, transposed into national law | regulation, directly applicable in every Member State | Art. 54 |
| Scope | machinery, interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, transmission devices, partly completed machinery | machinery and “related products” (interchangeable equipment, safety components, lifting accessories, chains, ropes and webbing, removable mechanical transmission devices) and partly completed machinery | Art. 2(1) |
| Software | not expressly covered in the definition of machinery | an assembly missing only the upload of the intended software is machinery; safety components can be digital, including software with a safety function placed on the market separately | Art. 3(1)(f), 3(3) |
| High-risk machinery | one list in Annex IV | two parts: Annex I Part A (6 categories, always with a notified body) and Part B (19 categories) | Art. 6, Annex I |
| Conformity assessment | internal checks, EC type-examination, full quality assurance | modules A, B+C and H, new unit verification (module G); for Annex I Part A no internal production control | Art. 25 |
| Essential requirements | Annex I | Annex III, extended with protection against corruption, software in control systems, self-evolving behaviour, human-machine interaction and autonomous mobile machinery | Annex III 1.1.6, 1.1.9, 1.2.1, 1.3.7, 3.2.4 |
| Technical documentation | Annex VII | Annex IV (Part A for machinery, Part B for partly completed machinery); source code or programming logic on reasoned request | Art. 10(3), Annex IV |
| Declaration of conformity | Annex II, naming the person authorised to compile the technical file | Annex V Part A; a single declaration for all acts; access also via internet address or machine-readable code | Art. 21, Art. 10(8) |
| Instructions | paper | digital allowed, online for at least ten years; paper on request at purchase; safety information always on paper for non-professional users | Art. 10(7) |
| Marking and contact | name and address of the manufacturer | also website, e-mail or other digital contact; a single contact point; year of construction = year the manufacturing process was completed | Art. 10(5), (6) |
| Economic operators | manufacturer and authorised representative | also obligations for importers and distributors; traceability for ten years | Arts 13–17, 19 |
| Substantial modification | not defined in the Directive | defined; whoever carries it out is considered the manufacturer | Art. 3(16), Art. 18 |
| Post-market monitoring | — | sample testing, complaints, register of recalls, where appropriate in view of the risks | Art. 10(4) |
| Content | Directive | Regulation |
|---|---|---|
| Essential requirements | Annex I | Annex III |
| EC/EU declarations of conformity and incorporation | Annex II | Annex V |
| CE marking | Annex III | Arts 23, 24 |
| High-risk machinery | Annex IV | Annex I |
| Safety components (indicative list) | Annex V | Annex II |
| Assembly instructions | Annex VI | Annex XI |
| Technical documentation | Annex VII | Annex IV |
| Internal checks | Annex VIII | Annex VI (module A) |
| Type-examination | Annex IX | Annex VII (module B) with Annex VIII (module C) |
| Full quality assurance | Annex X | Annex IX (module H) |
| Unit verification | — | Annex X (module G) |
The full correspondence of articles is set out in the correlation table in Annex XII of the Regulation.
The process changes little. The manufacturer assesses the risks, identifies the applicable requirements, designs accordingly, compiles the technical documentation, chooses the procedure, draws up the declaration and affixes the CE marking. The order of protective measures – first by design, then technical, finally information – is the same (Annex III 1.1.2). A clean file under the Directive needs to be completed, not rewritten.
Products placed on the market in accordance with the Directive before 20 January 2027 may continue to be made available. EC type-examination certificates issued under the Directive remain valid until they expire (Art. 52). What counts, for each individual unit, is the date of placing on the market.
Until 19 January 2027 placing on the market is governed by the Directive, from 20 January 2027 by the Regulation. If you design today and deliver in 2027, build the Regulation’s requirements into the design and the file now.
Only if it is listed in Annex I. For Part A always; for Part B only if harmonised standards or common specifications do not cover all relevant requirements. All other machinery stays with internal production control (Art. 25).
Yes. Whoever manufactures machinery and puts it into service for their own use is a manufacturer (Art. 3(18)(b)).
Presumption of conformity applies to standards whose references are published in the Official Journal (Art. 20(1)). Check before the declaration which standards are published for the Regulation – the list under the Directive does not carry over automatically.
Annex III requirements with evidence, Annex V declaration and nameplate in one place. Trial file free until 20.01.2027.
Sources. Regulation (EU) 2023/1230, OJ L 165, 29.6.2023, including the corrigendum of 1.4.2025; Directive 2006/42/EC for the previous regime.
The information has been checked against the official text, paraphrased and shortened; only the official text is authentic.
normakte is a drafting and calculation aid; it replaces neither conformity assessment, nor a notified body, nor a technical assessment by a specialist, nor legal advice.