normakte  /  Analysis 2026

Only 1 of 91 declarations of conformity already cites the Machinery Regulation

We analysed 91 publicly available declarations of conformity and incorporation from machine manufacturers. Three months before the deadline, almost none cites the new Regulation — not even those issued in 2025 and 2026.

The results

already cite Regulation (EU) 2023/12301 %cite only Directive 2006/42/EC97 %cite the Cyber Resilience Act0 %standards without the Official Journal date82 %still titled “EC declaration”45 %name the person authorised to compile the technical file45 %no reference to module A (declarations of conformity)78 %

24 of the declarations analysed carry a date from 2024 to 2026. 23 of them cite only the Machinery Directive, including all five from 2026. The templates are being maintained — but not yet switched over.

What this means — and what it does not

The declarations analysed are correct for machines placed on the market before 20 January 2027. The figures show how many templates have to be revised for future deliveries: legal basis, standards with the Official Journal date, no person authorised to compile the technical file, reference to module A and — for connected machines — the Cyber Resilience Act in the same declaration.

Method and limits

  • Sample: 91 publicly available declarations (81 of conformity, 10 of incorporation) from machine manufacturers' websites, mostly from Germany, Austria and Switzerland, some from Italy; collected in October 2026.
  • Excluded: guides, templates and samples, scanned documents without a text layer, declarations for other product types (e.g. electric motors, pressure equipment); at most three documents per manufacturer.
  • Analysis: automated text analysis with the normakte delta check; the year is the latest date in the document (14 documents without a date).
  • Not a representative survey: with 91 documents the uncertainty is about ±10 percentage points. Results are anonymous; no company is named.

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Sources. Regulation (EU) 2023/1230, OJ L 165 of 29.6.2023; Regulation (EU) 2024/2847, OJ L, 2024/2847 of 20.11.2024. Summarised; only the official text is authoritative. normakte is not legal advice.