normakte / Updating documentation
There is no fixed deadline. The technical documentation is updated whenever something changes that conformity relies on: the machine, its manufacture, the standards applied or the law.
| Reason | What to do | Basis |
|---|---|---|
| Change to the design, characteristics or production process of the series | review and update the risk assessment and the documents affected; if particulars of the declaration change, issue a new version | Art. 10(4); for partly completed machinery Art. 11(4) |
| New version of a harmonised standard or specification the declaration relies on | assess the changes, adapt the list of standards and the declaration | Art. 10(4) |
| Placing on the market from 20 January 2027 | switch the file to the Machinery Regulation: essential requirements of Annex III, declaration under Annex V | Regulation (EU) 2023/1230 |
| Substantial modification after placing on the market | whoever carries it out is considered the manufacturer: conformity assessment, file and declaration for the modified machine | Art. 3(16), Art. 18 |
| Product with digital elements | keep the documentation updated at least during the support period, and update the cybersecurity risk assessment | Art. 31(2) and Art. 13(3) CRA |
The regulation sets no interval. In practice a twofold rhythm works well: every change to the machine or production goes through a change process that includes the file; and once a year you check whether the references of the harmonised standards applied, as published in the Official Journal, have changed. This is a recommendation, not a legal deadline.
The free check reads your current declaration and shows what no longer fits from 20 January 2027. If you wish, it passes the text straight to normakte, where it becomes the updated file.
No. What counts is the law in force when the machine was placed on the market. A substantial modification is different: whoever carries it out becomes the manufacturer and must apply the Machinery Regulation.
The technical documentation for at least ten years after the machine is placed on the market; for products with digital elements, ten years or the support period, whichever is longer (Art. 13(13) CRA).
Sources. Regulation (EU) 2023/1230, OJ L 165, 29.6.2023; Regulation (EU) 2024/2847, OJ L, 2024/2847, 20.11.2024. Summarised; only the official text is authoritative.
normakte is a writing and calculation aid and does not replace the conformity assessment, a notified body or legal advice.
Maintain the file yourself in normakte, with versioned documents – free trial file until 20 January 2027.