26 n MACHINE BUILDING April 2026 www.drivesncontrols.com Are you ready for the changes to CE marking of machinery? January 2027 may feel like a long way off, but not when you need to change the way you CE mark your machinery. With less than a year until the new Machinery Regulation 2023/1230 supersedes the Machinery Directive 2026/42/EC, and no transition period being allowed, machine-builders must get ready. One-off and series machines will all have to be CE-marked to the new Machinery Regulation (MR) if they will be sold in the EU on or after 20 January, 2027. While the new MR is similar to the old Machinery Directive (MD), there are important differences. Some relate to additional essential health and safety requirements, such as those for cybersecurity and artificial intelligence, but others are administrative and entail revisions to paperwork. For a start, the technical documentation (previously referred to as the technical file) must contain more detail, and the EU Declaration of Conformity (previously the EC Declaration of Conformity) needs to be updated in several ways. Depending on the machine, even if it has been designed in accordance with the MD harmonised standards, all or part of it might need a fresh risk assessment against the EHSRs (essential health and safety requirements) contained in the new MR. The results of the risk assessment could potentially require changes to the machine, including to its control system and software. A particular challenge here is that the European Commission has not yet published the harmonised standards for the MR! One of the benefits of the new MR is that it no longer stipulates that a printed copy of the user instructions must be supplied with every machine, because digital versions are now allowed. Although this could save money for machine-builders, end-user customers can request, free of charge, a printed copy of the instructions when placing an order. Another way the MR differs from the MD is that it includes clauses about economic operators. In fact, these are essentially the same as in EU regulation 2019/1020 on market surveillance and compliance, which has been in force for around five years. By now, most machine-builders exporting to the EU will have mandated an EU Authorised Representative (EU AR) to act as an economic operator; any that have yet to do so, should make this a priority. Without an economic operator being named on the paperwork, a machine could be held at the border. January 2027 is less than a year away, and lead times for complex machinery can be considerable. Even if machine-builders only need to update their paperwork, it will take time to study the new Machinery Regulation and to ascertain what actions to take. n * Derek Coulson is a compliance specialist with more than 25 years of experience, mainly in machinery safety. He is the founder of Safe Machine, a UK-based machinery safety consultancy, and a director of Hold Tech Files (www.holdtechfiles.eu) which, being based in the Republic of Ireland, can act as an EU Authorised Representative. It also offers advice to machine-builders on preparing for the new Machinery Regulation. Machine-builders and systems integrators have less than a year to prepare for the new EU Machinery Regulation, and the UK Supply of Machinery (Safety) Regulations (if they are also updated to remain aligned). Compliance specialist Derek Coulson* emphasises the need the need to update your paperwork accordingly.
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