Machinery Regulation guide
Digital operating instructions: what the Machinery Regulation permits — and requires
Paper is no longer mandatory: Article 10(7) permits digital operating instructions — subject to four conditions.
Article 10(7): paper is no longer mandatory
The biggest change for technical documentation: the EU Machinery Regulation explicitly permits providing the operating instructions in digital form. The decades-long dispute over whether a PDF on a USB stick replaces the "supplied" manual is thereby settled — the digital version can be the sole form of provision.
The manufacturer must indicate on the machinery, on the packaging or in an accompanying document how the digital instructions can be accessed. In practice, the QR code on the nameplate has become the established route: scan, open the instructions in the browser, done.
The four conditions
Digital provision is tied to specific conditions. All four must be met:
- Access without barriers: the instructions must be retrievable without special software and without a user account — a link opening in a standard browser is sufficient, a proprietary portal with a login is not.
- Permanent availability: the instructions must remain available online for the expected lifetime of the machinery, but for at least 10 years after placing on the market.
- Paper on request: at the request of the buyer, a paper version must be supplied free of charge within one month.
- Protection of non-professional users: for machinery that may also be used by consumers, the safety information must additionally be enclosed in paper form.
What this means in practice
The underestimated requirement is permanence. A PDF folder on the company website only satisfies it as long as no relaunch, no domain migration and no restructuring breaks the link — over 10 years and more, that is almost impossible to guarantee without a dedicated system. Then there is the matter of assignment: the operator needs the instructions in exactly the version that belongs to their machine and its year of manufacture.
That is why the pattern "permanent QR code per machine, versioned file behind it" is becoming the standard: the code on the machine stays the same forever, while the documents behind it are maintained and versioned. How docks implements this is shown on our digital operating instructions page; a structure template based on DIN EN ISO 20607 is available free of charge in our templates section.
FAQ
Frequently asked questions
Is a PDF folder on our website sufficient?
Formally yes — in practice only if the link remains stable over the entire machine lifetime, the version can be unambiguously assigned to the machine and no login stands in the way. Experience shows that such links break after website relaunches; that is precisely when the manufacturer violates the provision obligation.
Must the QR code be attached directly to the machine?
The Machinery Regulation requires the access route to be indicated on the machinery, on the packaging or in an accompanying document. The QR code on the nameplate is the most robust route — it stays with the machine even when packaging and paperwork have long been discarded.
What happens to the digital instructions during a website migration?
The provision obligation continues to apply — a dead link is a compliance violation. That is why the target URL of the QR code should be decoupled from the company website: docks contractually guarantees URL stability for 10 years.
Keep reading
More chapters of this guide
Machinery Regulation: Deadlines and Transition until 20 January 2027
A hard cut-off date instead of a transition period: from 20 January 2027, every placing on the market is governed exclusively by the Machinery Regulation.
Technical Documentation under the Machinery Regulation: Scope, Retention, Access
From risk assessment to declaration of conformity: what must remain deliverable for 10 years — and what may stay protected.
QR Code on the Machine: How It Satisfies the Machinery Regulation
The Machinery Regulation does not prescribe a QR code — but it does require a permanent digital access route. The code is the de facto standard.
What Is an EU Declaration of Conformity? Mandatory Contents and Transition to the Machinery Regulation
The legally binding document behind the CE marking: what belongs in it — and what changes on 20 January 2027.
Risk Assessment under the Machinery Regulation: Obligation, Process, Documentation
No CE marking without a risk assessment: the process according to ISO 12100 — and the new Machinery Regulation requirements from cybersecurity to AI.
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