Deadlines and transition: what must happen by 20 January 2027

Regulation (EU) 2023/1230 already entered into force in July 2023 — it becomes mandatory from 20 January 2027. From that day on, it applies to every placing of machinery on the market within the European Economic Area. The current Machinery Directive 2006/42/EC is repealed at the same moment.

The principle behind this matters: there is no parallel regime and no transition period. Until 19 January 2027, the Machinery Directive applies exclusively; from 20 January 2027, the EU Machinery Regulation applies exclusively. A machine cannot be placed on the market "optionally" under one legal basis or the other.

Machinery lawfully placed on the market under the Machinery Directive before the cut-off date remains marketable. It may continue to be operated, resold and made available — the cut-off date creates no obligation to retrofit existing machinery to Machinery Regulation level.

Caution is needed with modifications: anyone who substantially modifies existing machinery can legally become the manufacturer — with all the obligations of the Machinery Regulation then in force, from the risk assessment through to a new EU declaration of conformity. What counts as a substantial modification is covered on our page on the substantial modification of machinery.

What matters is not the order date but the moment of placing on the market. A machine ordered in 2026 but delivered only after 20 January 2027 must fully comply with the Machinery Regulation — including its documentation obligations.

In practice this means: projects with delivery dates around the cut-off should already be documented in compliance with the Machinery Regulation today. Converting documentation processes — digital operating instructions, versioning, permanent availability — typically takes 6 to 12 months of lead time. Those who start now gain the buffer that special-purpose machinery and plant engineering with long project durations need anyway.