Have your existing operating manuals reviewed free of charge to make sure you are fully prepared for the new Machinery Regulation.

On 20 January 2027 the new EU Machinery Regulation 2023/1230 will come into force, replacing the existing Machinery Directive 2006/42/EC without a transition period. For products that will be placed on the market exactly during the period of the cut-off date, it may make sense to issue a “double” declaration of conformity – one for the Machinery Directive and one for the Machinery Regulation.

Supply of digital documentation
With the new Machinery Regulation, it will no longer be strictly necessary to enclose a printed set of operating instructions with the machinery. Generally speaking, this very welcome decision is in keeping with modern developments and will reduce the cost and effort associated with the production, publication and upkeep of documentation.

Important information: In the summer of 2024 the European Commission published an updated version of the guidelines for the Machinery Directive 2006/42/EC. This already makes it legally possible to provide documentation in a digital format. Accordingly, you do not need to wait until January 2027. What does this new option mean in detail? As a machine manufacturer, you can supply operating instructions in a digital format and it must be possible to print these out, download them and save them. The easiest way to do this is using the tried and tested PDF format. 
 

In future, operating instructions will need to be accessible online throughout the scheduled service life of the machine and for a period of at least ten years after it is placed on the market. To ensure that this is possible, many companies are going to need to adapt some of their processes, establish new cloud platforms or expand existing customer information systems. In the form of our standardised service portal, we offer a simple solution that can be customised to suit the needs of your company quickly and easily.

New areas covered
Of course, the new Machinery Regulation comes with a whole number of changes in terms of content and areas covered. For example, it will be a mandatory requirement that risk assessments also look at e.g. digital threats and cybersecurity risks. In addition, the list of machines that are classed as particularly at-risk and are therefore subject to more stringent test methods has been revised and expanded. Content relating to installation instructions for incomplete machines has also been defined in much more extensive detail – with just a few exceptions, the content now matches the requirements for complete machines.

Optimising authoring processes
When it comes to updating your operating instructions to get them ready for the new Machinery Regulation, it is worth remembering that this also provides you with an opportunity to scrutinise and optimise your existing processes. You will need to gather information from many different departments within your company: 
The engineering/design department provides technical data, CAD models, assembly drawings and parts lists. The software department supplies raw information for the description of controllers. The marketing department defines the graphical layout and design and also provides inputs on internal wording to be used within the company. The electrical engineering department provides schematic drawings and details for the control panels. Customer service defines the scope of replacement parts and wear parts, and the order confirmation from the sales department also contains valuable information about the scope of supply as well as translations. It takes careful planning, structuring and organisation of the processes to ensure that all this information is collected at the right time. Every department needs to know what information it is required to make available, when it needs to be ready, and in what form. This is the only way to ensure that operating instructions can be completed on time before the machine is delivered to the customer.

Boosting efficiency with the right software
One of the key factors in an efficient documentation process is the software used. There are two main areas of work involved in this process:
1. Text creation, document layout and PDF export
2. CAD data preparation and graphics creation
For item 1 a general decision must be made whether to use a classic text editor such as Microsoft Office, Adobe FrameMaker, Adobe InDesign etc. or whether to opt for a content management tool such as SCHEMA ST4, Docuglobe, Cosima Go etc. Although the latter are significantly more costly to purchase, they offer valuable functions that will help make document editing noticeably more efficient and deliver a standardised translation and quality assurance process. Release processes and version management are also core functionalities offered by these tools. When it comes to point 2, the interfaces and data quality of the internal CAD system often play a vital role. If the vast majority of the machine components are available in the 3D data model then line drawings or renderings can be exported and further processed in additional graphics programs (Adobe Illustrator, Corel Draw etc.). Some of these tools have direct interfaces to the 3D data model, which enables straightforward updates.
 

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