REGULATION
Machinery Regulation 2023/1230: three months to go for robot buyers
By Robot Distribution editorial teamPublished 6 min read
IN BRIEF
Regulation (EU) 2023/1230 on machinery applies from 20 January 2027, 90 days from today, and replaces Directive 2006/42/EC. Robots placed on the EU market from that date must comply with it. Buyers should check the declaration of conformity, digital instructions and any planned modification. AI Act high-risk rules for machinery now apply from 2 August 2028.
20 January 2027: the date that matters
Regulation (EU) 2023/1230 on machinery applies on a mandatory basis from 20 January 2027, according to the European Commission. On that date it replaces Directive 2006/42/EC. On 22 October 2026, that is 90 days away.
The European Commission states that machinery placed on the market before 20 January 2027 must comply with Directive 2006/42/EC, and that manufacturers may state in the EU declaration of conformity that it also conforms with the regulation, where applicable.
The date that counts is when a unit is placed on the EU market, not when it is ordered. A robot ordered in 2026 and delivered after 20 January 2027 must comply with the regulation.
What changes for companies that buy or rent robots
The regulation applies directly in every member state. The manufacturer still carries the main obligations, but buyers, renters and integrators have documents to check and decisions to make.
| Topic | What changes | What to do |
|---|---|---|
| CE marking and declaration | The EU declaration of conformity cites Regulation (EU) 2023/1230 instead of Directive 2006/42/EC | Check which text the declaration cites, depending on the date the unit is placed on the market |
| Instructions | Instructions may be supplied in digital format; paper can be requested free of charge at the time of purchase | Request paper instructions at purchase if your sites need them |
| Autonomous mobile robots | New requirements for autonomous mobile machinery, including a remote supervisory function where relevant | Ask how the supervisory function works and who holds it |
| AI and self-evolving safety functions | Safety components using machine learning are listed in Annex I, Part A and need a notified body | Ask whether a notified body took part and which certificate applies |
| Software and connectivity | Protection against corruption and a log of safety software versions | Ask how updates are delivered, logged and identified on the robot |
Modifying a robot: when you become the manufacturer
Article 3 of the regulation defines a substantial modification as a modification of a machine, by physical or digital means, after it has been placed on the market or put into service, that the manufacturer did not foresee or plan and that affects safety by creating a new hazard or increasing an existing risk.
A person who substantially modifies a machine is considered its manufacturer and takes on the manufacturer's obligations for it (Article 18). The phrase "by digital means" matters for robots: a software or configuration change can count, not only a new tool or attachment.
Before adding a module, changing safety parameters or installing third-party software on a robot, check with the supplier whether the change is covered by the manufacturer's instructions.
AI Act: high-risk rules for machinery move to August 2028
Regulation (EU) 2026/1744 of 8 July 2026, known as the Digital Omnibus on AI, was published in the Official Journal on 24 July 2026. It amends the AI Act, Regulation (EU) 2024/1689, and the Machinery Regulation (EU) 2023/1230.
- According to its recital 40, the AI Act's high-risk obligations for AI systems classified as high-risk under Article 6(1) and Annex I, such as safety components of regulated products, apply from 2 August 2028 instead of 2 August 2027.
- For the high-risk systems listed in Annex III of the AI Act, the date is set to 2 December 2027.
- According to its recital 42, Regulation (EU) 2023/1230 moves from Section A to Section B of Annex I of the AI Act. The relevant high-risk requirements are to be added to Annex III of the Machinery Regulation by Commission delegated acts, which should apply by 2 August 2028.
These dates do not change 20 January 2027: the Machinery Regulation, including its rules on self-evolving safety functions, applies from that date.
Checklist for buyers before 20 January 2027
- List the robots you plan to receive after 20 January 2027 and ask for the date each unit will be placed on the EU market.
- For those units, ask for an EU declaration of conformity that cites Regulation (EU) 2023/1230 and the standards applied.
- Check whether the instructions are digital, and request paper at purchase if your teams need it.
- For a robot with a safety function based on machine learning, ask whether a notified body took part.
- Ask how software updates are delivered and logged, and who may change safety settings.
- Before any modification, physical or digital, check whether it could be a substantial modification.
- For rented or RaaS robots, agree in writing who handles updates, modifications and documents.
Our full guide explains each requirement article by article: Machinery Regulation 2023/1230: what changes for robots in January 2027.
What Robot Distribution does
Robot Distribution checks the CE marking and the EU declaration of conformity of every robot before delivery, and is reviewing its catalogue model by model for 20 January 2027.
For a robot to be delivered around that date, state the planned delivery date in your quote request so the right documents are prepared.
Sources
- Regulation (EU) 2023/1230 on machinery · EUR-Lex · accessed
- Machinery: Regulation (EU) 2023/1230 and Directive 2006/42/EC · European Commission · accessed
- Regulation (EU) 2026/1744 (Digital Omnibus on AI), OJ L, 24.7.2026 · EUR-Lex · accessed
General information, not legal advice.
