§ Regulation (EU) 2023/1230 · applies from 20 January 2027
A regulatory twin for each machine: digital instructions reachable by QR code, a versioned technical file kept available for ten years, and a harmonised-standards watch that alerts you when a citation moves. The manufacturer signs; the passport proves, preserves and monitors.
Days remaining
until 20 January 2027
No transition period. Any machinery placed on the EU market from that date falls under the new Regulation — whatever state your range is in.
01 What the text requires
They are not of the same kind: one is a condition of access, one a document to produce, the third a state to monitor. The passport holds all three.
art. 10(7)Condition of access
The Regulation finally allows instructions in digital format — on three conditions: access is indicated on the machinery, the format stays printable and downloadable, and it remains available for at least ten years after placing on the market. A QR on the nameplate, a versioned page, full history kept.
Annex IVDocument to produce
EN ISO 12100 risk assessment, essential requirements justified one by one, and an evidence register with four truth states. Gaps appear with their closing path — a test protocol your own designated staff runs and signs — never dressed up as compliance.
art. 20State to monitor
Presumption of conformity rests on standards cited in the Official Journal. As of 26 August 2026, no standard has yet been cited under the Regulation; citations will arrive in waves before the application date. When one moves, the files invoking it are identified and their owners notified, with the excerpt and the source.
02 Importers and distributors
Article 13 puts real duties on the importer — and article 16 makes anyone a manufacturer who places machinery on the market under their own name, or modifies it substantially.
art. 13Before shipping
The importer must check that the conformity assessment was carried out, that the technical documentation exists, that the CE marking and instructions are there — and must refuse to place non-compliant machinery on the market. Its own name and address go on the machinery.
Annex IIIWhat we build
For machinery entering the Union — industrial cells, AGV and AMR fleets, mobile and humanoid robots — we build the Annex IV file and map non-EU test evidence against the essential requirements of Annex III, marking honestly what transfers and what has to be re-established in Europe.
03 Straight answers
From 20 January 2027, with no transition period, to any machinery — and related product — placed on the EU market from that date. It binds manufacturers, importers and distributors alike. Machinery already in service is not caught, unless it undergoes a substantial modification.
Yes. A modification not foreseen by the manufacturer, which affects safety and requires new protective measures, makes its author a manufacturer within the meaning of the Regulation — with the full set of obligations. Every retrofit should be assessed, and the conclusion recorded.
BYSS GROUP, a French company established in Fort-de-France (company register 103 443 719). We assist in constituting the technical file — responsibility for conformity rests with the manufacturer or the importer (art. 10 and 13). We are not a notified body and issue no certificates. Our standards register is verified down to the citing act and its date.