EU Machinery Regulation: what changes for your documentation

The EU Machinery Regulation (EU) 2023/1230 applies from 20 January 2027, with no transition period. It allows digital instructions for use, and it tightens what is expected of your language versions, their availability and your terminology. This article sets out what that means for technical documentation and translation workflows in mechanical engineering.

The short version

• What applies: Regulation (EU) 2023/1230 replaces Machinery Directive 2006/42/EC and applies from 20 January 2027. On that date there is no option to fall back on the old rules.
• Who it affects: manufacturers, importers, distributors and authorised representatives of machinery, related products and partly completed machinery.
• Language duties: instructions for use, safety information, the EU declaration of conformity and the EU declaration of incorporation must be in the language set by the destination country. For the German market, the MaschinenDG requires German.
• What it costs: specialist technical translation from €0.12/word, post-editing to ISO 18587 from €0.05/word. Repetitions from translation memory bring that down by up to 70%.

What the EU Machinery Regulation covers

Regulation (EU) 2023/1230 is the new European rulebook for machinery safety. It was published in the Official Journal on 29 June 2023, entered into force on 19 July 2023 and applies from 20 January 2027. From that date it replaces Machinery Directive 2006/42/EC in full.

Moving from a directive to a regulation has one practical consequence: the text applies directly in every member state, with no national transposition. National rules survive only where the regulation makes room for them, such as the language of the documents and the penalties. Machinery placed on the market under the old rules before the deadline may still be made available.

Digital instructions: allowed, with conditions

For the first time, the regulation expressly permits instructions for use to be supplied digitally, for example through a machine-readable code on the machine. That relief comes with strings attached: the format must let the user print, download and save the document, and it has to stay available online for the expected lifetime of the machine, and for at least ten years after it is placed on the market.

Two points are easy to miss. First, if the user asks for a paper copy at the time of purchase, the manufacturer has one month to supply it free of charge. Second, where machinery is intended for non-professional users, or may reasonably be used by them, the essential safety information still has to be supplied on paper.

That changes what translation has to deliver. A digital manual is not a finished document but a body of content that has to be maintained for a decade. Every change to the machine or its software pulls all the language versions along with it.

Which documents need translating, and into which languages

Instructions for use, safety information and conformity documents have to be clear, understandable and legible, in a language determined by the member state concerned. Ship into twelve EU markets and you need up to twelve reviewed language versions.

Germany: what the MaschinenDG adds

The German implementing act of 2 December 2025 fills the gaps the regulation leaves to national law. It repeals the old 9th ProdSV, sets out how conformity assessment bodies are notified, defines the penalties and, in section 2, settles the language of the documents. Those language rules apply from 20 January 2027.

For the German market that means the instructions for use, the information required by Annex III, the EU declaration of conformity, the assembly instructions and the EU declaration of incorporation all have to be written in German. Where the manual is supplied digitally, the notice explaining how to reach it has to be in German too. Breaching these language rules is listed in the act as an administrative offence.

Other member states settle this in their own implementing acts. If you export to France, Spain or Poland, check each set of national rules separately. An English version rarely covers it.

AI, autonomy and cybersecurity: new terms to get right

The regulation covers technologies that played no part in 2006. Annex I Part A lists, among others, safety components and machinery with fully or partly self-evolving behaviour that uses machine learning to deliver safety functions. For those products, a notified body has to be involved in conformity assessment.

Annex III 1.1.9 adds protection against corruption: manufacturers have to account for risks from third parties interfering with hardware or software. Software that performs a safety function counts as a safety component in its own right.

These subjects bring words into your documentation that have no settled equivalent in many target languages yet. Without an approved termbase, one translator writes "self-evolving behaviour", the next writes "self-learning" and a third writes "adaptive". Inside a warning, that is a liability. Our page on terminology management shows how to lock it down.

What this changes in your translation workflow

Three changes reach straight into the daily work of technical writers and localisation teams. They affect how language versions are produced and maintained more than any single job.

The "original instructions" label is gone

Annex III 1.7.4 no longer asks you to mark versions as "original instructions" or "translation of the original instructions". Every language version now stands on equal footing, which raises the bar for each one of them.

Ten years of keeping versions in step

Digital manuals stay reachable for the life of the machine. Every software or documentation update has to reach all languages. A well-kept translation memory is what keeps partial updates affordable.

Content systems, connected

Manuals increasingly live as modules in editorial systems such as Schema ST4, COSIMA or TIM-RS. An API or a system integration pushes changed modules into translation as soon as they are edited.

Your roadmap to January 2027

There is enough time left if the stocktake starts now. The effort rarely sits in the translation itself. It sits in sorting through everything that has piled up over the years.

1. Take stock of the documents. Which manuals, declarations and safety notices exist, in which languages, and how current are they?
2. Match markets to languages. Record the required official language for every destination country, including for partly completed machinery.
3. Clean up the translation memory. Find and replace references to Directive 2006/42/EC, superseded legal wording and the old labelling notices.
4. Build terminology for the new subjects. Approve the wording for machine learning, autonomous operation and cybersecurity before it turns up inside a warning.
5. Test the digital delivery. Check that every language version is reachable, printable and downloadable behind the code you publish.
6. Define the sign-off chain. Decide who approves safety-critical passages in the target language, and how that approval is recorded.

Where tolingo comes in

tolingo has been translating technical documentation since 2007 and knows the document types in mechanical engineering as well as those in robotics and automation. These are the services that matter for the switch to the new regulation:

• A check on your language assets. We go through your existing translation memories and glossaries for wording tied to the old Machinery Directive, and report back on which segments to revise before they are reused.
• Terminology for the new subjects. An approved termbase built through glossary creation and kept current through terminology management, including the terms that should never be translated at all.
• Operating and assembly instructions. Manual translation by specialist translators with an engineering or technician background, revised by a second subject expert under ISO 17100.
• Declarations of conformity and incorporation. The legally binding declarations, translated into every official EU language you need. When the date is tight, through express translation.
• HMI and software interfaces. Software localisation for controls and operator panels. We work directly in XML, JSON and PO files and watch string lengths on PLC and CNC displays.
• High volumes with post-editing. For spare parts catalogues and data sheets, post-editing to ISO 18587 from €0.05/word. For warnings and risk assessments we still recommend human translation.
• Connecting your content systems. Through tolingo connect, an API or a system integration, edited modules trigger translation on their own instead of travelling by email.
• Layout, typesetting and final checks. Layout adaptation for InDesign and FrameMaker, plus editing and proofreading for versions you already hold and want checked.

How we handle confidential design documents is set out on our page about security and data protection. For a worked example from special-purpose machinery, see the Becker Sonder-Maschinenbau case study.

Want your documentation reviewed before the deadline? Send us one instruction manual or one declaration of conformity. We come back with a read on volume, languages and how much of it can be reused. Start a document analysis, free and without obligation, reply in ~10 minutes within business hours.

Frequently asked questions

When does the EU Machinery Regulation apply?

Regulation (EU) 2023/1230 applies from 20 January 2027. Until 19 January 2027 machinery may still be placed on the market under Machinery Directive 2006/42/EC. On the deadline itself there is no choice between the old and the new rules. Products lawfully placed on the market before then may still be made available.

Do instructions for use still have to be supplied on paper?

Not as a rule. The manual may be supplied digitally. If the user asks for a paper copy at the time of purchase, the manufacturer has one month to supply it free of charge. For machinery used by non-professional users, the essential safety information still has to be included on paper.

Which languages do I have to translate my documentation into?

Into the language determined by the destination member state, one that users there can readily understand. For the German market the MaschinenDG requires German. This covers the instructions for use, the safety information, the EU declaration of conformity, the assembly instructions and the EU declaration of incorporation. Twelve target markets can therefore mean twelve language versions.

What does translating technical documentation cost?

Post-editing of machine output to ISO 18587 starts at €0.05/word, and specialist translation at €0.12/word. Repetitions from translation memory bring the price down by up to 70%. You will find an overview on our prices page.

Do I have to retranslate all my existing manuals?

Usually not. What helps is a review of the existing content: outdated references to Machinery Directive 2006/42/EC, superseded legal wording and the old labelling notices are replaced, and the rest stays available through translation memory. The effort is normally a fraction of a fresh translation.

Can AI translate safety-critical text?

For warnings, risk assessments and declarations of conformity we recommend translation by subject experts with a second reader afterwards. For spare parts catalogues, data sheets and bills of materials, post-editing to ISO 18587 is a sound and cheaper route.

How quickly do I get a quote?

Once you upload your document we analyse volume, language pair and repetition rate. You get a reply with a binding quote in about 10 minutes within business hours. Where the date is tight we deliver within 24 hours through express translation.

Key terms explained

Related product

The regulation's umbrella term for interchangeable equipment, safety components, lifting accessories, chains, ropes, webbing and removable mechanical transmission devices. These carry the same documentation and language duties as machinery itself.

Partly completed machinery

An assembly that performs no specific function on its own and becomes machinery only once it is built in. It needs assembly instructions and an EU declaration of incorporation rather than instructions for use.

Substantial modification

A physical or digital change made after the machinery was placed on the market, unforeseen by the manufacturer, that affects safety. It can make the machinery a new product in law, with documentation to match.

CE marking

The visible sign that the manufacturer declares conformity with the applicable EU rules. It rests on the risk assessment, the technical file and the EU declaration of conformity.

Four-eyes principle

The ISO 17100 procedure in which a second qualified linguist checks the translation against the source. At tolingo it is part of the premium service and recommended for safety-critical text. More on our quality page.

Sources

Legal sources: Regulation (EU) 2023/1230 on EUR-Lex and the MaschinenDG on gesetze-im-internet.de (German only). This article gives an overview and does not replace a legal review of your own case.

Related reading

• Technical translation
• Translation for mechanical engineering
• User manual translation
• Terminology management
• Translation memory
• Post-editing to ISO 18587
• Software localisation
• All industries
• All languages
• Our translators
• Quality and certifications

Written by the tolingo editorial team, engineering and industry. Last updated: 29 July 2026. Your contact: Philipp Walzok, service@tolingo.com, 0800 55 133 00.