Machinery Regulation (EU) 2023/1230 applies from 20 January 2027 to every machine placed on the market from that day onwards. There is no transition period. From mid October 2026 that leaves roughly 100 days, and those weeks decide whether your language versions are ready in time.
Our reference article sets out the six steps of the changeover under Roadmap to January 2027. This post spreads those steps across the time you have left: what has to be decided first, which documents take priority and where translation projects lose time at this stage.
This is an account of the legal position, not legal advice.
Every machine placed on the market from 20 January 2027 needs its instructions for use, its safety information and its EU declaration of conformity in the language the destination country specifies. For partly completed machinery the same applies to the assembly instructions and the EU declaration of incorporation. The basis for this is Article 10(7), Article 11(7) and Articles 21 and 22 of the Regulation.
For Germany, section 2 of the MaschinenDG, the national act implementing the Regulation, requires German, including for the note that tells the user where to find the digital instructions. Every other member state sets its own language requirement. Our summary of language obligations by destination market sets out which rule applies where.
One change feeds straight into the schedule: the marking “original instructions” disappears. Each language version now stands on its own and has to meet the requirements by itself. Plan the review steps for translations from the start, then, rather than in the last week before delivery.
The deadline applies to machines made available on the Union market from 20 January 2027. Machines lawfully placed on the market before that day may continue to be made available (Article 52, section 11 MaschinenDG). Your first job in October is therefore a list: which models ship from the deadline, and to which countries.
What matters is the point of supply, not the build date. Under the Blue Guide, the European Commission’s guide to implementing EU product rules, a product is placed on the market when it is first supplied for distribution or use on the Union market. Your shipping list then gives you the order of work:
Counting back from 20 January 2027 leaves four working phases. October is for deciding and briefing, November for translating, December for review and layout, January for publishing. If you reach the end of October without a language matrix, you will pay for it in December, when reviewers and approvers in the destination market disappear into the holidays.
| Period | Work packages | Output |
|---|---|---|
| October 2026 | Draw up the shipping list from 20 January, set the language matrix per model and market, review existing translations, agree terms for the new subjects, brief the packages and reserve capacity | Briefed translation packages with a schedule |
| November 2026 | Translate declarations and safety information, then the instructions. Clear references to Machinery Directive 2006/42/EC out of the translation memory. Book review slots in the destination market | First language versions in specialist review |
| December 2026 | Close out review and sign-off, adjust the layout per language, produce print files, test the access note and the links to the digital instructions | Approved, print-ready language versions |
| 1 to 19 January 2027 | Publish the digital versions, apply the access note to the machine, the packaging or an accompanying document, close any outstanding approvals | Complete documentation for the first deliveries |
| From 20 January 2027 | Carry changes and software updates through every language, supply paper versions within one month on request | Ongoing upkeep, digital versions available for at least ten years |
One more date falls inside the first phase. From 20 October 2026, Article 50(1) requires member states to lay down penalties for infringements. Germany sets these out in section 9 MaschinenDG. If you ship to other countries, check their implementing provisions at the same time as their language requirements.
The translation itself is rarely the bottleneck. Time goes on the steps either side of it: specialist sign-off in the destination market, missing terminology for subjects the old instructions never covered and turning each language version into a print-ready document. All three can be planned for in October.
Subsidiaries or distributors in the destination country often cross-check the safety-critical passages. Those reviewers do this alongside their day job, and in December public holidays and shutdowns overlap across several countries. Book the review slots in November, then, and agree who decides when opinions differ. Our quality process sets out how translation and revision fit together.
The Regulation brings terms into the instructions that have no settled equivalent in many target languages, corruption protection and self-evolving behaviour among them. Agree them before translation starts, or every language will decide for itself and the argument will land in the middle of your review phase. The four new subject areas, with a starter list of English equivalents, are on our topic page. For an authoritative termbase per language, see glossary creation and terminology management.
Even with digital delivery, every language version needs a printable file. If a buyer asks for a paper version at the time of purchase, you have one month to supply it free of charge (Article 10(7)). Text expands or contracts from language to language and moves your page breaks, tables and warnings with it. Build layout work into December as a step of its own, for InDesign or FrameMaker.
Digital delivery saves printing and shipping. It changes very little about the volume to translate: the language requirement covers the digital version exactly as it covers paper. It also adds work, namely an access note in the language of the destination market, a printable and downloadable file per language and availability for the lifetime of the machine, at least ten years.
For the final 100 days that means one extra item on the plan if you are switching: testing the access routes. Every language version has to open from the code or address you publish before the first machine ships, and version states have to stay distinct so that later changes can be carried through every language. A well-kept translation memory keeps those follow-up jobs small. The three conditions for digital delivery are set out in full on our EU Machinery Regulation topic page.
tolingo translates technical documentation for mechanical and plant engineering and is certified to ISO 17100, ISO 18587, ISO 9001 and ISO 27001. Three things count for the weeks that remain: a quick read on the volume, the right translation route for each document type and a connection that moves packages without manual handling.
How we handle unpublished design documentation is set out under security and data privacy.
The machine then fails to meet the requirements of the Regulation for that market and cannot be placed on the market there from the deadline. In Germany, breaches of the language obligations can be prosecuted as a regulatory offence under section 9 MaschinenDG. Machines lawfully placed on the market before the deadline are unaffected.
As a rule yes. What counts is the first placing on the market, meaning the first supply on the Union market, not the build date. A machine produced in December and supplied to the customer in February needs documentation under the new Regulation. Your legal team should assess the specific case.
That depends on how far your access routes have come. Digital delivery barely reduces the volume to translate and adds an access note, printability and availability of at least ten years per language. If you cannot test that infrastructure by December, ship the first machines with printed instructions and switch afterwards.
Translation work can be planned around the holidays. Sign-off in the destination market often cannot. Reviewers at subsidiaries and distributors are frequently unreachable between Christmas and early January. Schedule specialist sign-off for mid December, then, and keep January free for loose ends and publication.
No, the Regulation does not require you to hold stock. If a buyer asks for a paper version at the time of purchase, it has to be supplied free of charge within one month (Article 10(7)). What you do need on the deadline is an approved print file per language. Where non-professional users may operate the machine, the essential safety information is supplied on paper in any case.
Legal basis: Regulation (EU) 2023/1230 on EUR-Lex, in particular Articles 10, 11, 21, 22, 50, 52 and 54, together with the German MaschinenDG on gesetze-im-internet.de, sections 2, 9 and 11. On the concept of placing on the market: the European Commission’s Blue Guide on the implementation of EU product rules. This post gives an overview and does not replace legal assessment of an individual case.
What is realistic for you before January? Send us your destination markets, your shipping list and one set of instructions through the free language and process review. First response within ~10 minutes (within business hours).
Written by the tolingo specialist editorial team, technology and industry. Last updated: 15 September 2026. Your contact: Peer Bosse, service@tolingo.com, 0800 55 133 00.