EU Machinery Regulation:
From 2027, every language version carries equal weight.
On 20 January 2027, the EU Machinery Regulation drops the distinction between original instructions and their translation. From that date, every language version has to meet the requirements on its own.
What that means for you: an unclear warning in the Polish version is no longer a translation error. It is a defect in your documentation. That applies to the instructions for use, the safety information, the EU declaration of conformity and the EU declaration of incorporation. Eight questions in the language check show you where you need to act.
Peer Bosse is your contact for machinery and plant engineering. · service@tolingo.com
Technical writing and export teams have worked with tolingo since 2007
From this date, Regulation (EU) 2023/1230 applies, with no phase-in period.
What counts is the date a product is first placed on the market. Machinery lawfully placed on the market before then may still be made available (Article 52, Section 11 MaschinenDG). Everything new after that falls under the new rules.
Source: Regulation (EU) 2023/1230 on EUR-Lex, Article 54.
The key facts at a glance
Six things to have in place by 2027.
The regulation changes little about your machine. It changes which documents go with it, in which language, and for how long. tolingo covers points 1 to 3 and 6 directly.
01
Set the language matrix
Which document, in which target market, in which language. Scope, cost and schedule all follow from that.
02
Get the declarations translated
The EU declaration of conformity, plus the declaration of incorporation and assembly instructions for partly completed machinery. Suppliers who have shipped these in English will need the target market's own language version from 2027, and German for Germany.
03
Add the new terminology
Protection against corruption, self-evolving behaviour, human-machine interaction. Settle these terms first, or every language comes back with a different answer.
04
Plan digital delivery
Access details on the machine, every language version printable and downloadable, online for at least ten years.
05
Set up a print route
Within a month of a request made at purchase. That only works if every language version is ready to print.
06
Decide how content reaches us
Exporting packages by hand from the editorial system, or exchanging them over COTI. At twelve languages per model cycle, that choice decides the workload.
Where we come in.
Warnings, cybersecurity chapters and declarations carry liability. Spare parts lists, maintenance tables and boilerplate carry volume. The two need different treatment, but both should reach translation the same way.
Warnings, AI safety functions, protection against corruption, declarations of conformity and incorporation. A native-speaker specialist translator with a mechanical engineering background translates, and a second one revises under the four-eyes principle. From €0.12/word.
Maintenance tables, spare parts lists, variants and recurring blocks. Machine translation first, then full post-editing by a trained specialist. From €0.05/word.
One set of terms across both routesBoth draw on the same translation memory and the same termbase. "Protection against corruption" reads the same way in every language and in every document.
Connecting your editorial system
COTI, the standard from the DERCOM association, governs how packages move between an editorial system and a language service provider. tolingo supports all three levels, plus a REST API and watched folders.
Standardised packages, handed over manually. Structure, metadata and language direction all survive the trip. A good starting point while the editorial system is still being built.
The editorial system drops the package into a watched folder and the translation comes back to the same place. No development project, see system integration.
The editorial system starts the job, checks the status and imports the result automatically. For Schema ST4, COSIMA or TIM-RS. Details: API and tolingo connect.
The route is the same for every language. New target markets are switched on within the existing connection, with no new setup.
Transfer is encrypted and runs on European servers to ISO 27001. How we handle design data and unreleased product documents: quality and security.
What translation memory and post-editing are worth
Machinery documentation repeats itself: warnings, maintenance steps and assemblies read the same across models and variants. The worked example below uses the word prices above to show what repetition and the choice of route are worth.
| Worked example: 60,000 words, 8 target languages | Route A | Route B |
|---|---|---|
| Approach | everything as specialist translation, no translation memory | split by document type, with translation memory |
| Safety-related share | 60,000 words at €0.12 | 18,000 words at €0.12 (ISO 17100) |
| High-volume share | included in the above | 42,000 words at €0.05 (ISO 18587) |
| Per language | €7,200 | €4,260 |
| Eight languages, first translation | €57,600 | €34,080 |
| Next cycle, 40% repetition | €57,600 again | billed only on the 60% that changed |
These figures are a worked example using the entry prices on this page, not a quote. Your actual safety-related share and repetition rate only become clear once your files have been analysed. That is exactly what the free language and process review covers.
Your free language check
Eight questions, about two minutes. At the end you see which of the six points are still open at your company, and which service closes the biggest one first. The check looks at language needs and process; it is not a conformity assessment.
No email address, nothing stored. If you want to talk afterwards, one click carries your answers into the enquiry form.
- Drawn from the regulation and the MaschinenDG
- About two minutes, stop whenever you like
- A result that names the service that fits
- An assessment of where your translations stand, not a legal review
Result
Answer the questions to see where you stand.
Your result appears here once all eight points are set.
A checklist you can work through.
"Machinery Regulation 2027: translation and documentation in 12 steps". The points from the self-check as a checklist with references into the regulation, ready for the conversation with engineering, procurement and legal.
Free language and process review
Send us your target markets, a rough word count and the editorial system you use. We come back with an assessment of which documents need which languages, which route suits each document type, and what that costs. This is a review of language needs and process, not a legal or conformity assessment.
- A personal first reply in ~10 minutes (within business hours); the review itself follows
- No obligation, with an NDA before the upload on request
- Encrypted transfer, EU servers to ISO 27001
Peer Bosse is your contact for machinery and plant engineering.
service@tolingo.com · 0800 55 133 00
Request the review
Treated confidentially · First reply in ~10 minutes (within business hours) · no obligation
Which language each market requires.
There is no EU-wide list of languages. Article 10(7) requires the language determined by each member state, in a form users find easy to understand. Ship to twelve countries and you track twelve national rules.
The German implementing act has been in force since 6 December 2025, and its language requirements apply from 20 January 2027. Section 2(1) requires German for the instructions for use, the safety information and the EU declaration of conformity; Section 2(2) covers assembly instructions and the EU declaration of incorporation for partly completed machinery. The note explaining how to reach the digital instructions has to be in German too. Full text.
Assembly instructions and the declaration of incorporation have often shipped in English. Article 11(7) and Article 22(2) require the language of the target market, and Section 2(2) MaschinenDG requires German for Germany.
Section 9 MaschinenDG lists 26 administrative offences carrying fines of up to €10,000, and up to €100,000 in certain cases. Section 10 provides for up to one year of imprisonment where a deliberate breach endangers life or health. These provisions take effect on 20 January 2027.
Digital is allowed, with conditions attached.
Digital delivery is permitted as long as the access details are given, the document stays printable and downloadable, and it stays online for at least ten years. That turns every language version into something with a lifecycle rather than a one-off delivery.
On the machine, on the packaging or in an accompanying document.
- A machine-readable code or a plain web address
- In Germany, that note has to be in German as well
- Ideally it opens the language version for that market
Users have to be able to take the instructions with them, online or off.
- Printing, downloading and saving locally all have to work
- The same goes for every language version
- Layout and warnings have to stay legible in print
For the expected lifetime of the machine, and at least ten years.
- Counted from the day that machine is placed on the market
- You have to be able to tell versions and variants apart
- From 2027, a dead link is a documentation defect
Paper is still in play. Where a machine may be used by non-professional users, the essential safety information ships in printed form. On top of that, any buyer can ask at the time of purchase for a free paper copy, to be supplied within a month. Well-kept terminology and a clean translation memory are what keep reprints consistent over the years.
Six claims, checked against the regulation.
Six claims you hear often, checked against the text of the regulation, each with the reference so you can look it up.
This sets out the legal position and is not legal advice. Your own product is for your legal team or your notified body to assess.
| Claim | Verdict | What follows from it |
|---|---|---|
| The instructions for use may be supplied digitally, for example through a machine-readable code.Article 10(7) | Confirmed | The access details have to appear on the machine, the packaging or an accompanying document. In Germany that note has to be in German too (Section 2 MaschinenDG). |
| The instructions have to exist in every official language of every country you sell into.Article 10(7) | Partly | What is required is the language determined by the member state, in a form users find easy to understand. In practice that is the national language of each target market. |
| Digital documentation has to stay available, printable and downloadable for at least ten years.Article 10(7)(b) and (c) | Confirmed | The expected lifetime of the machine, and at least ten years from the day it was placed on the market. That covers every language version. |
| Printed safety information stays mandatory for non-professional users, with a paper copy on request.Article 10(7) | Confirmed | Free of charge within one month of a request made at purchase. That calls for a print route in every language. |
| Declarations of conformity and of incorporation have to be translated.Article 21(2), Article 22(2) | Confirmed | Into the languages the member state requires. For partly completed machinery the assembly instructions follow the same rule (Article 11(7)). |
| Newly covered: AI safety components, autonomous mobile machinery, cybersecurity and human-machine interaction.Annex I Part A No. 5 and 6, Annex III | Confirmed | Safety components with self-evolving behaviour sit in Annex I Part A No. 5, machinery with such systems embedded in No. 6. Annex III 1.1.9 governs protection against corruption. |
Four topics that never used to be in the instructions.
The regulation covers technology that did not exist in 2006. New chapters for the technical writers, and new terms with no settled equivalent in the target languages.
Annex I Part A No. 5 covers safety components with self-evolving behaviour, and No. 6 machinery with such systems embedded. The documentation has to describe the limits the risk assessment sets. Safety-related, so ISO 17100.
That is what Annex III 1.1.9 calls cybersecurity. Safety-related software and data have to be identified as such and protected against corruption. The instructions end up carrying chapters on access rights, updates and tamper protection.
For driverless machinery, Annex III calls for details of travel zones, working zones and hazard zones, and of what happens when something fails. Short, safety-critical warnings that have to land in more than twenty languages.
Operator interfaces count as safety-related information. Where the instructions are embedded in the controls, the same language and availability rules apply. Display and instructions have to use the same terms.
Terminology to add to your termbase
Twenty terms with their German source, as a starting point for your termbase and translation memory.
| German | English | Context |
|---|---|---|
| Maschinenverordnung | Machinery Regulation | Regulatory |
| dazugehöriges Produkt | related product | Product classes |
| unvollständige Maschine | partly completed machinery | Product classes |
| Sicherheitsbauteil | safety component | Product classes |
| selbstentwickelndes Verhalten | self-evolving behaviour | AI and software |
| maschinelles Lernen | machine learning | AI and software |
| Schutz gegen Korrumpierung | protection against corruption | Cybersecurity |
| Cybersicherheit | cybersecurity | Cybersecurity |
| Mensch-Maschine-Interaktion | human-machine interaction | Operation |
| autonome mobile Maschine | autonomous mobile machinery | Product classes |
| wesentliche Veränderung | substantial modification | Regulatory |
| Betriebsanleitung | instructions for use | Documentation |
| Montageanleitung | assembly instructions | Documentation |
| EU-Konformitätserklärung | EU declaration of conformity | Documentation |
| EU-Einbauerklärung | EU declaration of incorporation | Documentation |
| grundlegende Sicherheits- und Gesundheitsschutzanforderungen | essential health and safety requirements | Regulatory |
| Konformitätsbewertungsverfahren | conformity assessment procedure | Regulatory |
| notifizierte Stelle | notified body | Regulatory |
| Risikobeurteilung | risk assessment | Engineering |
| Inverkehrbringen | placing on the market | Regulatory |
Just under six months to 20 January 2027.
That is enough for an orderly changeover, as long as the language packages are planned now. Start with the self-check, or ask for a quote straight away.
Deadlines, languages, formats and cost.
When does the EU Machinery Regulation 2023/1230 apply?
From 20 January 2027, directly in every member state (Article 54). What counts is the date a product is first placed on the market. Machinery lawfully placed on the market before then may still be made available.
What changes compared with Machinery Directive 2006/42/EC?
The regulation applies directly, with no national transposition. New requirements cover AI safety functions, cybersecurity, autonomous mobile machinery and human-machine interaction. Digital instructions become permitted, and the label "original instructions" disappears.
Which language do the instructions for use have to be in?
The language determined by the member state concerned, in a form users find easy to understand (Article 10(7)). For Germany, Section 2 MaschinenDG requires German. With several target markets, each national rule applies in its own right.
From 2027, can I supply the instructions in digital form only?
For professional users, yes, provided the access details are given and the document can be printed, downloaded and saved. Where a machine may be used by non-professional users, the essential safety information has to ship in printed form.
How long do the digital instructions have to stay online?
For the expected lifetime of the machine, and at least ten years from the day it was placed on the market (Article 10(7)(c)). That covers every language version, which is why translations need version control.
Do I have to supply a paper copy on request, and how quickly?
Yes. Within one month of a request made at the time of purchase, free of charge, in the language version the target market requires. A print route for every language version therefore stays necessary.
Does the paper requirement still apply for non-professional users?
Yes. The safety information essential for safe operation ships in printed form, while the full instructions may be digital. The printed information is subject to the same language rule as everything else.
Does the EU declaration of conformity have to be translated?
Yes, under Article 21(2), into the languages the member state requires. Section 2(1) MaschinenDG requires German for Germany. Where it is supplied digitally, Article 10(8) applies.
What applies to partly completed machinery and the declaration of incorporation?
The declaration of incorporation under Article 22(2) and the assembly instructions under Article 11(7), both in the language of the target market. Section 2(2) MaschinenDG requires German for Germany.
Which cybersecurity requirements affect the documentation?
Annex III 1.1.9 requires safety-related software and data to be identified as such and protected against corruption. The instructions then carry chapters on access rights, updates and tamper protection.
How do AI safety functions affect the documentation?
Annex I Part A No. 5 covers safety components with self-evolving behaviour, and No. 6 machinery with such systems embedded. The documentation describes the limits set by the risk assessment. That is safety-related content, so ISO 17100.
What counts as a substantial modification?
A change the manufacturer did not foresee that creates a new hazard or increases an existing risk, whether physical or delivered by software update. Whoever makes it takes on the manufacturer's obligations, including updated documentation.
Which translation standards apply to technical documentation?
The regulation names none. In practice, ISO 17100 for specialist translation with independent revision and ISO 18587 for post-editing. tolingo is certified to both, and to ISO 9001 and ISO 27001.
How much lead time does a multilingual project need before 2027?
Several months for a package of a few thousand segments in ten to twenty languages, including terminology work and specialist review. Taking stock first shows what genuinely has to be translated from scratch.
What does it cost to translate instructions for use?
Specialist translation to ISO 17100 from €0.12/word, post-editing to ISO 18587 from €0.05/word. Repetitions from the translation memory are credited. For recurring document types we agree fixed prices on request.
Glossary: terms from the regulation and from translation practice
- Placing on the market
- The first time a machine is made available on the Union market. That date decides whether Directive 2006/42/EC or Regulation (EU) 2023/1230 applies.
- MaschinenDG
- The German act implementing the Machinery Regulation, in force since 6 December 2025. It governs responsibilities, market surveillance, penalties and, in Section 2, the language requirements.
- Protection against corruption
- Cybersecurity for machinery (Annex III 1.1.9). Safety-related software and data have to be identified as such and protected against alteration.
- COTI
- Common Translation Interface, the DERCOM standard for moving packages between an editorial system and a language service provider. Level 1 is manual, level 2 uses watched folders, level 3 a direct interface.
- Translation memory
- A store of segments already translated. It keeps identical warnings identical over the years and brings down the cost of follow-up work.
Let's talk about your language packages.
Send us your target markets, your word count and your editorial system. We come back with a concrete assessment and a quote, with no obligation.