Five months until EU Machinery Regulation 2023/1230 applies

Five months. That's what's left before EU Machinery Regulation 2023/1230 applies.

The date is January 20, 2027. It's a cut-off date regulation — a term both TÜV NORD and TÜV Rheinland use explicitly. The currently valid Machinery Directive 2006/42/EC will be replaced on that date. There is no provision for a transition period in which both sets of regulations are applicable and valid in parallel.

Machinery placed on the market up to and including January 19, 2027 must comply with the Machinery Directive. Machinery placed on the market from January 20, 2027 must meet the requirements of the Machinery Regulation. The switch is clean and absolute.

What changes: the Regulation introduces new requirements for AI-based safety functions, mandatory cybersecurity provisions for connected machines, digital documentation replacing paper, and expanded conformity assessment procedures. Six categories of high-risk machinery listed in Annex I Part A now require mandatory third-party certification through a notified body — applying a harmonized standard alone no longer exempts a manufacturer from this obligation.

For companies building autonomous robots or AI-embedded machinery: if you're starting a certification process from scratch today, five months is not enough time. A functional safety certification project typically takes 12 to 24 months for a SIL 2 product. The European Commission is still working on a complete list of harmonized standards for the new Regulation — the aim is to have an implementing decision by end of 2026, just weeks before the deadline. The companies that began preparing in 2025 will be ready. The ones starting now face a choice between delaying market entry or shipping non-compliant products into the EU — neither of which is a good option.