You have 127 days. Nobody publishes how long this takes.

Regulation (EU) 2023/1230 will apply from 20 January 2027. Counted from 15 September 2026, that is 127 days. It is a cut-off with no transition period, and Directive 2006/42/EC is repealed with effect from the same date by Article 51(2). Nothing sits between the two instruments.

The obvious thing to establish is how long the work in between takes. I went looking for a published duration and found none. The set checked was TÜV SÜD, TÜV Rheinland, TÜV NORD, exida, UL Solutions, SGS and Certification Management Ltd — six query sweeps, roughly sixty result URLs, four pages opened in full. Not one of those seven bodies publishes a duration benchmark for IEC 61508 SIL 2 or SIL 3 assessment, or for ISO 13849 PL c or PL d.

A second and narrower question fared worse: how long a notified-body conformity assessment runs, from application to certificate. Three queries plus the Commission's own notified-body database returned roughly twenty-five URLs and not one primary figure. That result is weaker than the first, and it should be read as weaker. The first is a measured absence over a named set of seven; the second is not measured at all, and I cannot settle from this sweep whether such a figure exists elsewhere.

The missing figure is the finding. An estimate of that duration has appeared on this site before, marked there as a planning estimate drawn from the lifecycle's structure rather than a surveyed average. That label was the accurate one, and the deadline is indifferent to which kind of number sits on the page.

Four things are documented, and they are worth more than an estimate.

The calendar is the only hard number here. Fifteen days remain in September, then thirty-one in October, thirty in November, thirty-one in December, and twenty in January — 127 in total. That is arithmetic rather than a projection, and the only quantity here that nobody had to choose to publish.

The first assessor was notified on 8 September 2024, roughly twenty-eight months before the Regulation applies. That is the earliest record for a notified body in the Commission's database, and it bounds the whole system: no conformity assessment under this Regulation can have been running longer than the roughly twenty-four months since. It does not reveal how long an assessment takes. It reveals how little calendar has existed in which to complete one.

No harmonised standard has yet been cited in the Official Journal under the Regulation. As of 13 September 2026, every machinery citation the Commission lists — including the most recent, made on 7 September 2026 — was in support of Directive 2006/42/EC. The same search returns at least ten results for citations in support of the Directive and none in support of the Regulation. The Commission's own page says a first list under the Regulation "can be expected before the end of this year". The page carries no date, so which year that wording means is not established. The dated estimate is IBF Solutions', which in August 2026 projected the fourth quarter of 2026, and which reports that the standardisation request was adopted on 20 January 2025 and that its first-phase deadline of 20 January 2026 was missed.

Seven trade associations put on record that machinery was the only sector left out. On 17 February 2026, CECE, CECIMO, CEMA, EGMF, EUnited, FEM and ATVEA stated jointly that machinery is the only industry excluded from the Omnibus IV transition period. Their wording was exact: machinery manufacturers "would have to comply directly at the date of application of the Machinery Regulation in January 2027, with no additional transition period". Their stated reason was structural rather than a claim about readiness — long product development cycles, complex value chains, and significant upfront investment. A joint statement in seven signatures says more about time than a benchmark would, because the signatories are the ones who would be measured.

One limit belongs here, and it keeps the claim honest. Article 52(1) carries forward products already placed on the market before 20 January 2027. I am not saying the window has closed. I am saying it has closed for one case: a product that must be placed on the market after 20 January 2027 by a route that depends on something nobody can yet supply.

If a certification body has published a duration benchmark for SIL 2 or SIL 3 assessment and I have missed it, that would close half of this, and I would like to see it. Until then the position is narrow. The deadline is measured to the day. How long the work behind it takes is not measured at all.