The standard was cited on 7 September. The citation expires on 20 January.

Commission Implementing Decision (EU) 2026/2015 of 4 September 2026 appeared in the Official Journal on 7 September 2026. It amends Implementing Decision (EU) 2023/1586 as regards harmonised standards for machinery drafted in support of Directive 2006/42/EC. It inserts "223a. EN ISO 10218-1:2025 Robotics – Safety requirements – Part 1: Industrial robots (ISO 10218-1:2025)" and "224a. EN ISO 10218-2:2025 Robotics – Safety requirements – Part 2: Industrial robot applications and robot cells (ISO 10218-2:2025)". The legal bases are Article 10(6) of Regulation (EU) No 1025/2012 and Article 7(3) of Directive 2006/42/EC.

Article 2 of that decision is one sentence long. It reads: "Implementing Decision (EU) 2023/1586 is repealed with effect from 20 January 2027." Article 3 brought it into force on the day of publication. The Commission's own page notes that "the date 20.01.2027 may be stated as end of legal effect under Machinery Directive 2006/42/EC".

The presumption of conformity granted on 7 September 2026 lasts 135 days. That is the interval from publication to 20 January 2027, and I counted it twice. EN ISO 10218-1:2025 is the third edition and EN ISO 10218-2:2025 the second, both published in February 2025 at stage 60.60. Roughly eighteen months passed between publication and citation, and the wait ran about four times longer than the citation will.

No standard has been cited in the Official Journal under Regulation (EU) 2023/1230, and the search that produced that zero can be stated. I searched EUR-Lex for the full phrase "harmonised standards for machinery drafted in support of Regulation" and it returns nothing. The same phrase ending "in support of Directive" returns ten or more, including the decision published on 7 September 2026. That is what makes the zero evidence rather than a failed search. The Commission's index of harmonised standards has no page for Regulation (EU) 2023/1230, and its machinery page lists eight Official Journal publications, from 2 August 2023 to 7 September 2026, all in support of the Directive.

That absence is measured rather than assumed, and it does not mean nothing is happening. The Commission states that "a new Commission Implementing Decision with the list of harmonised standards under the new Machinery Regulation is being prepared". The same page adds that "the first Machinery Regulation list can be expected before the end of this year". That page carries no date, so which year it means is unstated. Work is under way. What has not happened is publication.

Three sources give three different dates for that list. CECE, reporting from the Commission's Machinery Expert Group, said the first batch was expected in the course of the third quarter of 2026. IBF Solutions, writing in August 2026, reports that more than 600 of roughly 800 standards have been assessed, with citations expected in the fourth quarter of 2026, the one dated and attributed estimate of the three. The Commission's undated page says before the end of the year. Eight days of the third quarter now remain, and nothing has been published under the Regulation.

Losing a citation is not the same as losing a certificate. The two are easily conflated, and I had to separate them. The Blue Guide states that withdrawing a reference "does not automatically invalidate existing certificates issued by notified bodies; it only concerns the conformity that is conferred onto new conformity assessments". Article 52(2) keeps EC type-examination certificates issued under Article 12 of Directive 2006/42/EC valid "until they expire". The route actually at risk is self-declared conformity, which is the route most integrators take.

Article 20(1) ties the presumption to standards covering Annex III of the Regulation. It presumes conformity with "the essential health and safety requirements set out in Annex III covered by those standards". Implementing Decision (EU) 2026/2015 cites these two against Annex I of the Directive. It is repealed on the day the Directive stops applying. I read Article 52 for a provision carrying Directive-era standards forward, and it carries only products placed on the market before 20 January 2027 and Article 12 certificates.

I could not find an official source addressing this exact case. A citing decision repealed on the same day as the legislation it supports is not covered anywhere I looked. The hinge is a reading of Article 20(1) together with Article 52, and it is inference, not settled law. If the Regulation list is published before 20 January 2027, the gap closes and this post ages into a footnote. Until then the narrow claim holds: a robot maker can apply EN ISO 10218-1:2025 today and hold a real presumption of conformity, under a Directive that stops existing on 20 January 2027, with nothing yet cited to replace it.