Digital instructions for use: what is allowed, and on what conditions
Instructions may be digital under Regulation (EU) 2023/1230, but only if the model is identifiable, access is marked on the machine, the user can print and save a copy, and it stays online for at least ten years.
Under the old Machinery Directive, instructions travelled with the machine on paper. Since Regulation (EU) 2023/1230 they may be digital instead, which is the change most machine builders have heard about. What gets missed is that the permission comes with four conditions attached, and all four have to hold at once.
“Manufacturers shall ensure that the machinery or related products are accompanied by the instructions for use and the information set out in Annex III. The instructions may be provided in a digital format. Such instructions and information shall clearly describe the product model to which they correspond.”
The model must be identifiable from the instructions
The duty to describe the product model is easy to skim past and it carries real weight. A link to a general support page, or to a folder of manuals for a product family, does not describe the model it corresponds to. The page a user reaches has to be unambiguous about which machine, and which version of it, the document belongs to.
A way in, marked on the machine
“mark on the machinery or related product, or, where that is not possible, on its packaging or in an accompanying document, how to access the digital instructions;”
In practice this is a QR code and a printed address on the nameplate. The wording allows the packaging or an accompanying document only where marking the machine is not possible, so the plate is the default and the fallback needs a reason.
The user must be able to keep a copy
“present them in a format that makes it possible for the user to print and download the instructions for use and save them on an electronic device so that he or she can access them at all times, in particular during a breakdown of the machinery or related product; this requirement also applies where the instructions for use are embedded in the software of the machinery or related product;”
The reason given in the text is the useful part: during a breakdown. A viewer that streams pages, a login wall, or a portal that needs a working network connection all fail this, not because they are bad products but because the moment the instructions matter most is the moment the machine has stopped and the person standing in front of it may have nothing.
Ten years, at least
“make them accessible online during the expected lifetime of the machinery or related product and for at least 10 years after the placing on the market of the machinery or related product.”
Note that it is a floor, not a ceiling. If the expected lifetime of the machine is twenty years, twenty years is the duty. The clock also runs per unit placed on the market, so a model produced from 2027 to 2035 carries its obligation well past the end of production.
Paper has not gone away
Two obligations survive the move to digital, and both are commonly misread as being broader or narrower than they are.
“However, at the request of the user at the time of the purchase, the manufacturer shall provide the instructions for use in paper format free of charge within one month.”
This is a right exercised at the point of purchase, not a standing right to demand paper at any moment over the following decade. It still has to be honoured, free, within a month.
“In the case of machinery or a related product intended for non-professional users or that can, under reasonably foreseeable conditions, be used by non-professional users, even if not intended for them, the manufacturer shall provide, in paper format, the safety information that is essential for putting the machinery or related product into service and for using it in a safe way.”
If a non-professional could plausibly end up operating the machine, essential safety information ships on paper regardless of what you host. Digital delivery does not make that go away.
And the language duty applies to all of it
“The instructions for use, the safety information and the information set out in Annex III shall be in a language which can be easily understood by users, as determined by the Member State concerned, and shall be clear, understandable and legible.”
The language is set by the member state the machine is placed on the market in, not by the manufacturer. Selling one model into eight countries means the instructions exist in the languages those eight countries determine, and a digital address has to lead each user to their own.
Everplate is where this documentation lives
Upload the manuals and declarations you already have and you get a QR code, plate artwork and a permanent address, in every language you sell into. Published revisions are never deleted, so what you served in 2027 is still provable in 2037.