The ten-year availability requirement, and its three different versions
Instructions, declarations of conformity and declarations of incorporation each have their own retention rule under Regulation (EU) 2023/1230, and the clock runs per machine rather than per document.
The ten-year figure appears in three separate places in Regulation (EU) 2023/1230, and the three are not the same rule. Getting them confused is how an archive ends up either over-retained or, worse, cleared too early.
Instructions for use
“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.”
Two conditions joined by "and". Expected lifetime is the primary measure and ten years is the floor beneath it. For machinery with a twenty or thirty year service life, the longer figure governs.
Declaration of conformity
“Digital EU declarations of conformity shall be made accessible online for the expected lifetime of the machinery or related product and in any event for at least 10 years after the placing on the market or the putting into service of the machinery or related product.”
Same structure as the instructions, with one addition worth noticing: putting into service is named alongside placing on the market, so for machinery that is built and commissioned rather than sold off a shelf, the later date can be what starts the clock.
Declaration of incorporation
“Digital EU declarations of incorporation shall be made accessible online for at least 10 years after the placing on the market of the partly completed machinery.”
Here the expected-lifetime clause is absent. For partly completed machinery the duty is the flat ten years. This is the one that most often gets written into a policy as if it matched the other two.
The clock is per machine, not per document
This is the detail that decides how an archive has to be built. A model produced from 2027 to 2035 does not have one deadline. The last unit shipped in 2035 carries its own ten years, which runs to 2045, and if the expected lifetime of that machine is longer then so is the duty.
In practice this means retention cannot be driven by publication date. It has to be driven by when production of that version ended, at the earliest, and for most manufacturers the sensible policy is simply never to remove anything. Storage is cheap. Being unable to produce a document for a machine still in service is not.
What availability actually has to mean
"Accessible online" is doing quiet work in all three articles. A URL that resolves today but breaks during a website migration in 2031 was not available for ten years, it was available for four. The practical test is whether the address printed on a machine in 2027 still resolves, unchanged, after every rebrand, CMS change and hosting decision in between.
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.