From the Machinery Directive to the Regulation: the dates, and what happens to machines already sold

Start with the date, because a surprising share of the summaries circulating online get it wrong, including ones published by people who sell compliance services. The regulation states it in its final article.

20 January 2027. The date is worth a moment, because the Official Journal first published 14 January, and a corrigendum of 4 July 2023 (OJ L 169, page 35) corrected it to 20 January, along with thirteen other dates. EUR-Lex does not rewrite a published page when a corrigendum lands, so the uncorrected text is still the one most searches return, and a summary quoting it will tell you 14 January in complete good faith. If the source you are relying on says 14 January 2027, it has not read the corrigendum.

The Directive goes on the same day

There is no overlap period in which a manufacturer chooses between the two texts. Article 51(2) also says references to the repealed Directive are to be read as references to the Regulation, following the correlation table in Annex XII, which is the practical tool for anyone whose internal procedures, contracts or supplier specifications cite 2006/42/EC by article number.

Machines placed on the market before that day

This is the grandfathering rule, and it is narrower than people hope. It protects machines that were placed on the market in conformity with the Directive before 20 January 2027: those can go on being made available afterwards, and member states may not impede that. It does not convert a stock of unsold machines into compliant ones, because "placed on the market" is a per unit event about the first making available in the Union, not a statement about a model or a production run.

So the question for any individual machine is the date that unit was first made available in the Union, and the answer decides which text it is judged against for the rest of its life. A model in production either side of the date will have units under both regimes, with different documentation duties, at the same time.

Certificates you already hold

EC type-examination certificates and approval decisions issued under Article 12 of the Directive stay valid until they expire. They do not become permanent, and they do not extend to units placed on the market after the certificate lapses.

The clock that does not stop in 2027

The ten year online availability duty is counted per unit from the placing on the market of that unit, so it is still running long after the transition stops being news. A machine placed on the market in February 2027 carries its instructions online into 2037 at the earliest, and longer if its expected lifetime is longer. A model produced from 2027 to 2035 carries obligations into the 2040s, well past the end of its production. Whatever you choose to host documentation on, the choice has to survive a decade of your own staff turnover.

What is already in force

Not all of the regulation waited for 2027. Article 54 brings several parts forward: the notified body provisions in Articles 26 to 42 from 20 January 2024, the penalties provision in Article 50(1) from 20 October 2026, and Article 6(7) together with Articles 48 and 52 from 19 July 2023. That last one is why the transitional rule quoted above has been operative since 2023 rather than starting with everything else.

What this guide does not cover

What changes in substance, rather than in dates, is the subject of a separate guide. The correlation table in Annex XII is the authoritative mapping from old article numbers to new ones, and it is long. Nothing here is legal advice, and the one thing worth taking from this page is the habit of checking a date against the Official Journal rather than against a summary.