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EU Machinery Regulation 2027: are your machines ready?

Existing machines may keep running. Anyone who builds, imports or substantially modifies a machine from the deadline onwards has new obligations. The Machinery Regulation Check shows in half a day on site where your machine stands. From €890 net per machine, on site in Burgenland, Vienna, Lower Austria and throughout Austria.

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Who the regulation affects

  • Manufacturers

    Builders of machines and fixtures, including one-offs and small series.

  • Operators who modify machines

    Anyone who substantially modifies a machine is considered its manufacturer.

  • Importers

    Anyone who brings machines from third countries into the EU must ensure that the manufacturer has fulfilled its obligations.

What changes

  1. Substantial modification is defined for the first time

    A modification that the manufacturer did not foresee can create a new hazard or increase a risk. It only becomes substantial if this requires new protective devices and a changed safety control system. The same applies to additional measures for stability or mechanical strength.

    Spotting a substantial modification

  2. Cybersecurity

    Control systems must withstand foreseeable malicious access. Interventions in safety-relevant software must be traceable.

  3. Life cycle

    Versions of safety software installed later are logged, for up to five years after uploading. Self-learning control systems must not change their settings in a way that creates hazards either.

  4. Digital instructions

    The instructions for use may be supplied digitally. If the customer asks for paper at the time of purchase, they receive it free of charge within one month.

  5. New high-risk list

    Annex I reorganises the categories. For Part A, for example safety components with self-evolving behaviour, a notified body is mandatory.

The Machinery Regulation Check

Occasion
A modification is planned – or an existing machine is to be checked, for example after findings by the labour inspectorate.
Scope
Guards and protective devices, safety functions, control system and remote access of one machine, plus instructions, declaration of conformity and previous modifications.
Duration
15-minute call beforehand, then half a day on site.
Result
Report within 5 working days: traffic light rating per item, list of measures by priority and an assessment of whether modifications may be substantial modifications.
Price
from €890 net per machine plus VAT, offer for businesses. If your machine needs more than half a day, I tell you before any extra work is done. If an order follows, the check is credited.
Insured
Business liability insurance that also covers design errors.

What the report looks like

Fictitious example on a robotic palletising cell: every test item with a traffic light rating and test method, plus a layout plan with the findings. The list of measures names deadlines and responsibilities. This is the report you receive after 5 working days.

  • 5 green
  • 5 yellow
  • 1 red
  • 2 notes
Example report as PDF (in German, 6 pages, 89 KB)

How the check works

  1. 15-minute call

    You describe the machine and modifications and send photos and the rating plate. That way I can prepare the visit.

  2. Half a day on site

    I check guards and protective devices, safety functions and existing documents.

  3. Report within 5 working days

    With a traffic light rating per item and a list of measures by priority.

Frequently asked questions

Does this also apply to old machines?

Not retroactively. Machines placed on the market under the Machinery Directive before 20 January 2027 may continue to be made available and operated. For operation in Austria, the Employee Protection Act (ASchG) and the Work Equipment Ordinance (AM-VO) continue to apply. If such a machine is substantially modified afterwards, the manufacturer obligations of the new regulation apply to it.

When does a modification become a substantial modification?

What matters is whether the modification creates a new hazard or increases a risk. It is a substantial modification if this makes new protective devices necessary that require a change to the safety control system. The same applies to additional measures for stability or mechanical strength. A further condition is that the manufacturer had not foreseen the change.

In detail: spotting a substantial modification

What does the check cost?

From €890 net per machine plus VAT, for half a day on site and the report. If your machine needs more time, I tell you before any extra work is done. If an order follows, the check is credited.

What do I need to prepare for the visit?

Access to the machine and, where available, instructions, declaration of conformity, circuit diagrams and a list of modifications. Missing documents are no obstacle – the report shows that too.

Does the check replace a risk assessment or legal advice?

No. The check is a technical survey with a list of measures. On request I prepare the risk assessment to EN ISO 12100 as a separate order. Please clarify legal questions with the Austrian Economic Chamber (WKO) or a lawyer.

Request the check

Briefly tell me which machine it is about. I will get back to you within one working day to arrange the 15-minute call.

Prefer to call? +43 660 800 7100

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Source: Regulation (EU) 2023/1230, OJ L 165 of 29.6.2023, corrected by OJ L 169 of 4.7.2023