Guide · Art. 10(7) · updated
Digital instructions for machinery: what Article 10(7) of Regulation 2023/1230 requires
What Article 10(7) of Regulation (EU) 2023/1230 allows, the conditions you must meet to supply your machinery manuals digitally, and when paper is still required. Every point links to the official text.
Short answer
Yes, a machinery manual can be digital only. From 20 January 2027, Article 10(7) of Regulation (EU) 2023/1230 allows the instructions for use to be supplied in digital format. In return, the manufacturer must mark on the machine how to access them, provide them in a format that can be downloaded and printed, keep them online for the expected lifetime and at least ten years, and supply them on paper free of charge if the user asks at the time of purchase. If non-professionals may use the machine, the essential safety information must also be on paper.
What Article 10(7) allows
Article 10(7) keeps the long-standing obligation: the machinery must be accompanied by the instructions for use and the Annex III information, and those instructions must clearly describe the product model they correspond to. What is new compared with Directive 2006/42/EC fits in one sentence: ‘The instructions may be provided in a digital format.’
It is an option, not an obligation: you can keep supplying a printed manual. And it does not lower the bar on content: a digital manual must contain the same as a paper one (Annex III, section 1.7.4.2).
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 three conditions for supplying instructions digitally
If you choose the digital format, Article 10(7) requires the manufacturer to meet three conditions, points (a) to (c):
Mark on the machine how to access them
On the machinery itself and, only where that is not possible, on the packaging or in an accompanying document. The Regulation does not prescribe a specific means: the usual approach is a QR code with a short web address on the rating plate.
Official text
(a) 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;
Printable, downloadable and savable
Users must be able to print them, download them and save them on a device so they can access them at all times, in particular during a breakdown. This also applies to instructions embedded in the machine’s software. A website that can only be read online is not enough.
Official text
(b) 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;
Online for the lifetime and at least ten years
They must be accessible during the expected lifetime of the machinery and for at least ten years after it is placed on the market. Both periods apply, so in practice the longer one governs: if the expected lifetime is 20 years, it is 20.
Official text
(c) 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.
Is your manual ready to go digital? The free check reviews these conditions and the rest of the checklist (109 requirements), down to the page.
Check my manual for freeWhen paper is still required
Going digital does not remove paper altogether. Article 10(7) provides for two cases:
Art. 10(7), third subparagraphNew
Free paper copy if the user asks at the time of purchase
If the user requests it at the time of purchase, the manufacturer must provide the instructions on paper, free of charge, within one month. It pays to have the procedure ready before you sell: where the request is made, who prints and who sends.
Official text
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.
Art. 10(7), fourth subparagraphNew
Essential safety information on paper if non-professionals may use it
If the machinery is intended for non-professional users, or can be used by them under reasonably foreseeable conditions even if not intended for them, the safety information essential for putting it into service and using it safely must be supplied on paper. The rest of the instructions can still be digital.
Official text
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.
| Document | Digital only? | Condition | Basis |
|---|---|---|---|
| Instructions for use (Annex III content) | Digital only? Yes | Access marked on the machine; downloadable and printable; online for the lifetime and at least 10 years; free paper copy if requested at purchase. | Art. 10(7) |
| Essential safety information (machinery non-professionals may use) | Digital only? No | On paper, for putting into service and safe use. | Art. 10(7), fourth subparagraph |
| EU declaration of conformity | Digital only? Yes | Internet address or machine-readable code given in the instructions; online for the lifetime and at least 10 years. | Art. 10(8) and 1.7.4.2(1)(c) |
The EU declaration of conformity can be digital too
Article 10(8) applies the same logic to the EU declaration of conformity, and Annex III carries it over to the content of the manual:
Art. 10(8)Amended
Declaration via a link or code
The machinery may be accompanied by the EU declaration of conformity or, alternatively, the instructions may give the internet address or machine-readable code where it can be accessed. The digital version must stay online for the expected lifetime and in any event for at least ten years after placing on the market or putting into service.
Official text
Manufacturers shall ensure that the machinery or related product is accompanied by the EU declaration of conformity set out in Annex V, Part A or, alternatively, manufacturers shall provide the internet address or machine-readable code where that EU declaration of conformity can be accessed in the instructions for use and the information set out in Annex III. 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.
1.7.4.2(1)(c)Amended
What the manual must say
The contents of the instructions include the EU declaration of conformity or the internet address or code where it can be accessed. The term ‘EC declaration’ is gone.
Official text
the EU declaration of conformity, or the internet address or machine readable code, where the EU declaration of conformity can be accessed, in accordance with Article 10(8);
Which language digital instructions must be in
Art. 10(7), last subparagraphUnchanged
A language users can easily understand
The instructions for use, the safety information and the Annex III information must be in a language easily understood by users, as determined by each Member State, and must be clear, understandable and legible. Going digital does not change this rule.
Official text
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.
1.7.4Amended
Exception: maintenance by specialised personnel
Maintenance instructions intended for specialised personnel mandated by the manufacturer or its authorised representative may be supplied in only one official EU language that those personnel understand.
Official text
In addition to the obligations set out in Article 10(7), instructions for use shall be drawn up as set out below. By way of exception to Article 10(7), the maintenance instructions intended for use by specialised personnel mandated by the manufacturer or its authorised representative may be supplied in only one official language of the Union which the specialised personnel understand.
Checklist: what you need to switch to digital instructions
Decide model by model
Check whether each machine could end up in the hands of a non-professional user. If so, prepare the essential safety sheet on paper.
A stable web address and its QR code on the machine
On the rating plate or a label. Packaging or an accompanying document only if it will not fit on the machine.
A downloadable, printable PDF
For every version and every language, including instructions embedded in the software.
Hosting for the whole lifetime and at least ten years
Not dependent on a redesign of the corporate website or on a particular provider.
A paper-copy procedure
A channel to request it at purchase and someone responsible for printing it and sending it free of charge within a month.
The languages of each destination country
Every language version, with the same access, download and availability conditions.
EU declaration of conformity
On paper, or with its link or QR code given in the instructions and kept online for the same period.
The model, clearly identified
Each manual describes the model it corresponds to. Keep earlier versions so every machine sold still has its own.
Common mistakes when going digital
Putting the access details only inside the manual
If the address of the instructions only appears in the manual itself, users cannot reach them. Point (a) requires it to be marked on the machinery; packaging or an accompanying document only where that is not possible.
A website that can only be read online
Without download, printing and saving to a device, point (b) is not met. During a breakdown, at the machine and with no signal, users must be able to open their saved copy.
Linking to a page on the corporate website
A redesign, a new domain or a change of provider breaks the QR link and leaves the machine without instructions long before the point (c) period ends.
Forgetting non-professional users
If a non-professional can use the machinery under reasonably foreseeable conditions, even if it is not intended for them, the essential safety information must be on paper.
No plan for the paper copy
The request comes at the time of purchase and you have one month to provide it free of charge. Without a procedure, it is easy to miss.
A QR code that always opens the latest version
The user of an older machine may land on instructions that no longer describe their model. Keep every version and state which model or serial number it applies to.
How the Manualia Instructions portal handles it
If you would rather not build and maintain all this yourself, the Instructions portal publishes your digital instructions with QR access:
- One page per model, with its QR code and all its versions and languages.
- PDF download of every version, to save and print.
- Paper-copy requests: they reach you by email and you send the copy.
- On the Pro plan, a QR code per serial number: each unit opens the version of the manual it was sold with.
Basic
€79 / month + VAT
Up to 10 models, a QR code per model, version history and PDF download.
Pro
€199 / month + VAT
Unlimited models, a QR code per serial number and view statistics.
No minimum term. On the point (c) period: the portal keeps your instructions online while your subscription is active. And whenever you want, we hand over a complete copy (HTML and PDF) to host on your own domain, so you can meet the lifetime and at-least-ten-years obligation even if you leave the portal.
Frequently asked questions
Can machinery instructions be supplied in digital format only?
Yes. Article 10(7) of Regulation (EU) 2023/1230, which applies from 20 January 2027, allows the instructions for use to be supplied in digital format. The manufacturer must mark on the machinery how to access them, provide them in a format that can be printed, downloaded and saved, and keep them online for the expected lifetime and at least ten years.
Is a QR code on the machine mandatory?
Not literally. Article 10(7)(a) requires the manufacturer to mark on the machinery (or, where that is not possible, on the packaging or in an accompanying document) how to access the digital instructions. A QR code with a short web address on the rating plate is the most common way to do this.
How long must digital instructions remain available online?
For the expected lifetime of the machinery and for at least ten years after it is placed on the market (Article 10(7)(c)). Both periods apply, so in practice the longer one governs.
What happens if a customer asks for a paper manual?
If the user requests it at the time of purchase, the manufacturer must provide the instructions for use on paper, free of charge, within one month.
Does some machinery always need paper instructions?
Partly, yes. If the machinery is intended for non-professional users, or can be used by them under reasonably foreseeable conditions, the safety information essential for putting it into service and using it safely must be supplied on paper. The rest of the instructions can be digital.
Can the EU declaration of conformity be digital too?
Yes. Article 10(8) allows the instructions to give the internet address or machine-readable code where the EU declaration of conformity can be accessed. The digital declaration must stay online for the expected lifetime and at least ten years.
Do instructions built into the machine’s screen or software count?
Only if they can also be printed, downloaded and saved on an electronic device. Article 10(7)(b) also applies where the instructions for use are embedded in the machine’s software.
Official sources
- Regulation (EU) 2023/1230, OJ L 165, 29.6.2023 (EUR-Lex)
- All versions and consolidated texts on EUR-Lex
- Guide to Machinery Regulation 2023/1230: what changes and what to do before 20 January 2027
This guide is for information only and does not constitute legal advice. The official texts are taken from Regulation (EU) 2023/1230; the explanations are our own.