From 20 January 2027, machinery placed on the EU market must be supported by a Declaration of Conformity (DoC) that references Machinery Regulation (EU) 2023/1230, not the Machinery Directive (2006/42/EC). There is no grace period.
It's tempting to treat this as a paperwork job: swap the legislative reference, update the date, re-sign. That's the fastest way to end up with a declaration you can't defend. A DoC is a legal statement that your machine meets every applicable requirement, so if the evidence behind it hasn't changed, the declaration can't honestly change either.
At IES, we've supported CE and UKCA compliance for high-technology equipment since 1991. This guide walks through the seven steps we'd follow to bring a Declaration of Conformity in line with the Regulation.
● The DoC must reference Machinery Regulation (EU) 2023/1230 for any machine placed on the EU market on or after 20 January 2027.
● Machines already placed on the market before that date stay under the Directive, so their existing declarations remain valid and don't need reissuing.
● A new declaration is only as strong as the risk assessment, technical file and conformity assessment behind it.
● The Regulation introduces a defined content template for the DoC, and allows it to be provided digitally under set conditions.
● Complex machinery can take a long time to reassess, so it's worth checking your paperwork against the requirements now rather than later.
The DoC is the manufacturer's formal declaration that a machine meets the essential health and safety requirements and has been through the correct conformity assessment. It sits alongside the CE marking, and it is one of the first things a customer, importer, customs officer or market surveillance authority will ask to see.
Under the Regulation, manufacturers must keep the technical documentation and the DoC available to market surveillance authorities for at least 10 years after the machine is placed on the market or put into service.
Not every machine in your portfolio needs a new DoC on 20 January 2027. What decides it is when each individual unit is placed on the market or put into service.
● Placed on the EU market before 20 January 2027: stays under the Directive. No automatic re-certification.
● Placed on the market on or after 20 January 2027: needs a DoC under the Regulation.
● Substantially modified machines: whoever carries out the modification can become the manufacturer, and must make a new declaration. We cover this in Does the Machinery Regulation Apply to Your Equipment?
Build a simple register: one row per product configuration, with its destination market and expected placing date. That register drives everything else.
The Regulation restructures the old Annex IV list into a new Annex I, split into two parts. In broad terms, Part A covers the highest-risk machinery, where third-party assessment is required, and Part B covers high-risk machinery where self-certification may be possible if harmonised standards are followed. Two new categories cover safety components and machinery using self-evolving, machine-learning behaviour.
Don't assume your previous conformity assessment route still holds. A machine that followed one route under the Directive may need a different one now. The route you take determines what evidence you need and whether a notified body must be involved, so confirm it before you touch the declaration.
This is the step most teams underestimate. The Regulation adds new essential health and safety requirements, and your existing risk assessment may not cover them. In particular:
● Cybersecurity and safety functions. Control systems must be protected against corruption, including reasonably foreseeable malicious attempts from third parties that could lead to a hazardous situation.
● Software and connected functions. Safety-related software and remote updates need to be considered as part of the machine's safety case.
● AI and self-evolving behaviour. Where machine learning is used in safety functions, additional requirements apply.
● Digital safety components. These now sit within the scope of the assessment.
Risk assessments now have to account for cyber risk as well as mechanical and electrical hazards. If yours predates this, it needs a formal review, not a footnote.
The technical documentation is the evidence behind the declaration. Review it against the Regulation's annexes, in particular Annex III (essential health and safety requirements) and Annex IV (technical documentation). The old Annex I requirements are now Annex III, so cross-references in your existing file will be out of date.
Check that it includes:
● Updated risk assessment
● Test reports covering the requirements that apply
● Details of the harmonised standards applied, including the year and version
● Where relevant, the source code or programming logic that regulators may request to check compliance
Where the updated risk assessment shows a gap, or where a requirement is new, you'll need to test and document against it. For high-technology equipment, that usually means a combination of machinery safety, electrical safety (LVD) and electromagnetic compatibility (EMC) assessment, with on-site testing where the equipment can't be moved.
If a test fails, the priority is a remedial route, not another round of paperwork. Choose a partner who can advise on modifications as well as report the failure.
The Regulation now sets out the content of the DoC in Annex V, with a defined template. Points to check when rebuilding yours:
● The declaration references Machinery Regulation (EU) 2023/1230, not Directive 2006/42/EC
● A unique identifying number for the declaration
● Clear identification of the machine, and per the template, a photograph that identifies it
● Harmonised standards listed with their year and version, and any partial application made explicit
● For substantially modified machines, identification of the original machine, including brand and type
● The signatory's details and, where applicable, details of any notified body involved
Always check your final wording against the Regulation itself (Annex V), as the template controls what must appear.
The Regulation allows the DoC to be provided digitally. If you take that route, the instructions for use must give the internet address or a machine-readable code where it can be accessed. A digital DoC must stay accessible online for the expected lifetime of the machine, and in any event for at least 10 years after placing on the market or putting into service.
That has practical consequences: a stable URL, version control, and a clear owner in your business for keeping it live. Where the machine is sold into more than one Member State, also check the language requirements set by each country.
The Regulation applies directly in Northern Ireland from 20 January 2027. In Great Britain, the UK Government has confirmed it will continue to recognise CE marking, and that machinery CE-marked to the new Regulation can still be placed on the GB market without separate UKCA certification.
If you supply both the UK and the EU, one well-built technical file and declaration can carry a lot of weight for both.
If the DoC isn't ready, the machine can't lawfully be placed on the EU market. That means delayed shipments, delayed commissioning and delayed revenue, plus exposure to market surveillance action. Penalties are set by individual Member States.
The deadline is fixed, and industry guidance suggests that compliance programmes for complex machinery can take 12 to 24 months. For many manufacturers, that means the realistic question isn't "how do we do everything?" but "what do we prioritise in the time left?" Checking your current declarations, technical files and risk assessments against the requirements is the fastest way to answer it.
We've turned these seven steps into a short, practical checklist you can run against any machine in your portfolio. It shows you at a glance where your declaration, technical file and risk assessment need work before 20 January 2027.
Once you've downloaded it, our team will follow up to offer a free 20-minute consultation and talk through your specific results.
Book your free 20 minute consultation here.
See our full guide to the Machinery Regulation changes for the wider picture of what's changed and who is affected. Machinery Regulation (EU) 2023/1230: A Practical Guide For Manufacturers.
With over 35 years of hands-on engineering experience, IES tests, documents and certifies complex equipment start to finish, so you don't have to coordinate multiple suppliers.
This is a general guide, not legal advice. The right approach for your equipment depends on its category, history and destination market.