Regulation (EU) 2023/1230 on machinery entered into force on 19 July 2023. Its application date — the date from which manufacturers must comply — is 20 January 2027. After that date, any Declaration of Conformity issued in the format required by Directive 2006/42/EC is non-compliant.
This article explains what changes for manufacturers who issue their own Declarations of Conformity.
What is a Declaration of Conformity?
A Declaration of Conformity (DoC) is a legal document in which the manufacturer declares that a product meets the requirements of the applicable EU legislation. For machinery placed on the EU market, the DoC is one of the core documents that must accompany or be accessible with the product.
Under Directive 2006/42/EC, the DoC format was defined in Annex II. Under Regulation 2023/1230, the format is defined in Annex V. These are not the same format.
Key Changes in Annex V
1. Unique declaration number
Regulation 2023/1230 requires each Declaration of Conformity to bear a unique declaration number. This was not required under the Directive. The number must allow the document to be traced back to a specific machine model and version.
2. Colour photograph of the machine
Annex V now requires the inclusion of a colour photograph that clearly identifies the machinery. This is a new requirement with no equivalent in Directive 2006/42/EC.
3. Explicit version references for harmonised standards
Where the manufacturer relies on harmonised standards to demonstrate conformity, the DoC must reference the version of each standard applied. A reference to EN ISO 12100 is insufficient — the document must specify EN ISO 12100:2010 (or whichever version was applied). This prevents ambiguity during audits and market surveillance inspections.
4. Digital DoC is now permitted
Under Article 10(8), the Declaration of Conformity may be provided in digital form. If it is, the manufacturer must ensure the document remains publicly accessible for at least 10 years after the machine is placed on the market. The machine must also bear a link or QR code giving direct access to the digital DoC.
Note: the paper DoC remains valid. Digital format is permitted, not mandated.
5. 10-year retention obligation formalised
The Regulation formalises the requirement to retain both the DoC and the technical file for at least 10 years from the date the machinery is placed on the market. This was already common practice under the Directive, but is now an explicit statutory obligation.
What This Means for Manufacturers
If you currently use a Word document or Excel template to generate your Declarations of Conformity, your current process will not produce a compliant document after January 20, 2027.
Specifically:
- Your template does not have a unique declaration number field
- Your template does not include a colour photograph
- Your template may reference standards without version numbers
- Your filing system may not guarantee 10-year retention with reliable retrieval
None of these are trivial additions to a Word template. They require a change in process.
What You Should Do Now
The January 2027 deadline may seem distant, but the practical timeline is shorter than it appears. Updating your DoC process requires:
- Reviewing your current DoC template against Annex V of Regulation 2023/1230
- Establishing a numbering system for unique declaration numbers
- Updating your process to include a machine photograph in each DoC
- Verifying all harmonised standard references include version numbers
- Deciding whether to issue paper or digital DoCs — and setting up the corresponding infrastructure
Starting this process in 2026 gives you time to test the new format, validate it against your product range, and train the team responsible for CE marking before the deadline.
Summary
The transition from Directive 2006/42/EC to Regulation 2023/1230 changes the required format for Declarations of Conformity. The new Annex V format introduces mandatory fields (unique number, photograph, versioned standard references) and formalises the digital DoC option. Manufacturers who rely on manual templates will need to update their process before January 20, 2027.
The obligation is not optional, and there is no grace period for DoC format transition in the published Regulation text.