If you import machinery into the EU, mark your calendar: the Machinery Regulation (EU) 2023/1230 applies fully from 20 January 2027, replacing the long-standing Machinery Directive 2006/42/EC. The transition window is now — and the obligations sit with importers as much as with manufacturers.
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Ask About DocumentationWhat's changing
The Regulation carries forward the core CE-marking framework for machinery, but updates several things importers will feel directly:
- Technical documentation — updated requirements on what must exist and be kept available;
- Nameplate and instructions — new/updated content requirements for nameplates and instruction handbooks;
- Digital documentation — clearer rules for electronic formats;
- High-risk machinery (Annex I) — the list of machinery requiring notified-body involvement has been reshaped and expanded in areas relevant to many sectors.
For most standard industrial machines the conformity route (self-assessment with harmonised standards) remains, but the paperwork and marking requirements around it have been tightened.
The part importers keep getting wrong
Importer obligations are independent of the supplier's. Under the EU framework, the importer — the entity placing the machinery on the EU market — must verify, before placing it on the market, that:
- the Declaration of Conformity has actually been drawn up (and corresponds to the machine);
- technical documentation exists and can be provided on request;
- the machine carries the required marking and nameplate information;
- accompanying instructions are present and appropriate.
"The Chinese supplier said it's CE" is not verification — it's hearsay. If the DoC turns out to be false or the technical file doesn't exist, the legal exposure lands on the importer. This was true under the Directive; the Regulation sharpens it.
A practical preparation timeline (from 2026)
- Now → mid-2026: inventory your imported machinery against the new Regulation; request technical files and DoCs from suppliers and read them (do the declared standards match the actual machine?); identify any Annex I machines in your portfolio.
- Mid-2026 → late 2026: for new purchase orders, write the documentation requirements into contracts — DoC, technical file, nameplate content, instructions language — and make pre-shipment verification of documents a payment milestone.
- Before 20 Jan 2027: confirm that every machine placed on the market after that date complies with the Regulation — including stock ordered earlier but placed late.
What to demand from a Chinese supplier
A supplier taking the EU seriously should provide, without drama: a DoC that names actual standards, a technical file (or at least its index + risk assessment), correct nameplates, and instructions in the destination language. Suppliers who wave the topic away are telling you who carries the compliance risk — you.
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