Digital instructions for use in the EU Machinery Regulation

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Digital instructions for use – nice to have

2023-08-21 Long more or less enthusiastically awaited regulation: the digital instructions for us in the EU Machinery Regulation 2023. Whether the digital form of product information will bring spectacular relief for you or is rather an annoying zeitgeist – you will probably only know in a few years.

Lifelong IT alliance

If you as a manufacturer provide your instructions for usein digital form, you definitely need to coddle your IT. During the expected lifetime of the machine or for at least ten years after placing it on the market, you must make the instructions for use accessible online. Importers must also ensure the instructions for use requirements in Article 10, and distributors must review them before placing the machine on the market. (cf. Art. 10 Para. 7, Art. 13, 15)

Note: The same requirements for manufacturers apply to digital EU declarations of conformity after the machine has been placed on the market or put into service (cf. Art. 8).

For smart access

Just doing it doesn’t work. If the pressure of the market is great, business players may not be able to avoid instructions for usein digital form. This requires some preparation. Digital instructions for useshould be conveniently accessible to users. If the access information does not fit on the machine itself, you must include it on its packaging or in an accompanying document.

Regardless of how a user gains access to the digital instructions for use , the user must be able to print, download, and store the instructions for useon an electronic device. The point is that a user can access the instructions for useat any time, even if they are embedded in the machine’s software, for example.

The EU declaration of conformity also makes in digital. Manufacturers can specify the Internet address or machine-readable code for accessing the EU declaration of conformity in the instructions for use . (cf. Art. 10)

Check for free paper version

If your instructions for useare digital, you can prevent paper hassles by asking for them. It may not occur to some users until long after they have purchased the machine that they want a paper version of the instructions for use . According to the Machinery Regulation, the user can expressly request a paper operating manual at the time of purchase, free of charge. Either way, you have one month from purchase to provide them.

Always paper form is the order of the day for machines for non-professional users, or even for machines that may be used by non-professional users.

It is interesting to note that the Machinery Regulation does not explicitly refer to instructions for useat this point – but rather to safety information that is essential for the safe commissioning of the machine and its safe use. According to the definition of instructions for use in Art. 3, this is only a part of the instructions for use- perhaps this opens up room for interpretation. (cf. Art. 10)

Saving paper even with non-digital instructions for use

This has now come to an end: The Machinery Directive 2006/42/EC requires instructions for use for every machine in the official language(s) of the member state where the machine is placed on the market or put into operation. If the attached instructions for use are a translation of the original instructions for use, the original instructions for us must also be included (cf. MRL Annex I).

The EU Machinery Regulation only specifies in Annex III: Instructions for use, safety information and information must be written in a language easily understood by users. The member state concerned determines which language this can be. Quite simple.

Interesting at second glance: Writing the instructions for use in a language that is easy to understand implies that, in any case, a competent person prepares the instructions for use in this language, mainly because the texts must be clear, understandable and readable. The need to attach the marked translation to the original instructions for use, quite a safeguard for companies, is eliminated. This can also save paper if you do not put the instructions for use online anyway. (cf. Art. 10)

State of the art in digital and analogue

With regard to the content of the instructions for use, the new Machinery Ordinance requires state-of-the-art technology for the first time – naturally for the digital and analog versions. This achievement is due to the measurements. As was already the case in the Machinery Directive, measured values must be specified in the instructions for use. For example, if applicable, for airborne sound emissions, radiation, emissions of hazardous substances. The values must actually be measured for the machine. Also possible: Determine the values on the basis of measurements on a technically comparable machine that is representative of the state of the art. Voilà. (cf. Annex III)

Analog and digital instructions for use in the EU Machinery Regulation 2023/1230

Whether digital or not, you are on the safe side with complete and clear instructions for use and the corresponding version in another language. Good preparation is always cost-saving. Ask our experts.

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In loose succession, we continue to report on the new Regulation (EU) 2023/1230 on machinery in our CE Plus blog. Ask our CE experts if you want to clarify details about the Machinery Regulation.