The Digital
Operating Manual.

The EU Machinery Regulation sets the health and safety requirements for machinery and certain related products on the EU market. It replaces the existing Machinery Directive and takes account of, among other things, new technologies, safety-related software and digital operating manuals. (Regulation (EU) 2023/1230)

The main product requirements apply from 20 January 2027. The new rules apply to products first placed on the market or put into service from that date. Certain provisions apply earlier. Transitional arrangements apply to products placed on the market in conformity with the Directive before that date. (Articles 52 and 54)

The Regulation covers machinery as well as, for example, interchangeable equipment, safety components, lifting accessories and partly completed machinery. The applicable requirements depend on the type of product. Certain products are expressly excluded from its scope. (Articles 2 and 3)

Manufacturers must ensure that their products meet the applicable requirements. This includes risk assessments, technical documentation, the required conformity assessment procedure and the associated information. Importers and distributors also have obligations of their own. A technical service provider can provide support but does not automatically assume regulatory responsibility. (Articles 10 to 16)

Yes. The EU Machinery Regulation permits digital operating manuals under certain conditions. Manufacturers must indicate how they can be accessed. It must be possible to print, download and save the manual on an electronic device so that it remains available even if the machine breaks down. (Article 10(7))

The operating manual must remain accessible online throughout the expected lifetime of the machine or related product, and for at least ten years after it is placed on the market. Making it available for only ten years is therefore not sufficient where the expected lifetime is longer. (Article 10(7))

Yes, but only on request. If the user requests a printed operating manual at the time of purchase, the manufacturer must provide it free of charge within one month. For machinery and related products intended for non-professional users or which may, under reasonably foreseeable circumstances, be used by them, the essential safety information must also be supplied in paper form. (Article 10(7))

A QR code can provide direct access to the relevant digital operating manual. However, the Regulation does not explicitly require a QR code. What matters is that the manufacturer indicates how to access the manual on the machine or product, or, if that is not possible, on the packaging or in an accompanying document. A QR code alone does not fulfil all the requirements for the operating manual.

With the Digital Product Passport in mind, the QR code for the digital operating manual should be considered in a broader context. (Article 10(7))

The operating manual and safety information must be available in a language easily understood by users, as determined by the relevant Member State. The required language versions therefore depend on the markets in which the products are sold. Automatic language detection can make access easier but does not replace the required translations. (Article 10(7))

No. The digital operating manual serves, in particular, to enable the safe use of a machine. The Digital Product Passport provides product-related information in accordance with the applicable regulations. Both can technically be accessed via the same QR code or NFC chip on the product. However, the Machinery Regulation alone does not impose a general DPP obligation on all machinery. (Regulation (EU) 2023/1230; Regulation (EU) 2024/1781)

ECHO PRM GmbH helps companies make operating manuals available digitally at the product. Users can access and download the associated documents via a QR code. Language versions, service information, tutorials and a form for requesting a paper copy can also be integrated, for example.

The responsible company remains in charge of the accuracy and completeness of the documents.

ECHO PRM also offers a scalable platform that fulfils the Machinery Regulation's requirements for digital operating manuals and provides the perfect preparation for the Digital Product Passport under the Ecodesign Regulation and the European Product Act.

First, check which products are affected and which requirements apply to them. Then take stock of existing operating manuals, language versions, document versions and responsibilities. This provides a basis for arranging digital access, long-term availability and the process for paper requests. Contact us to arrange a no-obligation demo of the digital operating manual with ECHO PRM.