New EU rules for machinery and robots: what changes in 2027
From 20 January 2027, Regulation (EU) 2023/1230 on machinery will apply. It will replace the existing Machinery Directive and will be directly applicable in the Member States. The new framework is intended to better respond to the development of autonomous machines, collaborative robots, communications and safety software.
The material is for information purposes only and does not constitute legal advice.
Why were the regulations changed?
Machines are increasingly changing their behavior through updates, using network connections, and collaborating with humans. The classic division into mechanics and software is becoming insufficient. The new regulation clarifies, among other things, issues related to autonomy, security functions using machine learning and significant product modifications.
Whose responsibilities apply?
The majority of responsibilities rest with the manufacturer, but importers and distributors play an important role. Before introducing a product to the market, compliance with the requirements, technical documentation, appropriate conformity assessment, declaration and CE marking must be ensured.
The importer should ensure that the manufacturer has carried out the required actions and that the product has documents and instructions that are understandable to the user. Distributor cannot ignore apparent nonconformities.
Software becomes part of security
The update may improve the robot's function, but may also change its speed, trajectory, or response to humans. In systems where software performs a security function, its changes must be controlled. The manufacturer should take into account the risk of manipulation and loss of data integrity.
Significant modification
A company purchasing a robot often wants to add its own gripper, tool, or code. If the modification changes the intended use or creates a new risk, the entity making the change may be treated as a manufacturer. This is important for integrators and companies building their own workstations.
Digital Instructions and Documentation
The regulation allows instructions to be provided in digital form under certain conditions, but the user must still have easy access to the information needed for safe operation. Documentation cannot be hidden behind an account that stops working when support ends.
What should the company do before 2027?
- inventory of robots and machines planned for import,
- establish the roles of manufacturer, importer, distributor and integrator,
- check documentation and manual language,
- evaluate your own modifications and software,
- prepare update and incident handling procedures,
- require clear functional safety information from supplier.
What does this change mean for the home user?
The customer should more easily identify the responsible party and receive information about a safe installation. However, you should still not assume that any machine ordered from outside the EU automatically meets the requirements just because it has the CE mark printed on it.
Robots with AI capabilities
The Machinery Regulation and the AI Act may apply in parallel, depending on the product and function. A company should not attempt to independently classify a complex system based on a vendor's advertising. It is worth requiring the indication of applicable acts and responsibility for compliance in the contract.
Used and Rebuilt Machines
The new regulations also apply to equipment that has been significantly modified. Adding autonomous control to an older machine can create new risks. Saving on a purchase does not exempt you from re-analysis.
Shopping in 2026
Devices placed on the market before the date of application of the new regulations may be subject to the previous framework, but will last for many years. The buyer should ask whether the structure and documentation have already been prepared for the new regulation, especially in the case of a project delivered at the turn of 2026 and 2027.
List of questions for the supplier
- Who is the legal manufacturer of the complete system?
- Which software version was evaluated?
- How are later updates treated?
- Are our modifications covered by documentation?
- How long is technical documentation stored?
RoboMorrow Evaluation
New regulations will not stop the development of robotics, but will increase the importance of documentation, secure updates and responsible integration. This may be an advantage for reliable producers, and a barrier for random importers.