Is the Machinery Directive 2006/42/EC still valid? What changes on 20 January 2027

The directive is ending, the regulation is starting

On 20 January 2027, the Machinery Regulation (EU) 2023/1230 starts applying to machinery placed on the market from that date ^[1]. The old Machinery Directive 2006/42/EC stops applying to new machinery on the same day, though it continues to govern machinery already on the market ^[2].

The change of legal instrument is deliberate. A directive is a framework that each member state turns into national law. A regulation applies directly, without transposition, across all EU member states. For manufacturers outside the EU, the practical difference is smaller than it sounds: either way, if you want to place machinery on the EU market, you follow the EU rules. The difference is that from 20 January 2027, those rules are the same text everywhere.

Think of it like a product recall notice. A directive tells each country to write its own version of the notice. A regulation is one notice, posted in every language, with the same requirements for everyone.

What the regulation adds

The new regulation keeps most of the safety framework from the directive and adds requirements shaped by software and machine learning ^[1].

Safety-relevant software changes must be logged in a way that allows them to be traced for at least five years after the machinery is placed on the market. The regulation also requires manufacturers to protect machinery against corruption ^[1].

For machinery with self-learning behaviour, there are specific obligations: the manufacturer must describe the learning logic, the data used for training and the performance criteria, and take measures to eliminate or reduce risks from behaviour that could become dangerous after the machinery is placed on the market ^[1].

These are new words in machinery law, aimed squarely at systems where software is not just executing fixed instructions but adapting over time.

What this means for you

If you manufacture machinery, ask yourself:

• Which of our products will be placed on the market from 20 January 2027 onwards?
• Do any of them include safety-relevant software that can be updated or modified?
• Can we show, five years from now, which version of the software was running and what changes were made?
• For machinery with learning behaviour, have we documented the learning logic and the measures we have taken to prevent dangerous outcomes?

The regulation is addressed to manufacturers, but these questions apply equally to anyone in the supply chain who modifies software or places machinery on the market under their own name.

Logging changes you can trace

Here, the thing to seal is each safety-relevant software change as it is deployed: the release version, a fingerprint of the build, the change notes and the date. Sealing takes a fingerprint, not the software itself, so the code never leaves your systems.

Five years later, when a market surveillance authority or a notified body asks which version was running on a particular machine, you have a record they can check. Anyone you share it with can verify that the record is exactly what you created at the time, unchanged.

WitniumChain does that through a REST API, an SDK or an MCP server. The content stays with you. What gets sealed is a fingerprint. If the record changes, even by one character, the fingerprint no longer matches. The first 2,000 witnesses a month are free. Documentation here.

A digital witness doesn't show that the software was safe or that the change was properly tested. It shows that the record of what was deployed, and when, hasn't been quietly rewritten since.

How it would work

1. At deployment, your system sends a fingerprint of the release record to WitniumChain and gets a witness ID back.
2. The witness ID and the original record are kept together.
3. When asked, you share the record and the witness ID. The recipient calculates the fingerprint again and checks it matches the sealed one.

The question behind the question

The question in the title is really two questions. The first is about timing: does the directive still apply? The answer is yes, for machinery placed on the market before 20 January 2027, and no, for machinery placed on the market from that date ^[2].

The second question is about compliance: if I have been following the directive, do I now have to follow something completely different? The answer is no, if your machinery doesn't include software that matters to safety. And partly, if it does.

The regulation keeps the essential health and safety requirements. What it adds are rules for software traceability and learning systems. If your machinery includes neither, the change is largely administrative. If it includes either, the new requirements are real, and the clock is running.

What to watch

The regulation itself is in force. The question now is how notified bodies and market surveillance authorities interpret the logging and traceability requirements in practice, and what they accept as adequate documentation of self-learning behaviour.

For manufacturers placing machinery on the market from 20 January 2027, the safe approach is to assume the new rules apply in full and to document software changes and learning logic now, not when someone asks for them.

Sources

1. Regulation (EU) 2023/1230 of the European Parliament and of the Council on machinery and repealing Directive 2006/42/EC, EUR-Lex, 29 June 2023, https://eur-lex.europa.eu/eli/reg/2023/1230/oj
2. Is the Machinery Directive 2006/42/EC Still Valid? What Manufacturers Need to Know, GetReady Compliance, accessed January 2027, https://getreadycompliance.eu/machinery-directive-2006-42-ec-still-valid/
3. Machinery Regulation (EU) 2023/1230, European Commission Single Market Transparency Directive, accessed January 2027, https://single-market-economy.ec.europa.eu/sectors/machinery_en