Digital instructions for use: what is allowed, and the paper-on-request rule
Regulation (EU) 2023/1230 permits instructions for use, assembly instructions and the EU declaration of conformity to be supplied in digital form, for example by a QR code, data carrier or online, provided the manufacturer's risk assessment shows it is safe to do so. On a customer's request you must supply a paper version free of charge within one month. For consumer or non-professional use, safety information must still be provided on paper. Documentation must remain accessible for the machine's expected lifetime.
This is general information about Regulation (EU) 2023/1230, verified as at 12 July 2026, not legal advice. Confirm the exact Annex III clause and retention period against the final text.
Why this is a real change
Under the Machinery Directive, instructions travelled with the machine on paper. Manufacturers of industrial equipment have long wanted to ship a QR code or a link instead, both to cut cost and to keep instructions current. The Regulation allows that, but on conditions, so it is a permission with strings, not a free pass to drop paper.
The conditions
- A risk assessment must support it. Digital-only delivery is allowed where the manufacturer's assessment shows it is safe for the intended user and use. If a user could be left without the safety information they need at the moment they need it, digital-only is not appropriate.
- Paper on request, free, within one month. A customer can ask for a paper copy and you must provide it free of charge within one month. Build the process to fulfil that request before you rely on digital delivery.
- Non-professional use keeps paper safety information. Where the machine is intended for non-professional or consumer use, safety information must still be supplied on paper. This is the case to watch if you sell any machine that a non-professional might operate.
- Lifetime accessibility. The documentation must stay accessible for the machine's expected lifetime; sources cite a retention of at least ten years. A dead link years later is not compliant, so digital hosting has to be durable.
What to put in place
If you plan to go digital, you need three things before 20 January 2027: a documented risk assessment concluding that digital delivery is safe for your machine and user, a paper-on-request fulfilment process that can turn a request around within a month at no charge, and durable hosting that keeps the instructions and the EU declaration of conformity reachable for the machine's lifetime. Where any machine may be used by a non-professional, keep paper safety information in the box.
See the documentation set for your machine
The report lists the documents your machine must carry, including the digital-versus-paper rule for instructions and the paper-safety-information rule where your intended-use answer triggers it.
Get my machinery report →Sources
- Regulation (EU) 2023/1230, instructions for use and digital documentation (Annex III, reported clause 1.7.4, to be confirmed against the final text). EUR-Lex (checked 12 July 2026).
- Digital instructions, paper-on-request within one month, and paper safety information for non-professional use: instrktiv; adt-zielke (checked 12 July 2026).