Europe's machinery makers and the 2027 rulebook change
On 20 January 2027, Regulation (EU) 2023/1230 replaces the Machinery Directive that has governed the sector since 2006. It lands on one of the EU's largest industrial bases: tens of thousands of firms, most of them small, and it changes which of them can still put a CE mark on a machine by their own hand. Here is the sector by the numbers, and the conformity routes that reshape on the date.
Of those firms, 97.5% are SMEs employing fewer than 250 people, and 63% are micro firms of nine people or fewer. This is the base the Machinery Directive let self-certify with harmonised standards.
From 20 January 2027, six categories of machinery in the new Annex I Part A lose the self-declaration option entirely: a notified body becomes mandatory no matter which standards were applied. For a small manufacturer, that is the difference between signing a declaration and booking a third party.
A €262 billion industry that runs on small firms
Manufacture of machinery and equipment is the largest EU manufacturing division by value added, worth 10.8% of all EU manufacturing. It generates its output through a long tail of small workshops rather than a handful of giants.
- Enterprises
- 79,096NACE C28, EU, 2022
- People employed
- 3.06m10.2% of EU manufacturing jobs
- Value added
- €262bnlargest EU manufacturing division
- Net turnover
- €846bn€277k per person employed
Average firm size is 39 people. That number hides a split the next chart makes visible: the count of firms is dominated by micro and small businesses, while the headcount is dominated by a small number of large ones. When a compliance obligation changes, both groups feel it, but only one has a compliance department.
Most firms are tiny. Most workers are not.
The same 79,096 firms, split by employment size class two ways: what share of the firms sit in each band (left), and what share of the sector's 3.06 million workers each band employs (right). The mirror image is the story.
Share of machinery enterprises vs share of employment, by firm size
NACE C28, EU, 2022 · both axes are % of the sector total · same 0 to 65% scale on each side
Firms of nine people or fewer are 63.2% of the sector by count but hold just 4.6% of its jobs. At the other end, the 2.5% of firms with 250 or more staff employ 56.0% of the workforce. The new conformity rules do not scale to headcount. A ten-person Part A manufacturer carries the same "notified body is now mandatory" obligation as a multinational, which is why the change is felt hardest across the long tail of small makers.
Two countries hold 43% of the industry
Machinery manufacturing is unusually concentrated. Italy and Germany between them account for 34,201 of the EU's 79,096 machinery enterprises. The full 27-country picture, sorted by number of firms or alphabetically.
Machinery-manufacturing enterprises by EU member state
NACE C28, number of enterprises, 2022 · all 27 member states · bar colour deepens with the count
Because the Regulation is a single EU-wide instrument with no national transposition, every one of these firms works to the same text on the same date. There is no member state where the Machinery Directive lingers after 20 January 2027, and no local variation in the Annex I lists to hide behind.
Can you still self-certify? Follow the branch.
The Regulation keeps self-assessment as the default for ordinary machinery, but it moves the fence lines. Annex I replaces the old Annex IV and splits into Part A (notified body always) and Part B (notified body unless standards fully cover). This is the decision an engineer runs for each product.
Conformity-assessment route under Regulation (EU) 2023/1230
Article 25 routes · select a starting point to trace its path, or read all three
What actually changed, line by line
Most of the CE-marking spine carries over: technical file, conformity assessment, EU declaration of conformity, CE mark, instructions. These are the points where 2023/1230 genuinely departs from 2006/42/EC.
Legal points drawn from the EUR-Lex summary of the Regulation and named secondary sources (F2 Labs, TUV Rheinland, Intertek, instrktiv), verified as at 12 July 2026. The precise Annex and Article numbering behind each row should be confirmed against the Regulation text, see the caveats.
The date is fixed, and it is not far off
Adopted in June 2023, the Regulation switches parts of itself on in stages, mostly for authorities and notified bodies, before the full application date that manufacturers actually plan around. There is no dual-application window at the end: from 20 January 2027, new machinery placed on the market must meet the Regulation.
Regulation (EU) 2023/1230: from adoption to full application
Key dates on one axis · the amber marker is today · red is the date that matters to manufacturers
until full application on 20 January 2027
Because notified bodies can already certify against 2023/1230 during the transition, the practical deadline for a Part A or an uncovered Part B manufacturer sits well before January 2027: assessment lead times lengthen as more firms arrive at the same bodies at once.
How this was built, and what to treat with care
Honest caveats
- The sector figures are Eurostat structural business statistics for NACE Rev. 2 division C28, "manufacture of machinery and equipment n.e.c.", for the EU as a whole in 2022 (the latest full year in the table). C28 is a defined statistical division; it is a strong proxy for "machinery makers" but it is not identical to the set of products in scope of Regulation (EU) 2023/1230, which also reaches related products and some machinery classified under other divisions. Read the counts as the scale of the affected industry, not as a headcount of firms in legal scope.
- We do not publish a count of how many firms fall in Annex I Part A or Part B. That would require a product-level breakdown Eurostat does not provide, and inventing one would be dishonest. The size and country figures are real and complete; the classification split is deliberately left to each firm's own determination.
- The exact Annex I Part A and Part B enumerations, the Article 25 route wording, the Annex III instructions clause and the transitional article should be transcribed directly from the Regulation before relying on them. The route logic and the comparison table above reflect the EUR-Lex summary and named secondary sources; the Regulation text is the authority, and the paid report cites it article by article.
- Figures dependent on implementing acts, delegated acts and the evolving harmonised-standards list can change. Every dated fact carries a "verified as at" stamp; this feature was verified as at 12 July 2026.
Method
Enterprise counts, employment, value added and turnover were pulled from the Eurostat dataset sbs_sc_ovw (enterprise statistics by size class and NACE Rev. 2 activity), filtered to geo = EU (27 countries, from 2020), nace_r2 = C28, reference year 2022, table version updated 10 March 2026, accessed 12 July 2026. Size-class and country shares are computed as each cell's percentage of the corresponding EU total from the same table; no figure here is interpolated or modelled. Legal facts are from the sources below.
Sources
Eurostat, structural business statistics, dataset sbs_sc_ovw (enterprise statistics by size class and NACE Rev. 2 activity), 2022: databrowser view (accessed 12 Jul 2026).
Eurostat, Businesses in the manufacturing sector, Statistics Explained: statistics-explained (accessed 12 Jul 2026).
EUR-Lex, Regulation (EU) 2023/1230 (legal act): eli/reg/2023/1230 (checked 12 Jul 2026).
EUR-Lex summary, Machinery safety requirements: legal-content summary (checked 12 Jul 2026).
F2 Labs, Regulation vs Directive comparison; TUV Rheinland, transition note; Intertek, AI and cybersecurity; instrktiv, digital instructions (all checked 12 Jul 2026).
Find out which branch your machine sits on
The charts above give the shape of the sector. For a single machine, the free scope check returns a headline verdict in about a minute, and the €99 report names your Annex I part, your Article 25 route, the documents you must hold, and a dated checklist to 20 January 2027, each point cited to the Regulation.