Keeping digital instructions online for 10 years under the Machinery Regulation
Regulation (EU) 2023/1230 requires digital instructions to stay accessible online during the expected lifetime of the machine and for at least 10 years after it is placed on the market. Whichever period ends later applies. In practice this means a stable address, kept versions and a plan for changing systems or providers.
What the regulation says
(c) make them accessible online during the expected lifetime of the machinery or related product and for at least 10 years after the placing on the market of the machinery or related product.
Two periods, the longer one counts
The rule combines the expected lifetime of the machine and a minimum of 10 years after placing on the market. If you expect a machine to run for 20 years, the instructions stay online for 20 years. If the lifetime is shorter, 10 years is still the floor.
The clock runs per unit. A machine placed on the market in 2030 needs its instructions online until at least 2040, even if the model was launched years earlier.
Which version must stay online
Instructions change. A machine delivered in 2027 was shipped with the 2027 version. A good practice is to keep each published version and show the one that belongs to that machine, with later versions available alongside it.
Keep a record of the delivery date for each serial number. Without it you cannot tell which version a given machine received, or when its 10 years end.
Plan for change
Ten years is longer than most websites, document systems and software contracts last. The labels on the machines, however, stay the same.
- Use an address on your own domain, so the QR still works when you change system or provider.
- Make sure you can export all instructions, versions and machine data at any time.
- Give one person or team clear ownership of the online instructions.
- Check every year that a sample of old QR codes still opens the right page.
The declaration of conformity follows the same idea
Article 10(8) sets a similar rule for digital EU declarations of conformity: online for the expected lifetime and in any event for at least 10 years. Many manufacturers keep both on the same page.
Common mistakes
- Counting from the model launch. The 10 years run from the placing on the market of each machine, so late units extend the period.
- Overwriting the old PDF. When a new version replaces the old file, machines in the field lose the version they shipped with.
- Labels tied to a provider's address. If the provider changes, every label in the field points to a dead page. Use your own domain.
- No delivery dates on record. Without them you cannot tell which version a machine received or when its period ends.
How Nova handles long-term availability
Nova keeps each published version as a fixed copy and shows every machine the version it was delivered with. You stay in control of your data and your addresses.
- Published versions never change, stored as fixed copies with a checksum, with version history
- Machine list import with serial number, model and delivery date from your ERP spreadsheet
- Full export at any time as one file: PDFs, version history, machine list and paper requests
- Your own domain on the labels, so you won't need to reprint labels if you change provider
- The EU declaration of conformity on the same page as the instructions
Questions and answers
From which date do the 10 years start?
Is it 10 years or the lifetime of the machine?
What if our documentation provider closes or we switch?
Do we have to keep old versions online?
Does the 10-year rule apply to machines sold before 2027?
All six conditions for digital instructions
Each condition on its own page: the rule, what it means in practice and the common mistakes.
- 1 QR code and access Mark on the machine how to reach the instructions, for the right model.
- 2 Download, print, save Users must be able to print, download and save the instructions, even in a breakdown.
- 3 10 years online Keep the instructions online for the machine's lifetime and at least 10 years.
- 4 Paper copy on request A buyer who asks at purchase gets a paper copy free of charge within one month.
- 5 Language Instructions in the language the member state sets, clear and easy to understand.
- 6 Consumer machinery Machines non-professionals can use need essential safety information on paper.
Tools for choosing and checking
- Checklist20 checks across the six conditions. Tick them off or print the list.
- Platform comparisonThree kinds of platforms, 12 criteria and the questions to ask every vendor.
See it with your own machine.
Send us one manual. We set up that machine's QR page and show it to you the same day.
For information only, not legal advice. Regulation (EU) 2023/1230 applies from 20 January 2027.