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Analyses · 2026-10-03

Machinery: a changeover date that gets passed around wrong

Machinery is the first category in this series where the rules come mainly from employer duties rather than product admission, and that is clearest in the US. This sets out that structure, then the EU changeover now under way, and one date that circulates in the wrong form.

Rules for machinery come from two places

Compliance rules for industrial goods usually come from one of two places: whether the product may enter the market, or how the product is used on site and who guarantees its safety. Machinery has both, and the balance differs sharply by market.

In the EU it is a product admission question, and machinery carries the CE mark to be placed on the market. In the US it is mainly an employer duty: the federal machinery requirements sit in occupational safety standards, which govern the workplace rather than market access. Keeping the two apart removes much of the confusion in this category.

EU: a directive becomes a regulation, and the date is easy to get wrong

The current basis in the EU is the Machinery Directive 2006/42/EC, published at OJ L 157/24 on 9 June 2006. It is being replaced by the Machinery Regulation (EU) 2023/1230, published at L 165/1 on 29 June 2023.

The closing articles of the regulation are explicit: it enters into force on the twentieth day after publication and applies from 14 January 2027, and Directive 2006/42/EC is repealed with effect from 14 January 2027. Some articles apply earlier: Articles 26 to 42 from 14 January 2024, and Article 50(1) from 14 October 2023.

One point deserves saying directly. Between the two dates that circulate for the changeover, 20 January 2027 and 14 January 2027, the text supports the second. It is worth remembering because it is exactly the shape of the most common sourcing risk: a date that looks precise gets copied between companies for years without anyone going back to the text.

The regulation also gives transitional protection: products placed on the market in conformity with 2006/42/EC before 14 January 2027 may continue to be made available. The rule does not reach back, but newly placed goods must follow the new regulation.

EU conformity: it depends on Annex I

The conformity route turns on whether the machinery falls inside Annex I, which lists the high-risk categories: several kinds of saws and presses, woodworking machinery, injection moulding machines, lifting and hoisting equipment, and machinery with safety-related AI functions among them.

Inside Annex I, EU type-examination by a notified body is required. Outside it, the manufacturer can normally complete internal production control and draw up the technical file. The distinction is the same structure as the self-declaration versus third-party split in toys and appliances.

The supporting harmonised standards centre on the ISO 12100 family for general design principles and risk assessment, with separate standards for electrical equipment and safety-related control systems. The harmonised standards are not themselves mandatory, but testing against them is the usual route to a presumption of conformity.

US: the rules govern the workplace, not the market

Federal machinery rules in the US sit in the occupational safety and health standards at 29 CFR part 1910, where Subpart O covers machinery and machine guarding. This route differs entirely from the EU's: it sets out what an employer must do in the workplace, including guarding, procedures and training, not what certificate a product must hold.

So in the US, a machinery compliance question has to be split first. If it asks whether a machine may be sold, there is no unified federal product approval, though particular product classes have their own rules, laser products among them. If it asks what a machine installed in a workshop has to satisfy, the answer is in Subpart O and state occupational safety law.

That difference has a practical consequence for exporters: the same machine needs a CE mark for the EU, while in the US what matters is that the buyer, as employer, can pass an occupational safety inspection. The two produce different kinds of evidence.

China: mandatory standards plus catalogue controls

China leans on mandatory national standards, with some machinery inside the CCC mandatory certification catalogue, adjusted in recent years and to be checked against the current announcement. A further admission route is easy to overlook: special equipment manufacturing licences. Lifting machinery and some pressure vessels are special equipment, and that licence is a different kind of instrument from a CE mark.

For this category we currently hold the regime at that level only, with no standard text collected, so no standard numbers are written into the page.

Japan, Korea, Brazil, Gulf

Japan regulates machinery safety under its industrial safety and health act, with individual inspections for specified machinery. Korea works through its industrial safety and health act and the certification regime underneath it. Brazil has NR-12 on machinery and equipment safety, alongside INMETRO certification for machinery. The Gulf states regulate under the GSO machinery technical regulation, with Saudi Arabia routing through SABER.

For these four markets we currently hold the regime described but no primary text, so the page states the regime and no document numbers.

Ten markets side by side

One extra column, where the rule comes from, makes the structural difference clear:

The column that earns its place is the third. In the same category, the EU asks whether the machine may be sold, and the US asks whether it is safe in use. For a buyer that means the compliance material coming from a supplier is not even the same kind of document in the two markets.

What to ask before you order

Ask machinery questions in two groups. On admission: whether the machine has been assessed for the target market, whether the technical file is complete, whether any Annex I category required a notified body, and who carries the CE mark or its equivalent. On the site: which language the instructions and safety information are in, whether guards and safety functions are configured to the target market's requirements, and whether a risk assessment exists.

The second group matters more in this category than in most. Machinery fails differently from a small appliance, in that it injures people, so complete paperwork is not the same as a machine that will pass commissioning. A buyer who checks the mark but not the guarding and the risk assessment meets the problem again at installation. To work through these in order, start with the free verification checklist. The previous article in this series is packaging; the next, personal protective equipment, covers another risk-tiered structure. To see how certifications and export markets are recorded, look at a report sample, or get in touch.