Machinery regulation: how to deliver the manual digitally

For decades, every machine has left the factory with a paper manual. Starting January 20, 2027, paper will no longer be the only option. The new Machinery Regulation, Regulation (EU) 2023/1230, allows instruction manuals to be provided in digital format.

You can do this if you indicate how to access the manual, ensure the user can download and print it, and keep it online for at least ten years. Safety information is still written by engineering. What can be automated, however, is the part derived from product data.

Uploading a PDF to a website is not enough. Each machine needs its own manual, in the correct language, and in the version corresponding to what you sold. And that, more than a documentation problem, is a data problem..

In this article, we explain what the regulation requires, what part of the manual can come from a PIM, and the extent of a PIM in digitalization and compliance. We also cover where it falls short, which is just as important.

Product data, orchestration, and PIM: what is behind a digital manual

An instruction manual is full of product data: the model, dimensions, weight, electrical specifications, noise emissions, spare parts, images, and diagrams. These are the same data points that appear on your website, in your catalog, and on the spec sheets provided to distributors.

The problem is that they originate in different places. Some come from the ERP, the company's management system. Others come from engineering. Images, diagrams, and documents usually live in a DAM, the digital asset repository. Ensuring that everything reaches every channel consistently is what we call data orchestration.

The tool that typically handles this work is a PIM (Product Information Management) system, which centralizes product data, organizes it, and publishes it wherever it is needed. It does not replace the ERP or engineering. It receives what they produce, often through an integration with the ERP, and distributes it to each channel.

What the Machinery Regulation requires for digital instruction manuals

The Article 10.7 allows for digital manuals under three conditions:

• Indicate where it is located: on the machine or, if that is not possible, on the packaging or in an accompanying document.
• The user must be able to download and print it.
• It must remain online for the expected service life of the machine and for at least ten years after it is placed on the market.

Paper is not disappearing entirely:

• If the customer requests it at the time of purchase, you must provide it in printed form, free of charge, within a maximum period of one month.
• If the machine is intended for non-professional users, essential safety information must always be provided on paper.

And there are two more requirements:

• The manual must be in the language specified by each country where you sell the machine.
• It must clearly describe the model to which it corresponds.

Which parts of the manual can come from a PIM

Not all of the manual consists of product data. To determine how much you can automate, categorize the information by its source:

• Product data: designation, model, manufacturer, dimensions, weight, electrical specifications, noise level, spare parts, images, and diagrams. These come from the ERP or engineering, and the PIM organizes and publishes them.
• Risk assessment results: intended use, foreseeable misuse, residual risks, warnings, protective equipment, emergencies, safe maintenance, and operator training. This is determined by engineering. The PIM stores and displays it, but does not generate it.

A risk assessment is the analysis that identifies the hazards of a machine and determines how to reduce them. The ISO 12100 standard explains how to conduct one, but it is not part of the regulation itself.

Just because a safety text is stored in the PIM does not make it PIM data. It remains the responsibility of engineering..

When a PIM can generate almost the entire manual

When the differences between references are data-based rather than risk-based, a PIM can generate almost the entire manual. Three examples:

• Lifting accessories (chains, slings, hooks): these vary by load, length, or material. The warnings remain the same for the entire product family.
• Catalog safety components, such as light curtains (barriers that stop the machine if someone crosses them): these vary by height, resolution, and range. The instructions follow the same structure across the entire range.
• Standard machines without options: one model, one configuration, and one risk assessment. The manual only changes with product revisions and language updates.

For this to work, safety texts must be organized into blocks by family, approved by an engineering manager, and version-controlled. The PIM then assembles and publishes the manual. What it does not do is write it.

Instruction manual with QR code: one version per machine

There is a risk that almost no one sees until it happens. If you change an attribute in the PIM today, you might be rewriting the manual for every machine you sold yesterday.

The reason is that a PIM lives in the present: it stores data as it is today. Compliance, however, lives in the past. The manual must correspond to the machine you placed on the market and remain available for at least ten years.

The secure way to comply is to save a version of the manual for each series or batch, fixed and accessible. In practice, the circuit consists of five parts:

1. The PIM stores the data associated with each serial number or batch.
2. A template assembles the manual using the blocks and data for that specific version.
3. A PDF is generated for each version and language, once, and is never touched again.
4. That PDF is stored in the DAM with a stable link.
5. The QR code on the machine or packaging points to an address on your own domain, which redirects to that PDF. If you ever change DAM, you update the redirect and the QR code keeps working.

The regulation does not require a QR code. It requires indicating how to access the instructions, and a QR code is the most practical way to do so. If you want to follow a standard, IEC 61406 defines how that link between product and documentation should work.

Keeping those links live for the machine's expected service life and at least ten years is the manufacturer's responsibility. The DAM is where the versions are stored.

How far does a PIM go in regulatory compliance

A PIM digitizes and organizes the manual, but it does not ensure regulatory compliance for you. There are machines where automation has a clear limit, and responsibilities that remain with the manufacturer.

What remains an engineering task

• Risk assessment. Warnings are derived from this. The PIM publishes them, but it does not decide them.
• CE marking and EU declaration of conformity. The CE marking is the mark indicating that the machine complies with European regulations. Both remain the responsibility of the manufacturer. If you provide the declaration digitally, it must also remain online for the intended service life and for at least ten years.
• Cybersecurity. Software and security data must be protected against accidental or intentional damage. This is an engineering and IT task.

An architectural project, not a template project

The digital manual is not solved with a tool. It is solved by deciding who owns each piece of data, how it is versioned, and where it is published. Templates come at the end.

This is what we do at Novicell with manufacturers. We start with a data map involving engineering, product, and marketing teams, define the data model, and only then do we choose and implement the PIM and DAM.

If you want to reach 2027 with your digital manual sorted out, see how we approach PIM implementation and DAM consulting.