From January 2027, the new EU Machinery Regulation 2023/1230 will replace the current Machinery Directive for machinery placed on the EU market. The official regulation states that it applies from 14 January 2027 and directly affects manufacturers, importers, distributors and machinery suppliers operating in the EU.
One of the most practical changes is the move towards digital machinery documentation. This includes digital instructions and digital access to the EU Declaration of Conformity, often through an internet address or machine-readable code such as a QR code.
For equipment owners, hire companies and end customers, this is bigger than one document. It points towards a wider shift: machinery compliance records are becoming more digital, more traceable and easier to access on site.
The Declaration of Conformity is only the starting point
The Declaration of Conformity confirms that a machine met the relevant legal requirements when it was placed on the market or put into service. Under the new Machinery Regulation, manufacturers must either provide the Declaration with the machine or provide an internet address or machine-readable code where it can be accessed. Digital Declarations must remain available online for the expected lifetime of the machinery, and at least 10 years.
The regulation also allows instructions to be provided digitally, provided users can access, print, download and save them. Digital instructions also need to remain available for the expected lifetime of the machine and at least 10 years. Paper safety information is still required in some cases, particularly where machinery is intended for non-professional users or may reasonably be used by them.
This means a QR code may become a common way to access machinery documents, but the QR code itself does not make a machine compliant. The manufacturer still remains responsible for conformity assessment, technical documentation, CE marking and the accuracy of the Declaration.
Sustainable QR Codes: How FlexiQR is Helping the Construction Industry Go Greener | Capja
What this means for manufacturers
For manufacturers and machine builders, digital documentation is becoming part of the compliance process rather than a late-stage admin task.
Manufacturers need to consider how they will:
- Link declarations and instructions to the correct machine, model or serial number;
- Keep digital records available for the expected lifetime of the machinery;
- Manage document updates, revisions and safety notices;
- Ensure users can download, print and save digital instructions;
- Provide paper information where required;
- Maintain technical documentation and declarations for market oversight.
This is also becoming a customer support and sales message. ABB, for example, is already positioning the new Machinery Regulation around safety, cybersecurity and digital documentation, showing how larger suppliers are using regulatory change as a practical support message for machine builders.
What this means for importers, distributors and dealers
Distributors and dealers will not simply be able to assume the manufacturer has everything covered. Before making machinery available on the EU market, distributors must check that the machine has CE marking, is accompanied by the EU Declaration of Conformity, and has the required instructions and information in a language that users can understand.
Importers have additional responsibilities. They must keep a copy of the EU Declaration of Conformity for at least 10 years and ensure that the technical documentation can be made available to market surveillance authorities on request.
In practical terms, distributors, importers and dealers should start asking:
- Where is the digital Declaration hosted?
- Is it linked to the correct machine or serial number?
- Can the document be downloaded and retained?
- What happens if an OEM portal changes?
- Are instructions available in the required language?
- How are updates, recalls or safety notices managed?
What this means for hire companies and equipment customers
Hire companies may not usually be responsible for issuing the original Declaration of Conformity, but they will feel the impact.
When a machine arrives on site, customers increasingly expect to scan a QR code and see the documents they need immediately. That could include:
- Declaration of Conformity;
- Operator manuals;
- Safety instructions;
- LOLER, GA1 or equivalent inspection records;
- Maintenance evidence;
- Defect reports;
- Handover checks;
- RAMS and site documents.
.
For UK businesses, this links closely with existing PUWER and LOLER expectations. HSE guidance states that PUWER applies to people and companies who own, operate or have control over work equipment, including those providing equipment for hire. It also states that equipment must be suitable, safe, maintained, inspected where needed and used by people with adequate information, instruction and training.
For lifting equipment, LOLER places duties on those who own, operate or control lifting equipment. HSE guidance states that lifting equipment is often subject to statutory periodic thorough examination, and records must be kept of thorough examinations and defects.
So, for hire companies, the practical question is not only:
“Can we show the manufacturer’s Declaration of Conformity?”
It is also:
“Can we show the latest evidence that this asset is inspected, maintained and ready for site?”
D&G Noble and CapjaDocs: Fleet Paperwork at Your Fingertips | Capja
What about GA1, LOLER and equivalent re-testing?
The EU Declaration of Conformity deals with the machine at the point it is placed on the market. Once equipment is in use, the focus shifts to ongoing inspection, testing, maintenance and safe operation.
There is no single EU-wide “GA1” form. GA1 is commonly associated with Ireland and is used to record a Report of Thorough Examination for lifting equipment. The HSA’s GA1 form includes equipment identification, testing details, defects, competent-person details and the latest date for the next thorough examination.
The wider EU baseline comes from Directive 2009/104/EC, which sets minimum health and safety requirements for the use of work equipment. EU-OSHA explains that employers must keep work equipment compliant through adequate maintenance, and ensure inspection/testing by competent persons where required. Inspection results must be recorded and kept.
Different countries then apply their own national rules and inspection systems. Examples include:
- Ireland: GA1 Report of Thorough Examination for lifting equipment.
- UK: LOLER Thorough Examination, commonly every 6 months for lifting people or lifting accessories and 12 months for other lifting equipment unless an examination scheme says otherwise.
- France: VGP, or Vérification Générale Périodique, for periodic checks of lifting equipment and accessories. Common intervals include 12 months, with shorter periods for certain equipment types.
- Belgium: lifting equipment may require commissioning inspection and quarterly periodic inspections by an external technical inspection service.
- Italy: periodic verification applies to work equipment listed in Annex VII of Legislative Decree 81/2008, including lifting equipment for materials and lifting equipment for personnel.
- Germany: recurring DGUV / UVV-style inspections are used for work equipment such as hoists and cranes, with operators responsible for ensuring inspection by qualified or competent persons.
The terminology changes by country, but the practical need is similar: equipment owners need to prove that machinery and lifting equipment remains safe, inspected and documented throughout its working life.
“This innovation gives peace of mind and improves accountability”, Ian Bone, Las Plant | Capja
Nick Sampson Streamlines Crane Documentation with CapjaDocs | Capja
Why this matters for site access and customer confidence
Digital Declarations of Conformity are important, but they are only one part of the equipment lifecycle.
A contractor, site manager, operator or auditor may need to see:
- The original manufacturer compliance documents;
- The latest thorough examination or inspection report;
- The operator manual;
- Service and maintenance records;
- Defect history;
- Handover forms;
- Site-specific risk documents.
If these are spread across paper folders, OEM portals, emails, shared drives and inspection systems, the information may exist but still be difficult to prove quickly.
This is where QR-linked asset documentation becomes useful. A single asset-specific QR code can provide one controlled access point for the documents that matter.
How CapjaDocs can help
CapjaDocs helps equipment suppliers, hire companies and asset owners create QR-linked digital compliance packs for machinery, lifting equipment and plant.
A machine-specific CapjaDocs folder can hold:
- Declaration of Conformity;
- Operator manuals and instructions;
- LOLER, GA1, VGP or equivalent inspection records;
- Maintenance evidence;
- Safety notices;
- Handover forms;
- Defect reports;
- RAMS and site documents;
- Training or operator evidence where relevant.
.
This gives site teams, operators, customers and auditors one simple place to access the latest documents, while the equipment owner keeps control of updates, expiry dates and document history.
CapjaDocs does not replace the manufacturer’s legal responsibility for conformity, and it does not replace the role of a competent person carrying out inspections. It supports the practical management, access and sharing of the documents that prove equipment is ready, traceable and easier to check.
More than just lifting; it’s about lifting smarter | Capja / Quinn Crane Hire
Practical preparation checklist
Before January 2027, manufacturers, distributors, hire companies and equipment owners should review:
- Which assets need a Declaration of Conformity?
- Where are those Declarations stored today?
- Are documents linked to the correct machine, model or serial number?
- Can site teams access them quickly?
- Can documents be downloaded, printed and retained?
- Who controls document updates?
- How are expired inspection records managed?
- Where are GA1, LOLER, VGP or equivalent records stored?
- Can manufacturer documents and in-service inspection records sit together?
- Is there a reliable audit trail for changes?
This article is provided for general information only and reflects Capja’s current understanding at the time of writing. It should not be treated as legal or compliance advice. Regulations, guidance and national requirements may change, and businesses remain responsible for carrying out their own checks, seeking appropriate professional advice, and confirming how the relevant legislation applies to their specific equipment, market and responsibilities.
Want to make machinery documents easier to access, update and share?
Capja can help you apply flexible QR codes and manage long-term digital compliance packs for your equipment. Speak to our team to see how simple it can be.
Contact Capja | Discuss Your Needs
FAQs
Does the EU Machinery Regulation require a QR code?
The regulation refers to an internet address or machine-readable code. A QR code is likely to be one of the most practical methods, but the regulation does not only name QR codes.
Does a digital Declaration of Conformity replace CE marking?
No. CE marking, conformity assessment and technical documentation remain separate requirements. The digital Declaration is an access method for the compliance declaration, not a replacement for compliance.
Do hire companies need to issue the Declaration of Conformity?
Usually, no. The manufacturer issues the Declaration of Conformity. However, hire companies still need to give customers access to relevant machine documents, inspection records and safety information.
Is GA1 the same as LOLER?
Not exactly. GA1 is commonly used in Ireland as a Report of Thorough Examination. LOLER is the UK lifting equipment regime. Other European countries have their own equivalents, such as VGP in France.
Is there one EU inspection certificate for lifting equipment?
No. EU rules create a baseline for safe use, maintenance and inspection of work equipment, but each country implements its own national inspection systems, terminology and intervals.
Can inspection records be stored digitally?
In many cases, yes, provided they can be accessed, retained and produced when required. The important point is that records are available, accurate and linked to the correct equipment.
Source links used in this article
EU Machinery Regulation 2023/1230 – official EUR-Lex text
https://eur-lex.europa.eu/eli/reg/2023/1230/oj/eng
EU-OSHA summary of Directive 2009/104/EC on the use of work equipment
https://osha.europa.eu/en/legislation/directives/3
HSE PUWER overview
https://www.hse.gov.uk/work-equipment-machinery/puwer-overview.htm
HSE LOLER overview
https://www.hse.gov.uk/work-equipment-machinery/loler-overview.htm
HSE thorough examinations and inspections of lifting equipment
https://www.hse.gov.uk/work-equipment-machinery/thorough-examinations-lifting-equipment.htm
HSA GA1 Report of Thorough Examination form
https://www.hsa.ie/media/eeldqclm/ga_1_form_hsa.pdf
French VGP / periodic general inspection reference
https://www.traclev.com/en/inspection/periodic-general-inspection
Belgian lifting and hoisting inspection guidance
https://employment.belgium.be/en/themes/well-being-workers/work-equipment/lifting-and-hoisting
Italian periodic verification of work equipment reference
https://www.imq.it/en/inspections-audits-and-verifications-services/verification-of-work-equipment
German DGUV / UVV inspection reference
https://www.transprotec.com/infocenter/safety-inspections-according-to-german-dguv-regulations
ABB EU Machinery Regulation 2027 support page
https://www.abb.com/global/en/areas/motion/drives/expertise-technology/eu-machinery-regulation-2027
EU Council Omnibus IV provisional agreement on digitalisation and common specifications
https://www.consilium.europa.eu/en/press/press-releases/2026/06/09/simplification-council-and-parliament-strike-deal-to-help-growing-businesses-thrive-and-accelerate-digitalisation/
CEA / CECE industry concerns on Omnibus IV digital Declaration of Conformity transition periods
https://thecea.org.uk/industry-news/eu-digital-compliance-reforms-industry-calls-for-a-practical-approach
