Machinery Regulation 2027 and the GPSR: EU rules for instruction languages and digital formats

1The short version

• The GPSR, Regulation (EU) 2023/988, has applied since December 13, 2024 (Article 52).
• Manufacturers and importers must make sure products come with clear instructions and safety information in a language consumers can easily understand, as determined by the member state where the product is sold (Articles 9(7) and 11(4)). Distributors must check this (Article 12(1)).
• Online offers must show the product's warnings and safety information in that language too (Article 19).
• Under the GPSR, information in digital format comes in addition to these documents, not instead of them (Article 21).
• The Machinery Regulation, Regulation (EU) 2023/1230, applies from January 20, 2027. Instructions for use may then be digital, but users can ask for paper at the time of purchase, and essential safety information stays on paper for machinery that non-professionals may use (Article 10(7)).
• Video guides help customers follow the steps. They complement the required documents; they don't replace them.
• Change pending: an EU digitalisation package agreed in June 2026 would allow electronic instructions under the Low Voltage Directive and update the Machinery Regulation's declaration of conformity rules. It is not law yet (October 2026).

2GPSR: the language rules that apply now

Article 9(7) sets the rule for manufacturers: “Manufacturers shall ensure that their product is accompanied by clear instructions and safety information in a language which can be easily understood by consumers, as determined by the Member State in which the product is made available on the market.” It doesn't apply where the product can be used safely and as intended without them.

Importers have the same duty (Article 11(4)), and distributors must verify it before selling (Article 12(1)). If you place a product on the market under your own name or trademark, you're treated as the manufacturer (Article 13(1)).

For online sales, Article 19 lists what every offer must show clearly and visibly, including “any warning or safety information to be affixed to the product or to the packaging or included in an accompanying document”, in a language consumers in that member state can easily understand. So each market's listing needs those warnings in its language.

The regulation doesn't name the languages. Each member state decides, so check the national rule for every country you sell into.

Article 21 lets you also provide this information digitally, through an electronic solution visible on the product, packaging or accompanying document; recital 32 gives a QR or data matrix code as an example. It must be in a language consumers there can easily understand, “including in accessible formats for persons with disabilities.”

One scope note: where a product is subject to EU harmonisation legislation, meaning specific product laws such as the machinery rules, GPSR Articles 9 to 18 don't apply to it, and that legislation's own instruction rules do (Article 2(1)). Articles 19 and 21 sit in a different section and still apply.

3Machinery Regulation: digital instructions from January 20, 2027

Regulation (EU) 2023/1230 replaces the Machinery Directive 2006/42/EC. Article 54 first said it applies from January 14, 2027; a corrigendum in the Official Journal of July 4, 2023 corrected the date to January 20, 2027. Machinery placed on the market in line with the old directive before that date can still be made available (Article 52(1), as corrected).

Article 10(7) says the instructions for use “may be provided in a digital format” and must clearly describe the product model they belong to. When the instructions are digital, the manufacturer must meet these conditions:

1. Show how to access them Mark on the machinery, or where that isn't possible on the packaging or an accompanying document, how to access the digital instructions (point a).
2. Make them printable and saveable Use a format the user can print, download and save on a device, so the instructions are available at all times, including during a breakdown. This also applies to instructions built into the machine's software (point b).
3. Keep them online Keep the instructions accessible online for the expected lifetime of the product and for at least 10 years after it is placed on the market (point c).
4. Provide paper on request If the user asks at the time of purchase, provide the instructions on paper, free of charge, within one month. Recital 40 adds that distributors should be able to provide them.
5. Keep essential safety information on paper For machinery intended for non-professional users, or that they could foreseeably use, the safety information essential for putting it into service and using it safely must be provided on paper.
6. Use the right language Instructions, safety information and the Annex III information must be in a language users can easily understand, as determined by the member state concerned, and be clear, understandable and legible.

4Which products are covered?

The Machinery Regulation covers machinery, related products such as interchangeable equipment and safety components, and partly completed machinery (Article 2(1)).

Article 2(2)(p) excludes several electrical products where they fall under the Low Voltage Directive 2014/35/EU or the Radio Equipment Directive 2014/53/EU: household appliances intended for domestic use (other than electrically operated furniture), audio and video equipment, IT equipment, ordinary office machinery, low-voltage switchgear and electric motors. The office machinery exclusion does not cover additive printing machinery for producing three-dimensional products, so 3D printers are not excluded on that ground.

In practice, household kitchen appliances such as air fryers generally don't get the 2027 digital option. Their instruction rules come from the legislation that covers them. The Low Voltage Directive, for example, requires electrical equipment to be accompanied by instructions and safety information in a language consumers and other end-users can easily understand, as determined by the member state (Article 6(7)).

A change is pending. In May 2025 the European Commission proposed a digitalisation package. Its directive part would let equipment under the Low Voltage Directive come with instructions and safety information in electronic form, with safety information for consumer products still on paper or marked on the product. Its regulation part changes the Machinery Regulation's rules on declarations of conformity and documentation, but in the Commission's proposal not Article 10(7). Negotiators agreed a text in June 2026, but as of October 12, 2026 it is not law: Parliament's plenary vote is forecast for November 2026, then the Council must adopt it. Check the final text in the Official Journal before changing your packaging.

Two- and three-wheel vehicles covered by Regulation (EU) No 168/2013 are also excluded (Article 2(2)(h)). Whether a specific e-bike, scooter or garden robot counts as machinery is a classification question for your compliance team or notified body. The texts leave room for interpretation here, and we don't make that call.

5A checklist for brands selling in the EU

1. Classify each product GPSR only, or covered by specific legislation such as the Machinery Regulation or the Low Voltage Directive? The answer decides which instruction rules apply.
2. Map languages per country List every member state you sell into and the language each one requires for instructions and safety information.
3. Keep the documents in the box Where the GPSR applies, the instructions and safety information must accompany the product, and a digital version is only an addition (Article 21). For consumer machinery after January 20, 2027, keep at least the essential safety information on paper.
4. Fix your listings Show warnings and safety information on each market's listing, in its language (GPSR Article 19).
5. Going digital for machinery Print the access route on the product or packaging, offer a printable file, keep it online for at least 10 years after placing on the market, handle paper requests within a month, and identify the model clearly. Article 10(8) also lets you give the EU declaration of conformity as an internet address or machine-readable code.
6. Check your supply chain Importers must make sure the instructions accompany the machinery (Article 13(4)), and distributors must check them and their language before selling (Article 15(2)).
7. Plan accessibility GPSR Article 21 says digital information must be in a language consumers can easily understand, including in accessible formats for persons with disabilities. Captions and a text version make a video usable for more people.

6Where multilingual video guides fit

A video guide is not the legal instructions. It's the part many customers actually watch. Next to the required documents, it can show each step in the customer's language, repeat the manual's safety notes at the step where they apply, and be updated without reprinting the box.

A video can't be printed, so on its own it doesn't look able to meet the print-and-save condition in Article 10(7)(b). Treat it as a complement to a printable manual, linked from the same QR code or page. That's our reading of the text. Lawyers have also flagged open questions about how the GPSR's “additionally” wording in Article 21 sits next to the Machinery Regulation's digital option, so check with your adviser.

Our QR video manuals open the guide in the phone's language from one code on the box, and our page on video instructions for manufacturers covers multi-country rollouts. For print specs, see the QR code on packaging guide.

This is general information, not legal advice. Laws, national language rules and official guidance change, so confirm against the official texts and with a qualified adviser before you change your documents.

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