Changes in declarations of conformity under the Machinery Regulation: My professional assessment

What happens to declarations when the Machinery Regulation enters into force in early 2027? 🤔

An 'EC declaration of conformity' becomes an 'EU declaration of conformity', and the same applies to declarations of incorporation.

As simple as changing a single letter! Easy. 👏

Next new thing:

“References to the harmonised standards referred to in Article 20(1) (...)” _{(Machinery Regulation 2023/1230)}

Okay, the harmonised standards that have been used must be included on the declaration.

Most people are probably used to doing that anyway – sort of. 🤫

"In the event of partial application of harmonised standards or common specifications, the EU declaration of
conformity shall specify the parts which were applied." _{(Machinery Regulation 2023/1230)}

This is where it gets a bit tricky. If you have only applied part of a harmonised standard, you must specify on the declaration which specific part or clause was applied. ☝️

Firstly, this means that if you follow this to the letter, declarations will be significantly longer than what people are used to. Right now, most declarations of conformity can be kept to a single page.

Secondly, you really need to have a seamless collaboration between those developing and designing the machinery, and those responsible for the CE marking and paperwork.

Take a standard like EN 619 – Continuous handling equipment and systems - Safety requirements for equipment for mechanical handling of unit loads.

In my eyes, a really good and practical standard that many people use when designing conveyor and logistics systems.

Here, people often use various tables, clauses, etc., and rarely comply with everything written in it.

But if you have to ensure that all the clauses used by the design engineers from the standard are listed on the declaration, well, in practice that will mean there must be an extremely tight connection between the design and documentation departments.

And not least, that everything gets noted down while developing and designing. That is something I might find a liiittle hard to envision working in practice in many organizations. 😮

On the other hand, from a buyer's perspective, it is enormously transparent what the machine complies with and what it does not. 👏

So in my humble personal opinion: A change that favors the buyer of the machinery quite a bit, and something that from my own experience will be a challenge for many manufacturers to manage in practice. 📣

Exciting it will certainly be! Check ANNEX V in the Machinery Regulation for the full text regarding requirements for declarations. There are a few other things you should be aware of.

(...) is where I have abridged the text.

Source for all quoted texts: ‘Machinery Regulation’ (EU) 2023/1230.

Last updated: 26/07/2026

About the author

Jesper Deleuran Larsen (LinkedIn)

CEO & Founder at Yellow Safety

• _‍FS Eng (TÜV Rheinland) # 33932 / 26 - Safety Instrumented Systems‍
• CMSE® Certified Machinery Safety Expert (TÜV Nord)

Jesper has many years of practical experience in automation, electrical installations, and safety-related control systems. He manages the sales function within the company as well as consultancy tasks regarding European and international regulations and standards. Jesper is the primary presenter for courses and training, serves as the managing director, and is the owner and founder of Yellow Safety.

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_{Disclaimer
The information provided in this blog post is for general informational and educational purposes only. It does not constitute, nor should it be considered, professional engineering advice or technical assistance. For specific projects or concrete machinery installations, obtaining an individual professional evaluation is always recommended. While we strive to keep the information as up-to-date as possible, always verify that all standards, executive orders, regulations, directives, etc., are the latest applicable versions.}

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