Whitepaper - Introduction

The European Association for Technical Communication – tekom Europe e.V. (tekom Europe)
welcomes the Machinery Regulation (EU) 2023/1230; herein MR, which will succeed the Machinery
Directive 2006/42/EC (herein MD) as of January 20, 2027.

The new law will have a great impact on Technical Communication as with the new law the EU
did open the door to digital instructions for use. Between EUR 6.63 billion and EUR 26.5 billion
are spent every year by approx. 82.239 companies for printing instructions for use for machinery.

The acceptance of printed instructions for use is questionable, as 62.7 % of all users don’t
want paper as format for the instructions for use. It is expected that by the introduction of
digital instructions for use printing costs can be reduced significantly and that digital instructions
for use will contribute substantially to environmental friendliness.

Besides allowing supply of digital instructions for use, the MR contains improvements of rules
and regulations, aligning it with the New Legislative Framework (NLF).

tekom Europe participated in the legislative process. It should be acknowledged that the wording
of the MR is a compromise between the respective stakeholders. Consequently, the wording
may be considered as lacking optimum precision and clarity. tekom Europe would like to
address open issues and sections to improve the understanding of the MR in the further discussion process. In the meantime, technical communicators will have to manage and deal with
the different issues in this state of uncertainty and doubts regarding the exact interpretation.

As has been practiced for the MD, the application of the rules and regulations will be significantly
influenced by the yet to be developed European Commission’s Guide to the application of
Machinery Regulation, which will provide background information and statements forming the
basis for the interpretation of the MR. It is expected that the guidance document will be published by the European Commission before the MR applies.1 Certainly, the guidance document will give rise to a revision of the present whitepaper as well. This whitepaper aims to support technical communicators regarding the most crucial aspects of the MR adoption and application.

Furthermore, it is expected, that we will have EU Legislation dealing with digitalization (AI, cyber
resilience) and the Green Deal shortly. Such legislation may have some impact on machinery
and consequently on the application of the MR as well. tekom Europe will follow the developments continuously and analyze the impact in detail.

Finally, tekom Europe would like to emphasize the need for a discussion within the community
of technical communication dealing with the impact of the MR and encourages the reader
to participate in that discussion. Please use the following contact data for any contribution:
European Association for Technical Communication – tekom Europe e.V., Heilbronner Straße 86
70191 Stuttgart, GERMANY, +49 711 65704-0,,

Tiziana Sicilia, President tekom Europe
Stuttgart, November 1, 2023