Can the technical file be stored entirely in the cloud?

Yes. MR 2023/1230 does not require physical storage. Cloud-based document management systems are acceptable provided they guarantee the integrity, authenticity and accessibility of all documents throughout the ten-year retention period. Long-term archive formats are recommended (PDF/A, standard CAD exports), along with independent backup copies.

What happens to the technical file when a company is acquired or merged?

The retention obligation passes to the legal successor of the original manufacturer. In a merger or acquisition, due diligence must include verifying that technical files for all marketed models are complete and accessible. The acquirer assumes custodial responsibility until the ten-year period expires from the date of last manufacture of each model.

Does the importer need access to the technical file?

The importer is not required to hold the technical file, but MR 2023/1230 requires them to verify that the manufacturer established outside the EU has drawn up the file and can make it available to market surveillance authorities. Responsible importers include a contractual clause requiring the non-EU manufacturer to provide the technical file within a specified period upon request by a competent authority.

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Article 22 of the Machinery Regulation 2023/1230 — Technical Documentation: Required Documents and How to Prepare

Equip IgeraSolutions

July 1, 2026

12 min read

Técnico revisando documentación técnica de maquinaria industrial para expediente CE

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Article 22 of Machinery Regulation (EU) 2023/1230 requires manufacturers to compile the technical file (Annex IV) before placing machinery on the market. Learn the 10 mandatory documents, the 10-year retention obligation and how IgeraIndustria helps you audit it before a market surveillance inspecti

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