Article 24 of the Machinery Regulation 2023/1230: the big change on digital instructions and when paper is still mandatory
Direct answer: Article 24 of Regulation (EU) 2023/1230 allows, for the first time, the manufacturer to provide instructions for use in digital format instead of paper, something Directive 2006/42/EC did not contemplate. But this possibility comes with strict conditions: the manufacturer must indicate on the machinery itself or on its packaging how to access the digital instructions, guarantee their availability throughout the whole expected lifetime of the machinery, and — the point that causes the most confusion — must provide a paper version free of charge if the consumer requests it at the time of purchase. The instructions must be drafted in the official language or languages of the Member State where the machinery is placed on the market. In this article we explain exactly what changes compared with the previous Directive and what minimum content Annex III requires.
Regulation 2023/1230, fully applicable from 20 January 2027, introduces digital instructions in response to a demand from the industrial sector that had for years been calling for a reduction in the volume of paper delivered with complex machinery, without giving up protection for the non-professional user.
The instructions for use are the documentation the manufacturer must provide together with the machinery, on paper or — since Regulation (EU) 2023/1230 — in digital format under specific conditions, with the minimum content set out in Annex III, point 1.7.4, drafted in the official language of the Member State of placing on the market, and whose absence or insufficiency prevents the machinery from being considered compliant even if it meets the rest of the technical requirements.
Paper on request, free of charge, no exceptions
Article 24(3) obliges the manufacturer to provide paper instructions free of charge if the consumer requests them at the time of purchasing the machinery. This guarantee does not exist for other professional recipients, for whom digital access may be the only route if the manufacturer so decides.
— Regulation (EU) 2023/1230, Article 24 (OJ L 165, 29.6.2023)
What actually changes compared with Directive 2006/42/EC?
Under Directive 2006/42/EC, instructions for use always had to be provided on paper, together with the machinery, with no exception allowing digital format as a substitute. Article 24 of Regulation 2023/1230 breaks that rule and allows, by default, instructions to be provided in digital format, provided the following conditions are met cumulatively:
- Clear indication of the access method: the manufacturer must indicate on the machinery, or where that is not possible on the packaging or in an accompanying document, how to access the digital instructions.
- Format that allows printing: the digital instructions must be presented in a format the user can download and print, not only consult on screen in a fragmented way.
- Availability throughout the whole expected lifetime: the manufacturer must guarantee access to the digital instructions while the machinery is in use, not only during the commercial warranty period.
- Delivery of critical safety information not solely dependent on the digital channel: essential safety warnings must still be able to be conveyed even if digital access fails at the time of use.
- Free paper copy at the consumer's request: if the recipient is a consumer — not a professional acting within the scope of their activity — they must be able to request the paper version free of charge at the time of purchase.
Can I provide only digital instructions to an industrial customer?
In principle yes, provided the conditions of Article 24(2) are met. The guarantee of free paper on request set out in Article 24(3) is formulated specifically for consumers, understood as natural persons acting for purposes outside their professional activity. For machinery sold to manufacturing companies, workshops or industrial facilities, the manufacturer may opt for a fully digital model, although in practice many manufacturers also offer paper on request to professional customers for commercial reasons and the customer's own internal traceability, not because the Regulation requires it in that case.
Identify whether the final recipient is a consumer or a professional
This classification determines whether the free-paper guarantee in Art. 24(3) is enforceable, and it must be documented in the sales channel.
Mark the digital access method on the machine or its packaging
A QR code or short URL durably printed on the rating plate is usually the most common and auditable solution.
Set up the paper-request process at the point of sale
If you sell to consumers, the distributor must be able to channel the request for free paper instructions before completing the sale.
Translate into the official language of each target market
Digital format does not remove the translation obligation: each language version must be available on the same digital channel.
Ensure the digital hosting persists throughout the lifetime of the machine
Plan for what happens if you change hosting provider or domain: the link recorded on the machine cannot end up broken years later.
What minimum content must the instructions have, on paper or digital?
The format — paper or digital — does not alter the minimum content required by Annex III, point 1.7.4, of the Regulation. The instructions must include, among other elements: a reproduction of the EU Declaration of Conformity or equivalent information about its content; the intended conditions of use and reasonably foreseeable misuse; assembly, installation and connection instructions; instructions for putting into service and use; information on residual risks that persist despite the integrated protective measures; maintenance instructions to be carried out by the user and those relating to recommended spare parts when they affect health and safety; and, where relevant, the essential characteristics of the tools that can be fitted to the machinery.
| Aspect | Directive 2006/42/EC | Regulation (EU) 2023/1230 |
|---|---|---|
| Accepted format | Paper only | Digital by default, with conditions (Art. 24(2)) |
| Paper for consumers | Always mandatory | Free of charge on request at purchase (Art. 24(3)) |
| Language | Official language of the Member State of marketing | Stays the same, also on the digital channel |
| Time availability | Linked to physical delivery | Must remain accessible throughout the whole expected lifetime |
Directly replacing paper instructions with a QR code without actively offering the consumer the option of free paper. Article 24(3) requires that the consumer be able to request it, which means informing them of that possibility at the point of sale, not simply providing it only if the consumer spontaneously asks for it without having been informed that the option exists.
A practical case: the brush cutter that Ferretería Cantoblanco sold without paper
Maquinaria Cantoblanco S.L., a fictitious distributor of small gardening machinery, began in 2027 selling a range of brush cutters whose manufacturer had opted for exclusively digital instructions, accessible via a QR code engraved on the chassis. An individual customer bought the equipment without the shop assistant informing them that they could request the paper manual free of charge. Weeks later, the customer filed a complaint with the consumer authority alleging insufficient information for the safe maintenance of the equipment. The investigation concluded that the manufacturer had complied with Article 24(2) regarding digital access, but the distributor had not fulfilled its part of the sales process by failing to actively offer the paper alternative provided for in Article 24(3), which led to a corrective recommendation on the sales protocol.
IgeraIndustria in action: verifying compliance with Article 24
How IgeraIndustria solves it
Question:
\"We want to move the instructions for our concrete mixers to an exclusively digital QR-code format. We sell them both to construction companies and to individuals through hardware stores. What does Art. 24 require of us?\"
IgeraIndustria answers:
\"Under Art. 24(2), you can opt for digital instructions if: you indicate the access method on the machine or the packaging, the format allows downloading and printing, and you guarantee availability throughout the whole expected lifetime. But pay attention to the sales channel in hardware stores: Art. 24(3) requires you to offer free paper on request to consumer buyers, not to construction companies buying as professionals. I recommend instructing your retail distributors to actively inform individual buyers of the free-paper option before completing the sale.\"
Do your digital instructions meet all the conditions of Article 24?
IgeraIndustria reviews the content of Annex III and the conditions of the digital channel before you receive a consumer complaint.
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Can digital information and paper warnings be combined on the same machine?
Yes, and in fact it is a practice recommended by many notified bodies. Article 24 does not impose an all-or-nothing model: the manufacturer can opt for a fully digital manual and keep, on paper, attached to the machine itself, only a summary of critical safety warnings — hazard pictograms, safety distances, emergency stop procedure — to ensure that this essential information is available even if the operator does not have immediate access to the digital channel at the time of use. This hybrid approach ties in with the general requirement in Annex III that the most critical safety information must reach the user at the time and place where it is needed.
In summary: instructions for use under Article 24
- Regulation 2023/1230 allows digital instructions by default, something Directive 2006/42/EC did not permit.
- They must indicate the access method, be downloadable and printable, and remain available throughout the whole expected lifetime.
- Consumers have the right to free paper if they request it at purchase; professionals do not have that legal guarantee.
- The minimum content of Annex III, point 1.7.4, does not change depending on the format chosen.
- Critical safety warnings should be kept accessible on the machine itself, not only on the digital channel.
Frequently asked questions about Article 24
Since when can digital instructions be used?
The possibility of replacing paper with digital format, under the conditions of Article 24(2), applies once Regulation (EU) 2023/1230 becomes fully applicable, on 20 January 2027. Before that date, Directive 2006/42/EC applies, which does not provide for this alternative.
In what file format must the digital instructions be provided?
Article 24 does not impose a specific file format, but requires it to be downloadable and printable by the user. In practice, formats such as PDF meet both requirements; a web page that does not allow structured download of the complete content may fail to satisfy the \"format that allows printing\" requirement set out in the rule.
What happens if the QR link stops working years after the sale?
The manufacturer would be in breach of the obligation to guarantee availability of the instructions throughout the whole expected lifetime of the machinery, set out in Article 24(2). It is the manufacturer's responsibility to keep the digital hosting active, migrate the content if it changes domain or provider, and put in place redirection mechanisms so that the access recorded on the machine continues to work.
Must digital instructions be translated into all EU languages?
Not into all of them, only into the official language or languages of the Member State or States where the machinery is actually placed on the market, just as Directive 2006/42/EC required for the paper format. If the manufacturer sells in several Member States, it must offer the digital version corresponding to each target market, not just a generic English version.
How do I tell if my customer is a consumer for the purposes of Article 24(3)?
The general criterion of EU consumer law, applicable by analogy, considers a consumer to be a natural person acting for purposes outside their trade, business, craft or profession. A purchase made by a company for its production activity does not give rise to the right to free paper under Article 24(3), even if the buyer is, in other contexts, also a natural person.
Can IgeraIndustria check whether my digital instructions comply with Article 24?
IgeraIndustria reviews the minimum content required by Annex III, point 1.7.4, against the documentation provided, and flags if elements are missing such as residual risks, intended conditions of use or maintenance instructions, in addition to reminding you of the obligation to offer free paper when the recipient is a consumer, although the final commercial decision always rests with the manufacturer or distributor.
Avoid a consumer complaint for not offering free paper in time
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Last updated: July 2026 | Author: Jordi Bassols, Industrial Safety Engineer, COEIC registered | Sources: Regulation (EU) 2023/1230 of the European Parliament and of the Council of 14 June 2023 on machinery, Article 24 and Annex III, point 1.7.4 (OJ L 165, 29.6.2023); Directive 2006/42/EC (in force until 19.1.2027). This article is for informational purposes only and does not constitute legal or engineering advice. IgeraIndustria — free trial. EUR-Lex — Regulation (EU) 2023/1230 This content is for informational purposes only and does not constitute legal or engineering advice. For the conformity assessment of your machinery, consult a notified body or a qualified industrial safety engineer.