What is "Machinery" under Article 4 of the Machinery Regulation 2023/1230?

Article 4(1)(a) of Regulation 2023/1230 defines "machinery" as an assembly of components or parts, at least one of which is movable, linked together for a specific application, fitted or intended to be fitted with a drive system other than directly applied human or animal effort. This definition is intentionally broad to capture the technological diversity of the sector.

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Does the Machinery Regulation 2023/1230 change the definition of "machinery" compared to Directive 2006/42/EC?

Yes, although the essence is similar, the Machinery Regulation 2023/1230 broadens and refines the definitions. It introduces new categories of "machinery-related products", expands the concept of "partly completed machinery" to explicitly include drive systems, and adds specific definitions for emerging technologies such as AI-integrated machinery. Moreover, being a Regulation (not a Directive), it applies directly in all Member States without national transposition, eliminating interpretive discrepancies between countries.

Is a collaborative robot (cobot) always "machinery" under Article 4?

Generally yes, if it is marketed as a functional unit with its own controller and task programming software. A cobot that can execute work cycles autonomously once programmed meets the criteria of Article 4(1)(a): it has movable parts, its own drive system, a specific function and does not require direct human force to operate. However, if it is sold as a kinematic module without a controller or programming software (to be integrated into a larger robotic system), it may be classified as partly completed machinery. The manufacturer's commercial and technical documentation must accurately reflect the intended classification.

When does Article 4 of the Machinery Regulation 2023/1230 become applicable?

The Machinery Regulation 2023/1230 has been in force since 19 July 2023, but its mandatory application begins on 20 January 2027. Until that date it coexists with the Machinery Directive 2006/42/EC, which remains valid for products placed on the market before January 2027. Manufacturers may voluntarily choose to apply the new regulation before that date. In any event, it is advisable to begin the classification analysis under Article 4 of the Machinery Regulation 2023/1230 now, to avoid complications during the transition.

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Article 4 of the Machinery Regulation 2023/1230 — Definitions: Machinery, Partly Completed Machinery and Machinery Assembly

Equip IgeraSolutions

July 1, 2026

11 min read

Maquinaria industrial con marcado CE — definición de máquina según Reglamento 2023/1230

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Article 4 of the Machinery Regulation 2023/1230 — Definitions: Machinery, Partly Completed Machinery and Machinery Assembly

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