Europe’s machinery overhaul reaches the slings, shackles and software under the hook

▌  INDUSTRY BRIEFING  ·  SEPTEMBER 2026  ·  EU MACHINERY REGULATION

Europe’s machinery overhaul reaches the slings, shackles and software under the hook

Two documents have been sitting in the EU’s Official Journal since the summer of 2023, and both of them reach the hardware that hangs under a crane hook. Regulation (EU) 2023/1230 — the Machinery Regulation — was adopted on 14 June 2023, published as OJ L 165 of 29 June 2023, and entered into force on 19 July 2023. It applies in full from 20 January 2027. On that day Directive 2006/42/EC, the Machinery Directive that lifting equipment has been certified against for the better part of two decades, is repealed.

The two positions are not in conflict. Nothing lawfully on the market has to be re-certified, and every sling and shackle shipped between now and January 2027 can still be declared under the old directive. But the file a notified body will ask to see in 2027 is not the file most lifting suppliers keep today — and a July 2026 amendment has just added a second layer to it.

▌  01  THE TWO DATES

▌  IN FORCE SINCE 19 JULY 2023  The Regulation has been law for more than three years. It entered into force on the twentieth day after publication, as Article 54 provides, and parts of it have applied since: the rules on notifying conformity assessment bodies from 20 January 2024, and Member State penalty rules from 20 October 2023. What has not applied yet is the product-facing core.

▌  APPLIES FROM 20 JANUARY 2027  On that date the Regulation applies in full and Directive 2006/42/EC is repealed. Until 19 January 2027 inclusive the directive remains the operative law. Products lawfully placed on the EU market before 20 January 2027 stay on the market under the directive and are not pulled back into the Regulation. There is no transition window after the date itself.

▌  02  WHAT DOES NOT CHANGE

▌  THE SCOPE LIST KEEPS ITS SHAPE  Article 2(1) still covers machinery and five named related products: interchangeable equipment, safety components, lifting accessories and chains, ropes and webbing, plus removable mechanical transmission devices. Slings, ropes and webbing are as much in scope in 2027 as they were in 2006. What moves is the route, not the perimeter.

▌  ANNEX I IS THE OLD ANNEX IV, SPLIT IN TWO  The directive’s single annex of category machinery has become Annex I of the Regulation, divided into Part A and Part B. Part A is short: removable mechanical transmission devices and their guards, vehicle servicing lifts, portable cartridge-operated fixing and other impact machinery, and the new machine-learning entries described below. Part B carries the older list — circular saws, presses, plastics and rubber moulding machines, machinery for underground working, devices for lifting persons where there is a fall hazard above three metres, protective devices designed to detect the presence of persons, logic units to ensure safety functions, roll-over and falling-object protective structures.

▌  MOST LIFTING PRODUCTS ARE NOT ON THE LIST  Most machinery does not appear in Annex I at all, and for those products Article 25(4) leaves internal production control — self-assessment — as the route. A standard sling, shackle or lifting point outside the list does not become a notified-body product on 20 January 2027. The list is where the pressure sits, and it is shorter than the headlines suggest.

▌  03  WHAT ACTUALLY CHANGES

▌  TWO ROUTES INSTEAD OF ONE  For Annex I Part A products, Article 25(2) applies: a notified body is involved, through EU type-examination plus internal production control, conformity based on full quality assurance, or unit verification. For Part B, Article 25(3) keeps self-assessment alive — but only where the product is designed and built to harmonised standards, or common specifications, that are specific to that category and cover all the relevant essential health and safety requirements. Where no such standard is cited, Part B quietly behaves like Part A.

▌  SELF-EVOLVING SAFETY FUNCTIONS NOW SIT IN PART A  This is the genuinely new entry. Annex I Part A reaches safety components — and embedded systems that have not been placed independently on the market — with fully or partially self-evolving behaviour using machine-learning approaches that ensure safety functions. A learning anti-collision function, a load-moment limiter that adapts its own limits, an AI-assisted zone-control layer: if it ensures a safety function and its behaviour evolves, it sits in the stricter column. The directive had no equivalent entry, so this category of product could previously be declared without third-party involvement.

▌  SOFTWARE CAN BE A SAFETY COMPONENT ON ITS OWN  Article 3(3) explicitly brings software ensuring a safety function inside the definition of a safety component. Software placed on the market separately is therefore itself a safety component: CE marking, technical documentation, and a notified body where the applicable procedure requires one. Under the directive, standalone safety software occupied a contested position; under the Regulation it does not.

▌  A SUBSTANTIAL MODIFICATION MAKES YOU THE MANUFACTURER  Article 3(16) defines a substantial modification as a physical or digital change to machinery or a related product, made after it is placed on the market or put into service, which the manufacturer did not foresee or plan, and which affects safety by creating a new hazard or increasing an existing risk. Article 18 attaches the consequence: the person who makes that modification is treated as the manufacturer for the affected product and takes on the manufacturer’s obligations. A retrofit, a deep parameter change or an unauthorised software modification can move the compliance burden from the supplier to the site that made the change.

▌  THE MACHINE HAS TO KNOW ITS OWN SOFTWARE  Annex III requires machinery to be designed so that the safety-relevant software installed can be identified and so that interventions on it can be evidenced. For a monitoring system that receives updates, that is a documentation requirement as much as a technical one: which software, which version, and what was changed.

▌  DOCUMENTATION MOVES DIGITAL  The Regulation moves instructions and technical documentation in a digital direction, reducing the paper-first expectation inherited from the directive. For exporters that is a saving; for site teams it changes what actually arrives with the machine.

▌  04  THE NEWEST LAYER: 8 JULY 2026

▌  REGULATION (EU) 2026/1744  Signed on 8 July 2026, published in the Official Journal on 24 July 2026 and in force since 27 July 2026, this is the Digital Omnibus on AI. Its Article 3 amends the Machinery Regulation.

▌  ONE FILE, NOT TWO  The point is to stop manufacturers of AI-enabled machinery from working through the AI Act and the machinery rules as two separate, overlapping regimes. Rather than two conformity exercises, the relevant AI Act requirements are folded into the machinery safety framework. The Commission is empowered to amend Annex III of the Machinery Regulation to add health and safety requirements for AI systems classified as high-risk because they are a safety component of machinery, or machinery products in their own right.

▌  THE AI DATES MOVED WITH IT  The omnibus also deferred the AI Act’s own high-risk deadlines. Stand-alone high-risk systems under Annex III now apply from 2 December 2027, and product-embedded high-risk AI — the route machinery falls under — from 2 August 2028. The AI Act’s wider application, including its Article 50 transparency duties, took effect on 2 August 2026.

▌  05  WHAT IT MEANS WHEN YOU SPECIFY OR BUY

●  If your anti-collision or load-moment function learns, who certified the learning — and against which document?

●  Who becomes the manufacturer when a safety function is retrofitted on a machine already in service?

●  Does the supplier’s declaration of conformity cite harmonised standards that cover every relevant requirement, or only some of them?

●  Will the technical file for a 2027-delivered machine identify the safety-relevant software and its version?

●  If instructions arrive digitally only, can the buying site still obtain paper?

●  Is the notified body you plan to use actually designated for this product category?

▌  06  WHAT TO WATCH

●  20 October 2026 — Member States’ communication obligations under the Regulation fall due, the last administrative marker before the product rules bite.

●  Annex I keeps moving: the Commission can add or remove categories by delegated act, and the machine-learning entries are new enough to be revisited.

●  Harmonised standards are the hinge for Part B. Where the citation list is thin, self-assessment stops being available for that category, whatever the annex says.

●  Notified-body capacity, not the legal text, is likely to be the practical constraint through 2026 and 2027.

●  The first market-surveillance actions are what usually turn a date in the calendar into a condition in a purchase order.

This briefing summarises EU-level rules. It is not legal advice, and local rules still govern your site.

ABOUT

Shandong Zhinuo (ZNAQ) designs and manufactures tower crane safety monitoring systems and lifting-safety hardware for export markets, including load-moment limiting, zone-control and anti-collision functions that are increasingly software-defined. We follow the EU machinery framework as it moves from directive to regulation, and build technical documentation to the stricter of the routes a product may fall under.

▌  CONTACT  shandongzhinuo@outlook.com  +86 176 6371 0314 · en.znaqkj.com

SOURCES

EUR-Lex, Regulation (EU) 2023/1230 on machinery — eur-lex.europa.eu

Official Journal of the European Union, OJ L 165, 29.6.2023, p. 1 — eur-lex.europa.eu

Corrigendum to Regulation (EU) 2023/1230, OJ L 169, 4.7.2023, p. 35 — eur-lex.europa.eu

Regulation (EU) 2024/2748 amending Regulation (EU) 2023/1230, OJ 8.11.2024 — eur-lex.europa.eu

Regulation (EU) 2026/1744 (Digital Omnibus on AI), OJ 24.7.2026 — eur-lex.europa.eu

Replacement EU Act Assessment of Impact, Regulation (EU) 2026/1744 — niassembly.gov.uk

European Commission summary, Directive 2006/42/EC on machinery — eur-lex.europa.eu