In numbers
| Quantity | Value | Where it comes from |
|---|---|---|
| Date the Machinery Regulation applies | 20 January 2027 | DG GROW; a corrigendum moved the Official Journal date of 14 January |
| High-risk categories in Annex I | 6 in Part A, 19 in Part B, coating lines in neither | Regulation (EU) 2023/1230, Annex I |
| Online availability of digital instructions | Lifetime of the machine, at least 10 years | Regulation (EU) 2023/1230, Art. 10(7) |
| Paper instructions on request | Free of charge, within one month | Regulation (EU) 2023/1230, Art. 10(7) |
| Log of safety-software versions | 5 years | Regulation (EU) 2023/1230, Annex III 1.2.1 |
| Turkish mirror regulation | Published 16 October 2026, applies 20 January 2027 | Resmî Gazete 33402 |
The date that decides which rules apply to a coating line
The date that decides the regime is the day the line is placed on the market. Regulation (EU) 2023/1230 "applies on a mandatory basis as of 20 January 2027", according to DG GROW, and no postponement has been proposed. The Official Journal text first said 14 January; a corrigendum moved it to 20 January.
A line placed on the market under the Machinery Directive 2006/42/EC before that date stays legal after it (Art. 52 of the Regulation). A line placed on the market from that day carries a declaration that cites the Regulation.
The moment matters more for a coating line than for a single machine, because the line ships in parts and is assembled on site over weeks. When a project straddles the change, the regime is best fixed in writing at order stage.
A complete coating line is an assembly of machinery with one CE marking
A complete coating line counts as an "assembly of machinery", defined in Art. 3(1)(d) of Regulation (EU) 2023/1230 as machines "arranged and controlled so that they function as an integral whole".
That has three consequences. The assembly needs one declaration of conformity and one CE marking covering the whole line. One party has to act as the manufacturer of the assembly and sign that declaration. The risk assessment has to cover the interfaces: where the conveyor enters the booth, where the oven doors and the conveyor share an emergency stop, and where the pretreatment tunnel hands parts to the dry-off oven.
The product standards stay in place under the new Regulation. EN 16985 covers the spray booth, EN 1539 covers dryers and ovens in which flammable substances are released, and the ATEX Directive 2014/34/EU covers equipment inside the zoned areas of a powder booth.
Self-certification remains because Annex I does not list coating lines
Self-certification remains the route for a coating line. Annex I of Regulation (EU) 2023/1230 lists the high-risk machinery that needs a notified body, in 6 categories in Part A and 19 in Part B. Booths, ovens, pretreatment tunnels and conveyors appear in neither part.
The manufacturer carries out the conformity assessment and signs the declaration. Art. 10(3) requires that documentation to be kept for 10 years. A buyer should therefore not expect a notified-body certificate for the line as a whole.
The first list of harmonised standards under the Regulation had not been confirmed in the sources we used. Until it appears, the risk assessment in the technical file has to carry the reasoning for each standard applied to the booth, the ovens and the conveyor.
What changes for a coating line from 20 January 2027
Four changes in Regulation (EU) 2023/1230 reach the daily work of a coating line: digital instructions, the documentation period, the safety of the control system and the definition of substantial modification.
| Topic | Rule from 20 January 2027 | Article | What it means on a coating line |
|---|---|---|---|
| Digital instructions | Allowed if printable, online for the machine's lifetime and at least 10 years; paper free of charge within one month on request | Art. 10(7) | The manual can be a file or a link; the buyer can still ask for paper |
| Documentation | Kept for 10 years | Art. 10(3) | Applies to the technical file of the whole line |
| Protection against corruption | Control system protected against corruption | Annex III 1.1.9 | Remote access to the PLC and HMI is part of the safety design |
| Safety software | Versions of safety-related software logged for 5 years | Annex III 1.2.1 | Every update to the safety program is recorded |
| Substantial modification | Defined in law; the modifier becomes the manufacturer | Art. 3(16), Art. 18 | Adding a booth or extending an oven can make the buyer the manufacturer |
Regulation (EU) 2019/881 is named as the route to a presumption of conformity for the cybersecurity requirements. A practical application guide for the Regulation does not exist yet; only "Recommendation for Use" sheets were available as of May 2026.
Importer duties and the Turkish mirror regulation
Importer duties sit in Art. 13 of Regulation (EU) 2023/1230, and whether an EU buyer of a line built in Türkiye counts as the importer is not settled by any source we found. A cautious working rule is to treat the buyer as an importer and to hand over the full documentation pack on that basis, until the buyer's legal advice says otherwise. Member States had to notify their penalty rules to the Commission by 20 October 2026, and the Regulation states that these "may include criminal penalties".
On the Turkish side, the machinery safety regulation transposing 2023/1230 was published in the Resmî Gazete on 16 October 2026 (issue 33402) and applies from 20 January 2027. It mirrors the EU rules on importers and on digital instructions. A line built in İzmir can therefore be designed and documented to the same text at home and at its destination in the EU.
A dated timeline for three coating line deliveries
A dated timeline shows how the regime follows the placing-on-the-market date. We take three lines of the same design, built in İzmir and shipped to an EU buyer, and change only the date.
Line A placed on the market on 12 January 2027 = declaration under Directive 2006/42/EC Line A after 20 January 2027 = stays legal under Art. 52, no new declaration Line B placed on the market on 20 January 2027 = declaration under Regulation (EU) 2023/1230 Line B instructions = digital allowed, online at least 10 years, paper within one month on request Line B safety software = version log kept for 5 years Line C placed on the market under the Directive, booth added in 2028 = risk assessment under Art. 3(16) Line C if the change is substantial = the party adding the booth becomes manufacturer under Art. 18
For line C, Art. 18 limits the new manufacturer's duties to the machine of the assembly that the risk assessment shows to be affected.
A job coater in the EU whose line arrives in January 2027 typically asks which declaration will come with it, because the insurer and the labour inspectorate will ask for it. The answer depends on the day the line is placed on the market, and on a line that arrives in parts and is assembled over weeks that day is easy to leave undefined. On projects that straddle 20 January 2027, the date and the regime belong in the order confirmation.
An aluminium extruder's IT department often joins the project late and asks how the line's PLC will be reached for remote diagnostics, and who can change the safety program. From 20 January 2027 those answers belong in the design file under Annex III 1.1.9 and 1.2.1: who has access, how the access is protected, and where each version of the safety software is logged for 5 years.
The line configurator records the scope the declaration must cover
The scope of the declaration of conformity follows the equipment on the line, so the first step is to fix that equipment. Our line configurator builds the line from pretreatment, dry-off oven, booth, curing oven and conveyor, and asks the five quote questions: largest part size, maximum weight, available space L x W x H, energy source and number of colours. Its equipment list is the list the assembly declaration will name.
What this does not tell you
This post covers the machinery rules only. It leaves out the air permit for the oven exhaust and the ATEX zone drawing of the booth, which follow their own texts. The timeline assumes the date of placing on the market is agreed; for a line assembled on site it has to be fixed per project. Whether an EU buyer is an importer under Art. 13 is open. Legal advice in the destination country settles it.
Standards and sources
- Machinery Directive 2006/42/EC, applies to machinery placed on the market before 20 January 2027.
- Regulation (EU) 2023/1230, Art. 3(1)(d), 3(16), 10(3), 10(7), 13, 18, 52, Annex I and Annex III 1.1.9 and 1.2.1 (EUR-Lex).
- DG GROW, machinery page: application date of 20 January 2027 and the corrigendum to 14 January.
- Resmî Gazete issue 33402 of 16 October 2026: Turkish machinery safety regulation mirroring 2023/1230.
- Regulation (EU) 2019/881, presumption of conformity for cybersecurity.
- EN 16985 for spray booths, EN 1539 for dryers and ovens releasing flammable substances, ATEX Directive 2014/34/EU.
Questions buyers ask
Does a coating line delivered in 2027 need a notified body?
A coating line delivered in 2027 does not need a notified body for the line itself. Annex I of Regulation (EU) 2023/1230 lists 6 categories of high-risk machinery in Part A and 19 in Part B, and coating booths, ovens, pretreatment tunnels and conveyors are not among them. The manufacturer self-certifies and signs the declaration of conformity.
Is a line CE marked under the Machinery Directive still legal after 20 January 2027?
A line placed on the market under Directive 2006/42/EC before 20 January 2027 stays legal after that date under Art. 52 of Regulation (EU) 2023/1230. It does not need a new declaration. A later substantial modification is assessed under the Regulation, and the party making it can become the manufacturer.
Can the instructions for a coating line be supplied only in digital form?
The instructions can be digital from 20 January 2027 under Art. 10(7) of Regulation (EU) 2023/1230. They must be printable and kept online for the lifetime of the machine and at least 10 years. A buyer who asks for paper must receive it free of charge within one month.
Who signs the declaration of conformity for a complete line built from several machines?
The party that acts as manufacturer of the assembly signs one declaration covering the whole line, defined as an assembly of machinery in Art. 3(1)(d). On a turnkey line that is usually the supplier who designs, integrates and commissions the line. If several suppliers deliver parts, the contract has to name who takes that role.
If your line will be placed on the market between December 2026 and February 2027, send us the planned delivery date with your enquiry so the declaration regime is fixed in the offer. The turnkey powder coating plant page shows what a complete line covers, and the contact form reaches our engineers.