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Directive 2006/42/EC applies to machinery placed on the market or put into service before 20 January 2027. Regulation (EU) 2023/1230 generally applies from that date.

Machinery intended for lifting loads can be covered even when its only source of power is directly applied human effort.

Legal status depends on the definitions and intended function, not merely on whether the equipment will later be connected to something else.

Physical connection or location next to each other is not sufficient on its own.

Where risks interact at interfaces, the risk assessment must cover the whole.

All three criteria — common function, functional linkage and control as a whole — are assessed together.

Directive 2006/42/EC does not contain the same definition of “substantial modification” as the Regulation. The question is whether the change is so extensive that the resulting equipment may need to be treated as new machinery or a new assembly.

The following questions apply Article 3(16) of Regulation (EU) 2023/1230. A change alone is not automatically a substantial modification.

This is one condition in the definition of substantial modification.

Assess specific hazards and risks, not merely the name or scale of the project.

This includes guards or protective devices whose integration requires modification of the existing safety control system, or additional measures to ensure stability or mechanical strength.