(Photo: © Bunse-Aufzüge)
July 2026
As the date of application for the regulation as of 20 January 2027 is approaching, manufacturers and all other stakeholders need to be prepared urgently to comply with the new and revised requirements in a timely fashion.
The January 2024 issue of LIFTjournal provided a comprehensive introduction to the new EU Machinery Regulation.
BY ESFANDIAR GHARIBAAN
Overview: The EU Machinery Regulation, (EU) 2023/1230 was published on 29 June 2023 and entered into force on 19 July 2023, when its references were published in the EU Official Journal. The Regulation will definitively replace the current Machinery Directive 2006/42/EC on 20 January 2027 and will be repealed on the same day.
This is an EU regulation and therefore it becomes an identical national regulation in all 27 EU Member States without a transition period.
Machinery Regulation covers requitements and conformity assessment procedures for a wide range of products in the lift sector, such as escalators and moving walks, lifting platforms, building hoists, goods only lifts, stairlifts and lifts used to access workplaces, such as lifts in wind turbines or in cranes. In addition, more than 50 Essential Health and Safety Requirements (EHSRs) of the Machinery Regulation apply to lifts.
New and revised requirements in the Machinery Regulation include new and emerging technologies, such as self-evolving behaviour (Artificial Intelligence, AI) and protection against corruption (cyber safety). Inclusion of these aspects has been one of the main reasons for revising the current Machinery Directive to become the Machinery Regulation.
Important changes in the ESHRs, which are directly relevant to lifts and escalators, include:
All machinery products to be placed on the EU market on or after 20 January 2027 must be in full compliance with the Machinery Regulation. Typically, manufacturers may apply internal production control to demonstrate conformity to the requirements. For the products that are not listed in Annex I of the regulation, Notified Body assessment is not required.
However, Functional Safety and System Integrity Level (SIL) rated control systems, as described in Annex I, Part B, 17 (Logic units to ensure safety functions), will require a conformity assessment involving a Notified Body, when cited harmonized standards cannot be applied or such standards are not available.
The current challenge for the industry is achieving conformity with EHSR 1.1.9, Protection against corruption. A new harmonised standard prEN 50742 on protection against corruption is under development. However, the date of readiness of the standard and the date of its citation in the EU Official Journal are not yet clear.
In absence of cited harmonised standards and for the new and changed essential requirements, the Notified Bodies will have to assess the conformity of the machinery without having the benchmark of a cited standard. In the meantime, the existing ISO 8102-20:2022 standard on cybersecurity for lifts and escalators can serve as an orientation for Notified Bodies to anticipate the changes. This ISO standard is under revision to be updated and published as EN ISO 8102-20 in the future, but later than January 2027.
As mentioned above, relevant EHSRs of the Machinery Directive and now Machinery Regulation that have not been covered in Annex I of the Lifts Directive, apply to lifts and safety components for lifts. Although the Lifts Directive, 2014/33/EU has not been revised, the new or revised relevant EHSRs of the Machinery Regulation affect lifts. Therefore, lifts or safety components for lifts to be placed on the EU market on or after 20 January 2027 must comply with those EHSRs.
"All machinery products to be placed on the EU market on or after 20 January 2027 must be in full compliance with the Machinery Regulation." Esfandiar Gharibaan
Conformity of safety components has another complexity. Those components placed on the market before 20 January 2027 must comply with the relevant EHSRs of Annex I of the Machinery Directive. However, lifts in which those safety components are integrated must comply with the relevant requirements of the Annex III of the Machinery Regulation as of 20 January 2027.
It is important to note that only the relevant EHSRs of the Machinery Regulation apply to lifts. Other aspects of the regulation, for example articles, are not applicable to lifts. Therefore, topics such as definition of the substantial modification for machinery are not applicable to lifts and a specific definition for lifts should be provided by the EU Commission.
The EU Commission is preparing a guide on the impact of the Machinery Regulation and conformity assessment for lifts and safety components for lifts and validity of lift and lift safety component certificates.
The new EN ISO 8100-1:2026 standard that will replace EN 81-20:2020 will address the new and changed essential requirements of the Machinery Regulation. EN ISO 8100-1 was published on 27 March and is expected to be cited in the EU Official Journal by early Q4 2026.
Standardization committee, CEN TC10, has prepared a guide explaining which of the new or changed EHSRs of the Machinery Regulation are covered by EN 81-20:2020 and which paragraphs of the new EN ISO 8100-1:2026 will cover the new or changed EHSRs of the Machinery Regulation which are not covered by EN 81-20:2020. The guide is available through the national standardization bodies.
To cover the new or modified EHSRs of the Machinery Regulation, the following additional requirements of EN ISO 8100-1:2026 must be considered in addition to EN 81-20:2020:
Date of application for the new EU Machinery Regulation, 20 January 2027, approaching. Considering the important changes affecting lifts and escalators, manufacturers and all stakeholders must prepare their products and processes accordingly.
Ongoing standardisation work will provide means of conformity to the new and revised requirements. However, the standards may not be available on time and conformity should be achieved by other means and procedures. EU Commission is preparing necessary guide to provide a coherent method of compliance across the EU.
It is necessary for all interested parties to closely follow the development of the guides and documents through their national standardization bodies and the national lift associations to ensure that they meet the deadline with the best knowledge of requirements for conformity.
The autor is chairman of CEN/TC 10, the European standardization committee for lifts and escalators.
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