Can a product tag replace the paper manual?

What the machinery regulation allows

regulation (EU) 2023/1230 on machinery states in article 10 that the instructions for use may be provided in a digital format, and then sets out what that costs the manufacturer. The instructions must clearly describe the product model they correspond to, and three obligations follow.

Mark on the product, or where that is not possible on its packaging or in an accompanying document, how to access the digital instructions. Present them in a format the user can print, download and save on a device. Make them accessible online during the expected lifetime of the product and for at least ten years after it is placed on the market.

Two limits sit beside that. At the request of the user at the time of purchase, the manufacturer provides the instructions on paper free of charge within one month. And where the product is intended for non professional users, or can reasonably be used by them, the safety information essential for putting it into service and using it safely is provided on paper.

The same article allows the EU declaration of conformity to be reached through an internet address or a machine readable code rather than travelling with the product, with the same availability duty.

The mark is the part the tag does

The regulation asks for a mark saying how to access the instructions. A tag is one way to carry that, a printed code is another, and a printed address is a third.

The difference is what happens to someone without a working phone, which is the situation the paper manual existed for. A tag says nothing to a person who cannot tap it, so a human readable address belongs beside it rather than instead of it.

Where a tag earns its place is the object with no room for a legible address, or the one whose label will not survive its environment, and the same placement work applies as anywhere else on a product, which the placement page covers.

It has to work during a breakdown

The requirement to let the user print, download and save the instructions is written with a reason attached: so that the user can access them at all times, in particular during a breakdown of the product. The text adds that this applies even where the instructions are embedded in the software of the product itself.

Read that against a tap. A manual that exists only behind a tag and a live server fails precisely when the machine has failed, the network is down, or the site has moved. The offer to download is not a nicety in that design, it is the thing the rule is protecting.

It also settles a question that comes up on every project: what the tap opens should be a page that leads to a file, not a viewer that only works online.

Keeping it available

Ten years after placing on the market, and the expected lifetime if that is longer, is the same shape of obligation as the product passport carries, which the availability page sets out. A manufacturer who has both has one availability problem rather than two.

That is an argument for an address on a domain you control, resolved by something you run, rather than a link to whatever platform hosts the documents this year. The storage page makes the same argument for a different reason, and the conclusion is the same one.

And the rule is per product group. Machinery says this; another category says something else or says nothing, and the text covering the product is the one to read.