The Machinery Regulation from 20 January 2027: when a software update makes you the manufacturer
On 20 January 2027 the Machinery Directive is repealed and Regulation (EU) 2023/1230 applies with no transition period. Article 3(3) counts software expressly as a safety component for the first time, and under Article 18 anyone making a substantial modification is treated as the manufacturer. Yet two sub-paragraphs in Article 3(16) keep the great majority of updates outside that rule.