Comparison
EU Rules on Digital Manuals Compared
The Short Answer
Digital Is Usually Allowed. The Conditions Differ.
EU product law has moved toward electronic instructions, but not in one voice. Some rules allow a digital manual and owe paper on request, some allow it with no paper clause, one requires a permanent web copy, and one treats the digital copy as an extra. The deadlines, retention periods, and application dates differ as well.
The table below sets out seven rules, read on the Publications Office text on 4 November 2026. It covers instructions and the information that goes with them, not every labelling or documentation duty in each act. It is a reading aid, not legal advice; confirm what applies to your products with your conformity assessment advisers. For the wider question of which legal duties apply to a manual at all, see user manual legal requirements.
The Comparison
Seven Rules, Five Questions
| Rule | Digital instructions allowed? | Paper on request | Language and accessibility | Availability and duration | Applies from |
|---|---|---|---|---|---|
| Machinery Regulation (EU) 2023/1230 | Yes. Article 10(7): the instructions "may be provided in a digital format", with the access route marked on the machine, its packaging, or an accompanying document. | Free of charge, within one month, if the user asks at the time of purchase. Safety information essential for putting into service and safe use must be on paper for machinery that non-professional users can foreseeably use (Article 10(7)). | A language users can easily understand, as determined by the Member State; clear, understandable, legible (Article 10(7)). No accessibility standard named. | Online during the expected lifetime of the machinery and at least 10 years after placing on the market. Must be printable, downloadable, and saveable to a device (Article 10(7)(b), (c)). | 20 January 2027 (Article 54, as corrected) |
| Cyber Resilience Act (EU) 2024/2847 | Yes. Article 13(18): the Annex II information and instructions accompany the product "in paper or electronic form". | Not addressed. Article 13(18) lets the manufacturer pick either form and has no request mechanism. | A language easily understood by users and market surveillance authorities; clear, understandable, intelligible, legible. If online, "accessible, user-friendly" (Article 13(18)). | At the disposal of users and authorities for at least 10 years after placing on the market or for the support period, whichever is longer; the same period applies to online copies (Article 13(18)). | 11 December 2027 (Article 71(2)) |
| Batteries Regulation (EU) 2023/1542 | Online is required. Article 11(1): products incorporating portable batteries are accompanied by instructions and safety information on use, removal, and replacement, made available online. | Not addressed. The paragraph requires an accompanying set plus a website copy and does not say which form the accompanying set takes. | "In an easily understandable way for end-users" (Article 11(1)). No language rule in that paragraph. | "Permanently online, on a publicly available website" (Article 11(1)). No year count. | 18 February 2027 (Article 96(2)(a)) |
| Construction Products Regulation (EU) 2024/3110 | Yes. Article 91(2): information obligations may be met by electronic means, in a commonly readable format that lets the recipient download and print. | Free of charge if the end-user asks at the time of purchase (Article 91(2)). No delivery deadline is stated. | A language determined by the Member State concerned or, if none is determined, one users can easily understand (Article 22(6)). Content set by Annex IV. No accessibility standard named. | Not addressed for instructions. Where the digital product passport obligation is established, documents can be provided through it (Article 91(2), Article 22(7)). | 8 January 2026 (Article 96); Article 9 and Annex IV from 7 January 2025 |
| eIFU Regulation (EU) 2021/2226 (medical devices), as amended by (EU) 2025/1234 | Yes, for devices intended for use by professional users, on conditions including a documented risk assessment (Articles 3(1), 4, 5). Where lay use is reasonably foreseeable, the lay instructions must be on paper (Article 3(2)). | No additional cost, within the period in the risk assessment and at the latest 7 calendar days after a request, or at delivery if requested at order (Article 5(3)). | On the website, in an official Union language determined by the Member State where the device is made available (Article 5(11)). Readable with freely available software (Article 7(2)(a)). Accessibility not addressed. | 10 years after the last device is placed on the market and at least 2 years after the last expiry date (devices with an expiry date, except implantables); 15 years for the rest (Article 5(9), (10)). Earlier versions on the website, or on request if obsolete (Article 5(13)). | In force from 4 January 2022; amendments in force from 16 July 2025 |
| AI Act (EU) 2024/1689, Article 13 | Yes. Article 13(2): high-risk systems are accompanied by instructions for use "in an appropriate digital format or otherwise". | Not addressed. | "Concise, complete, correct and clear" and "relevant, accessible and comprehensible to deployers" (Article 13(2)). No language is named. | Not addressed in Article 13. The 10-year keeping duty in Article 18(1) names technical documentation, not instructions for use. | 2 December 2027 (Annex III systems) and 2 August 2028 (Annex I systems), Article 113 as amended by Regulation (EU) 2026/1744 |
| General Product Safety Regulation (EU) 2023/988 | As an addition only. Article 9(7) requires clear instructions and safety information to accompany the product; Article 21 lets operators "additionally" offer them digitally, clearly visible on the product, packaging, or an accompanying document. | Not addressed. The digital copy is additional, so the accompanying instructions remain. | A language consumers easily understand, as determined by the Member State (Article 9(7)). The digital copy must also be available in accessible formats for persons with disabilities (Article 21). | Not addressed for instructions. Article 9(7) does not apply where the product can be used safely and as intended without instructions. Online offers must show warnings and safety information (Article 19(d)). | 13 December 2024 (Article 52) |
"Not addressed" means the article cited was read and is silent on the point; other provisions of the same act, or national law, may still apply. The Machinery Regulation's published text said 14 January 2027; a corrigendum in the Official Journal of 4 July 2023 corrected it to 20 January 2027.
Patterns
Four Ways the Rules Treat Digital
- Digital, with a paper fallback
- The Machinery Regulation, the Construction Products Regulation, and the eIFU Regulation all permit digital delivery and give the user a route back to paper. They differ on the clock: one month, no stated deadline, or 7 calendar days.
- Digital permitted, no paper clause
- The Cyber Resilience Act says "paper or electronic form" and the AI Act says "an appropriate digital format or otherwise". Neither sets a request mechanism. Both put the weight on content, clarity, and (for the CRA) retention.
- Online required
- The Batteries Regulation does not treat the web as optional. For products with portable batteries, the removal and replacement instructions have to sit permanently on a public website.
- Digital as a supplement
- Under the General Product Safety Regulation, the digital copy comes in addition to the instructions that accompany the product. It does not replace them.
Dates
The Order Things Start to Apply
Already applying: the General Product Safety Regulation (13 December 2024), the eIFU Regulation as amended (July 2025), and the Construction Products Regulation (8 January 2026). Next come the Machinery Regulation on 20 January 2027 and Article 11 of the Batteries Regulation on 18 February 2027. The Cyber Resilience Act applies from 11 December 2027, although its Article 14 reporting duties started on 11 September 2026. For what each one asks of the manual, see our briefings on the battery instructions and QR code and the Cyber Resilience Act user information. Separate from all of these, the Product Liability Directive applies to products placed on the market after 9 December 2026 and lists instructions as a factor in whether a product is defective.
The AI Act's high-risk dates moved. Regulation (EU) 2026/1744 replaced Article 113(c) so that Chapter III Sections 1 to 3, which include Article 13, apply from 2 December 2027 for Annex III systems and 2 August 2028 for systems under Article 6(1) and Annex I. The same Regulation moved the Machinery Regulation into Section B of Annex I. For Section B products, Article 2(2) of the AI Act, as replaced, applies only Article 6(1), Article 60a, and Articles 102 to 112; AI requirements reach machinery through delegated acts amending Annex III to the Machinery Regulation, which are to apply by 2 August 2028. For product-level detail on the machinery rule, see our briefing on Article 10(7). For what Article 13(3) requires inside the instructions, see AI Act instructions for use.
What It Means
One Source, Several Delivery Rules
Read side by side, the rules share more than they differ. Most want the instructions tied to the right product model, reachable by a stated route, readable in a language the market determines, and kept for a defined period. A superseded set has to stay reachable where the retention period runs from the placing date, which is the same discipline as effective-dated publishing. Where paper is owed on request, someone has to be able to print the correct revision and send it inside the deadline, and content written once and published from a single source keeps the paper and digital copies identical.
The medical-device version of this, with its seven-day clock and risk assessment, is covered in our guide to eIFU. The consumer-products rule, the General Product Safety Regulation, has its own explainer on GPSR instructions and safety information. On content, IEC/IEEE 82079-1 is the international standard for preparing instructions for use, and warnings, cautions, and notes covers how safety content holds up once the format changes. For the separate accessibility regime, see how the European Accessibility Act reached manuals and EN 301 549 V4.1.1.
FAQ
Questions We Hear
Can instructions be digital only under EU rules?
It depends on the rule. The Cyber Resilience Act (Article 13(18)) and the AI Act (Article 13(2)) allow digital delivery without a paper-on-request clause. The Machinery Regulation (Article 10(7)), the Construction Products Regulation (Article 91(2)), and the eIFU Regulation (Article 5(3)) allow digital but owe paper on request. Under the General Product Safety Regulation (Article 21), a digital copy is additional to the accompanying instructions.
Which of these rules set a deadline for supplying paper?
Two do. The Machinery Regulation says within one month, for a request made at the time of purchase (Article 10(7)). The eIFU Regulation says no later than 7 calendar days after a request, or at delivery if requested at order (Article 5(3)). The Construction Products Regulation requires free paper if requested at the time of purchase (Article 91(2)) and states no deadline.
How long do digital instructions have to stay available?
The Machinery Regulation: the machine's expected lifetime and at least 10 years after placing on the market. The Cyber Resilience Act: at least 10 years or the support period, whichever is longer. The eIFU Regulation: 10 or 15 years depending on the device. The Batteries Regulation says permanently online and gives no year count. The AI Act, the Construction Products Regulation, and the GPSR set no period for the instructions themselves.
Can one product fall under more than one of these rules?
Yes. A connected machine with a portable battery can sit under the Machinery Regulation, the Cyber Resilience Act, and the Batteries Regulation at once, each with its own delivery conditions and dates. Read each text for its scope; this comparison is a reading aid, not legal advice, and your conformity assessment advisers should confirm which apply.
Do these rules require accessible digital instructions?
Mostly they use general words. The CRA asks for online instructions that are "accessible, user-friendly", the AI Act for information that is "accessible and comprehensible", and the GPSR for accessible formats for persons with disabilities in the digital copy. None of the seven names a technical accessibility standard in the articles compared here. The European Accessibility Act is a separate regime for a different set of products and services.
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