Machinery Regulation Annex I: High-Risk Machinery in Part A and Part B (Formerly Directive Annex IV)

For Part B, the standards or common specifications the manufacturer applies also decide whether a notified body takes part.

Annex I takes the place of Annex IV of Directive 2006/42/EC, a list of 23 points that applies until 19 January 2027 through the national transpositions. The Regulation is directly applicable from 20 January 2027, and how Annex I fits into the rest of the EU Machinery Regulation is explained on the home page.

The sections below give the 25 points by group, the three Article 25 routes, the point-by-point correspondence with Annex IV, the Article 6 rules under which the Commission can change the list, and the status of Annex I as of 12 November 2026.

What Is Annex I of the Machinery Regulation?

Annex I of Regulation (EU) 2023/1230 is the list of "categories of machinery or related products to which one of the procedures referred to in Article 25(2) and (3) shall be applied", divided into Part A and Part B.

Part A holds 6 categories and Part B holds 19 points, 25 in total. Three Part B points are split into sub-types: circular saws into points 1.1 to 1.4, band-saws into points 4.1 and 4.2, and machinery for underground working into points 12.1 and 12.2.

The sub-types do not add to the count, so Part B ends at point 19. The figure of 23 belongs to Annex IV of the Directive, not to Annex I.

A listing changes the conformity route, not the requirements. Machinery and related products not listed in Annex I follow internal production control (module A, Annex VI) only, under Article 25(4) of the Regulation, and listed and unlisted products meet the same essential health and safety requirements of Annex III.

Apart from the procedure, the other steps of Machinery Regulation compliance apply to every product, listed or not.

Why "High-Risk Machinery" Is Not a Defined Term

"High-risk machinery" is a colloquial name: Article 3 of Regulation (EU) 2023/1230 does not define it, and the act speaks of categories with "a higher risk factor" (recital 59) and of a "serious inherent potential risk" (Article 6).

The Article 6 test decides whether a category enters Annex I at all and in which part it sits. A category with a serious inherent potential risk belongs in Part B; it belongs in Part A when at least one of the four further conditions of Article 6(7) also applies.

The label "high-risk" therefore describes membership of the Annex I list, not a separate legal class with requirements of its own.

Annex I at a Glance: 6 Part A Categories and 19 Part B Points

Part A of Annex I to Regulation (EU) 2023/1230 holds 6 categories that always need a notified body, and Part B holds 19 points that may use internal production control only under the category-specific condition of Article 25(3). Table 1 sets the two parts side by side.

Part A groups transmission devices and their guards, vehicle servicing lifts, cartridge-operated impact machinery and machine-learning safety functions.

Part B groups woodworking machinery and chainsaws (points 1 to 8), presses and moulding machinery (9 to 11), underground machinery and refuse trucks (12 and 13), lifting of persons (14), safety components such as logic units (15 to 17), and ROPS and FOPS (18 and 19).

Table 2 gives short names by group; the official wording of each point is on the Part A and Part B pages.

Conformity Routes for Annex I Products under Article 25

Article 25 of Regulation (EU) 2023/1230 gives Annex I Part A products three routes, all with a notified body (module B with C, module H or module G), and Annex I Part B products the same three routes plus internal production control (module A) when the category-specific condition of Article 25(3) is met. For Part A, Article 25(2) excludes module A completely.

The Part B condition requires the product to be designed and constructed "in accordance with the harmonised standards or common specifications specific to that category of machinery or related product covering all the relevant essential health and safety requirements" (Article 25(3)).

The modules sit in annexes of the Regulation: module A in Annex VI, module B in Annex VII, module C in Annex VIII, module H in Annex IX and module G in Annex X, and each module is explained under conformity assessment under the Machinery Regulation.

Products not listed in Annex I have one route only, module A under Article 25(4), with no notified body in the procedure. The route finder below gives an indicative result for one product, with the legal basis for each answer.

From Machinery Directive Annex IV to Regulation Annex I

Annex IV of Directive 2006/42/EC lists 23 points and applies until 19 January 2027; from 20 January 2027 Annex I of Regulation (EU) 2023/1230 takes its place with 25 points, and Annex XII of the Regulation records the correspondence. Annex XII pairs each provision of Directive 2006/42/EC with its successor in the Regulation.

Nineteen Annex IV points keep their content in Part B. Points 1 to 13 keep their numbers, point 17 becomes Part B point 14, and points 19 to 23 become Part B points 15 to 19. The full Machinery Directive to Machinery Regulation changes cover every article and annex.

Two thresholds carry over unchanged. Part B point 9 covers presses, including press-brakes, for the cold working of metals with manual loading or unloading, a travel exceeding 6 mm and a speed exceeding 30 mm/s, as Annex IV point 9 did.

Part B point 14 covers devices for lifting persons, or persons and goods, with a hazard of falling from a vertical height of more than 3 m, where Annex IV point 17 reads "more than three metres".

Table 3 maps each Annex IV point of the Directive to its place in Annex I of the Regulation, following Annex XII.

What Changed: Four Points Moved to Part A and Two New Categories

Four Annex IV points of Directive 2006/42/EC moved to Part A: points 14, 15, 16 and 18 became Part A points 1 to 4 (transmission devices, their guards, vehicle servicing lifts, cartridge-operated fixing and other impact machinery).

Part A points 5 and 6 have no Directive counterpart. Point 5 covers safety components with fully or partially self-evolving behaviour using machine learning approaches ensuring safety functions; point 6 covers machinery with embedded systems of that kind that are not placed independently on the market, in respect only of those systems.

Recital 55 of the Regulation explains that this third-party assessment concerns only such self-evolving systems, not software incapable of learning or evolving. The rules for machinery with self-evolving behaviour are set out separately.

AI systems acting as safety components are also high-risk under Regulation (EU) 2024/1689.

How Annex IV Machinery Was Assessed under Article 12 of the Directive

Under Article 12(3) of Directive 2006/42/EC, Annex IV machinery built to harmonised standards covering all relevant requirements could use internal checks (Annex VIII), EC type-examination (Annex IX with Annex VIII point 3) or full quality assurance (Annex X); without such standards, only the last two applied (Article 12(4)).

The Regulation changes this in three ways. Part A points 1 to 4 lose the internal-checks option and always need a notified body. Part B keeps a module A option, but only under the Article 25(3) condition quoted in the routes section.

Module G, unit verification under Annex X of the Regulation, has no counterpart in the Directive. How the rest of the Machinery Directive 2006/42/EC works until its repeal is explained on its own page.

How the Commission Can Amend Annex I (Article 6)

Article 6(2) of Regulation (EU) 2023/1230 empowers the Commission to amend Annex I by delegated act in three ways: adding a category, withdrawing a category, or moving a category between Part A and Part B.

Article 6(2) to (6), (8) and (11) have applied since 20 July 2024, and Article 6(7) since 19 July 2023 (Article 54 of the Regulation as corrected by the corrigendum, OJ L 169, 4.7.2023, p. 35).

The delegation for Article 6(2) runs for five years from 19 July 2023 (Article 47(2), as replaced by Regulation (EU) 2026/1744). A delegated act enters into force only if the European Parliament and the Council raise no objection within two months, a period extendable by two months (Article 47(6)).

The Article 6(4) Risk Criteria and the Part A Test of Article 6(7)

Article 6(4) of Regulation (EU) 2023/1230 sets six criteria for judging whether a category has a serious inherent potential risk: (a) the nature of the hazard, (b) its severity including reversibility, (c) the number of persons affected, (d) the frequency and duration of exposure, (e) the possibilities of avoiding or limiting harm, and (f) for safety components, the likelihood of serious consequences on failure.

A category belongs in Part A when, besides that risk, at least one of the four Article 6(7) conditions listed below applies; otherwise it belongs in Part B.

• (a) Standards gap: no harmonised standards or common specifications exist for the category.
• (b) Accident record: residual risks lead to recurring serious or fatal accidents.
• (c) Wrongful application: standards are recurrently applied wrongly, and market surveillance has not fixed it.
• (d) Method uncertainty: risk assessment methods for new categories or technologies are uncertain.

These criteria concern the list, not the manufacturer's own machinery risk assessment.

Condition (d) is the basis of Part A points 5 and 6, the machine-learning safety functions. Because the four conditions are alternatives, one of them is enough to place a category in Part A.

Member State Accident Data and the Five-Year Review Cycle

Article 6(5)(d) of Regulation (EU) 2023/1230 bases any change to Annex I on accident data covering at least the preceding four years, from sources such as ICSMS, safeguard clauses, Safety Gate, the European Injury Database, Eurostat ESAW and the Machinery AdCo.

Article 6(9) requires Member States to provide that data by 20 July 2025 and every five years after that, so the next round falls due on 20 July 2030. The format is set by Commission Implementing Regulation (EU) 2024/1922 of 12 July 2024, adopted under Article 6(10) and in force since 4 August 2024.

The Commission's report under Article 53(3), with an assessment of the Annex I list, was due on 20 July 2026. The instruments adopted under the Regulation are listed under Machinery Regulation amendments.

Where Annex I Stands on 2026-11-12

As of 12 November 2026, Annex I of Regulation (EU) 2023/1230 is unchanged since adoption: the consolidated version 02023R1230-20260727 shows no amendment to it, and no delegated act under Article 6(2) has been adopted. The consolidated text of Regulation (EU) 2023/1230 still carries 6 Part A categories and 19 Part B points.

Regulation (EU) 2024/2748 and Article 3 of Regulation (EU) 2026/1744 amend the Regulation, but neither amends Annex I or Article 25. The Annex I list becomes applicable together with the rest of the Regulation.

As of 12 November 2026, no harmonised standard is cited in the Official Journal under Regulation (EU) 2023/1230.

The Directive list, Implementing Decision (EU) 2023/1586, was last amended by Implementing Decision (EU) 2026/2015 of 4 September 2026, which also repeals it with effect from 20 January 2027 (Article 2). What each harmonised standard for machinery covers is set out on the standards page.

What an Annex I Listing Does Not Decide

An Annex I listing decides the conformity route only: it does not add requirements, does not make a product machinery, and does not by itself say which notified body or which standard applies.

The requirements come from Annex III, the product category from Article 2 and the definitions of Article 3, and the route from Article 25.

Where Annex I Overlaps with Annex II

Seven points of the Annex II indicative list of safety components are also Annex I categories, paired as listed below.

• Annex II point 1 = Annex I Part A point 2
• Annex II point 2 = Annex I Part B point 15
• Annex II point 3 = Annex I Part B point 16
• Annex II point 4 = Annex I Part B point 17
• Annex II point 14 = Annex I Part B point 18
• Annex II point 15 = Annex I Part B point 19
• Annex II point 19 = Annex I Part A point 5

Annex II holds 20 points in total, and the full list of safety components under Annex II has its own page.

Annex I Lists Categories, Annex III Sets the Requirements

Annex I of Regulation (EU) 2023/1230 lists categories, while Annex III sets the essential health and safety requirements every product must meet, listed or not; in the Directive the same roles sat in Annex IV and Annex I. Annex XII of the Regulation pairs Annex I of the Directive with Annex III of the Regulation, so a Directive reference to "Annex I" points to the requirements, not to the high-risk list. The essential health and safety requirements of Annex III are explained in full.