Machinery Safety Maturity · Regulation (EU) 2023/1230
Your machinery fleet assessed against Regulation 2023/1230, with a costed action plan through to January 2027.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Machinery Safety Maturity · Regulation (EU) 2023/1230
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2023/1230 on machinery assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
It is this mechanism, one level, the level above, and the action that connects the two, that turns a finding into a trajectory.
Are modifications made to in service machinery qualified to determine whether they constitute a substantial modification?
- N1
No qualification. Modifications are carried out by maintenance or capital works teams without any review of their regulatory implications.
- N2
The subject is known to a few people in the design office. Qualification takes place on major projects, not on routine interventions.
- N3
A written rule defines the criteria for substantial modification and a checkpoint exists before works. It is applied in most cases, with exceptions for urgent works.
- N4
Every modification is reviewed and recorded, substantial cases trigger a new risk analysis and an update to the technical file, validated by an identified function.
- N5
Qualification decisions are reviewed periodically, informed by operational feedback and incidents, and criteria are adjusted and redistributed to sites with documented follow up.
Action to move from L2 to L3
Write a two page rule for qualifying modifications, with criteria and a decision tree, embed it as a mandatory checkpoint in the weekly capital works and maintenance review, and verify its application on this quarter’s interventions.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2023/1230 sets out the requirements applicable to the design, construction and placing on the market of machinery, interchangeable equipment, safety components, lifting accessories, chains and cables, removable mechanical transmission devices and partly completed machinery. It requires a documented risk analysis, compliance with essential health and safety requirements, a technical file, instructions for use, an EU declaration of conformity and CE marking. It also sets out the obligations of manufacturers, authorised representatives, importers and distributors. It replaces Directive 2006/42/EC and applies from 20 January 2027.
In practice, governance runs into simple questions that are rarely settled. Who, within the group, is a manufacturer within the meaning of the regulation when a workshop assembles a complete line or substantially modifies an existing installation? Is the technical file for each machine in the fleet easy to locate and up to date, or reconstructed on request during an inspection? Are the requirements for safety components incorporating software owned by automation engineering, by the design office, or by no one? On an extractive site, these questions arise machine by machine, on equipment that is often old and has been modified.
Two developments deserve attention. First, Annex I now sets out a category of high risk machinery subject to intervention by a notified body, whereas the directive left more room for self certification. Second, the text explicitly addresses software performing safety functions, machine learning, and updates capable of changing a machine’s behaviour after it has been placed on the market. One common confusion remains: the regulation governs placing on the market, it does not replace the obligations to use and maintain compliance that fall under occupational safety law and sector specific extractive industry directives.
A compliance audit ends with a binary finding: the machine is compliant or it is not, the file exists or it is missing. The maturity assessment answers a different question. What level of control exists over risk analysis, document management, qualification of modifications, fleet monitoring, and what specific action moves you up to the next level. This is what allows you to prioritise across sites and sequence a transformation programme through to the deadline.
Within Datamensio, the framework is ready to use and adaptable. The AI adjusts themes, questions and levels to your industrial organisation, or builds a variant from your own documents: engineering procedures, standard technical files, equipment procurement specifications.
Reference standard: Regulation (EU) 2023/1230 on machinery
The themes assessed
Scope and product qualification
Identification of machinery, partly completed machinery, safety components, lifting accessories and interchangeable equipment present or made available, applicable exclusions, treatment of used equipment.
Roles and responsibilities of economic operators
Determination of manufacturer, authorised representative, importer or distributor status, cases of on site assembly, line integration and substantial modification.
Risk analysis and reduction
Risk assessment process, reduction iterations, choice of built in protective measures, guards and devices, residual information provided to the user.
Essential health and safety requirements
Coverage of Annex III requirements, controls and stopping functions, prevention of mechanical hazards, ergonomics, dust and noise hazards, requirements specific to mobile and lifting machinery.
Safety functions, software and evolving systems
Reliability of control systems, treatment of safety software, control system cybersecurity, evolving behaviour and learning, update management.
Conformity assessment and high risk machinery
Selection of the applicable procedure, identification of Annex I categories, use of a notified body, management of attestations and harmonised standards applied.
Technical file and documentation
Compilation and retention of the technical file, EU declaration of conformity, declaration of incorporation for partly completed machinery, instructions for use, accepted digital formats, languages.
Marking, traceability and identification
CE marking, identification plate, serial numbers, contact details of economic operators, traceability of the fleet and delivered batches.
Market surveillance, non-conformities and lessons learned
Handling of detected non-conformities, corrective actions, recalls, cooperation with authorities, feeding incidents and accidents back into design.
Skills, procurement and compliance governance
Safety engineering competence, requirements imposed on suppliers, design review, steering the trajectory towards the regulation’s applicability.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Does Regulation 2023/1230 replace Directive 2006/42/EC?
Yes. It becomes applicable on 20 January 2027 and repeals the Machinery Directive. As a regulation, it applies directly in member states without national transposition, which reduces differences in interpretation between countries but effectively brings internal deadlines forward.
Does this assessment issue a certificate of conformity?
No. Datamensio measures the maturity of your practices and prepares you for the deadlines. Conformity assessment is the responsibility of the manufacturer and, for Annex I categories, of a notified body. The assessment tells you where you stand and what is missing before you get there.
How does this differ from a machinery compliance audit?
An audit rules on each piece of equipment: compliant or non compliant. The maturity assessment evaluates the processes that produce compliance: risk analysis, documentation, qualification of modifications, procurement. The two are complementary: the assessment prioritises, the audit verifies.
Are we concerned if we only purchase CE marked machinery?
Only partly. As soon as a site assembles several pieces of equipment into a line, integrates partly completed machinery, or substantially modifies an installation, it may take on manufacturer obligations. The framework includes a dedicated theme for this qualification of roles.
How long does the assessment take?
The short version takes 20 to 30 minutes to complete. The full version, run collaboratively with the design office, maintenance, HSE and procurement, typically spans one to two weeks, with most of the time spent gathering documentary evidence.
Can the framework be adapted to our equipment families?
Yes. Themes, questions and levels can be modified, and the AI can build a variant by equipment family or by site from your engineering procedures. Control of the framework remains yours.
How can several extractive sites be compared with each other?
Each site completes the same assessment, which makes scores per theme comparable across business units and over time. A cross site roadmap consolidates common gaps and avoids duplicating the same actions at every quarry.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.