ZhilianhaiMachinery Regulation Transition: Planning for January 2027
A practical transition plan
| Quarter | Action | Evidence |
|---|---|---|
| Now | Map current declarations and files to the new requirements | Gap list |
| 6 months before | Update templates, manuals and digital file structure | Revised templates |
| 3 months before | Train the team on the new documentation duties | Training record |
| From application date | New machines declared under the new rules only | Declarations and files |
Three areas that catch people out
- Digital instructions must be genuinely usable offline, with a paper option on request.
- Software updates are treated as part of the product: the update process must preserve safety.
- Machinery with AI-based safety functions carries additional obligations on data and validation.
Keep the old files
Machines placed on the market under the previous directive keep their documentation for their lifetime. Do not rewrite history: keep the original file and add a note describing the rules that applied when the machine was placed on the market.