Asansörler İçin Yeni Bir Dönem: Makine Yönetmeliği (AB) 2023/1230

20 Ocak 2027'de yürürlüğe girecek olan yönetmelik; kapsamı, "EHSR köprüsü" ve asansör sektörü için neleri değiştiriyor?

by Süleyman Özcan

For decades, the European Union's machinery safety framework operated under the Machinery Directive — in its current form, 2006/42/EC. On January 20, 2027, that chapter closes: It will be replaced by the directly applicable new Machinery Regulation (EU) 2023/1230. At first glance, this may look like a development of only marginal interest to the lift industry, but the reality is far closer to home. The new safety requirements the regulation introduces affect not only the platform and goods lifts that fall under machinery legislation, but also the conventional building lifts built to EN 81-20. This article looks closely at what the regulation is, where it captures the lift sector and what it changes for design and conformity.

From Directive to Regulation: A Quiet but Fundamental Shift

The first dimension of the change is legal form. A “directive” is a framework each Member State transposes into national law, which can create differences in interpretation and timing between countries. A “regulation,” by contrast, applies directly and with the same text across the entire EU; no national transposition is required. Therefore, the transition will be uniform and fast. For a manufacturer placing products on – or exporting to – the EU market, the text is binding word for word, and national implementing rules are expected to align with it.

The second dimension is the timeline. The regulation was published on June 29, 2023, and its main obligations apply from January 20, 2027. On the same day, the Machinery Directive 2006/42/EC will be repealed. Critically, there is no gradual “soft transition”. Products placed on the market under the old Directive before January 20, 2027, may remain on the market, but every new product placed on the market after that date must comply with the regulation. Given the length of design and production cycles in the lift business, starting preparation during 2026 is a realistic plan.

Scope: Which Lift Falls Under Which Legislation?

The decisive distinction is the long-familiar $0.15\text{ m/s}$ speed threshold. Passenger or goods/passenger lifts that permanently serve buildings, move between rigid guides and travel faster than $0.15\text{ m/s}$ fall under the Lifts Directive 2014/33/EU and take their CE marking from it. Conversely, lifts traveling at $0.15\text{ m/s}$ or slower and products outside the building/lift definition – vertical lifting platforms and home lifts (EN 81-41), stairlifts (EN 81-40), goods and service lifts that persons cannot enter (EN 81-31), small goods lifts/dumbwaiters (EN 81-3) and escalators (EN 115-1) – fall directly under the Machinery Regulation.

The regulation sets up this distinction not by listing lifts among its exclusions, but through the “more specific legislation” principle (Article 9): where a product's risks are covered by EU legislation more specific than the regulation, the regulation does not apply to that extent. For building lifts, that “more specific legislation” is the Lifts Directive. And it is precisely here that the mechanism the sector must not overlook comes into play.

Key Point: The EHSR Bridge

The common view that “building lifts stay under the Lifts Directive so the Machinery Regulation doesn't concern us” is widespread, but incomplete. The Lifts Directive 2014/33/EU's own Annex I (Preliminary Remarks §1.1) requires that, for hazards not addressed in that Annex, the essential health and safety requirements (EHSRs) of the machinery legislation apply. In other words, the Lifts Directive has internalized the machinery EHSRs for whatever it does not itself cover.

When the Machinery Directive is repealed on January 20, 2027, the regulation's transitional rule (Article 51) applies: “References to Directive 2006/42/EC shall be construed as references to this Regulation.” That reference in the Lifts Directive now points to Annex III of the Machinery Regulation.

The output of the chain is clear: The new machinery EHSRs absent from the Lifts Directive’s Annex I also become applicable to EN 81-20 lifts and to lift safety components. An EN 81-20 lift declared after January 20, 2027, must now also meet the regulation’s new essential requirements.

This bridge has an important practical consequence: Even though the route by which the CE marking is obtained (the Lifts Directive) does not change, the regulation’s new requirements affect all three product groups – conventional EN 81-20 lifts, low-speed/home lifts and platforms, and goods lifts within machinery scope – in terms of design and conformity.

What the Regulation Introduces

So what are these new requirements? The regulation’s most prominent innovations for lifts are largely tied to the digitalization and connectivity of machinery; the mechanical safety rules (locking, ropes, guidance) continue to be covered in detail by the existing EN 81 standards. The genuinely new burden lies in the headings below.

Cybersecurity and connected systems. For the first time, the regulation introduces an explicit cybersecurity requirement (Annex III, 1.1.9). Connecting a lift or safety component to

another device or to a remote-access system must not create a hazardous situation; software and data critical to conformity must be protected against intentional or accidental corruption. As remote monitoring, cloud-connected controllers and predictive maintenance spread, this will become a natural part of lift design.

Control systems, software and parameter security. The control system must be resilient to external influences and to malicious third-party attempts that could affect safety (1.2.1). Settings and rules relating to safety functions must not be alterable in a way that could create a hazard. In addition, a log of safety-software versions and interventions uploaded after placing a product on the market must be retained for five years to demonstrate conformity.

AI and self-evolving systems. Systems that learn, change their behavior or operate with varying levels of autonomy must not go beyond their defined task and movement space, must not take decisions that compromise safety and must always allow corrective intervention. Data on safety-related decision-making is retained for one year. Systems whose safety functions self-evolve through machine learning are additionally subject to mandatory NB assessment.

Power supply and communication interruptions. Interruption, restoration after interruption or fluctuation of the power supply or communication network must not lead to a hazardous situation (1.2.6). In particular, the lift must not start unexpectedly, safety parameters must not change in an uncontrolled way and a stop command already given must not be prevented.

Digital documentation and substantial modification. Instructions for use and the EU declaration of conformity may now be provided digitally. However, a free paper copy within one month (on request) and essential safety information on paper for consumer products (home lifts) remain mandatory. The regulation also defines “substantial modification” for the first time (Article 3(16)): Whoever makes a post-market change that creates a new hazard or increases a risk assumes the obligations of a manufacturer. This calls for modernization and refurbishment work to be reconsidered in terms of contracts and liability.

Certificates and Standards: EN 81-20 Alone Is Not Enough

So what happens to existing certificates? Conformity-assessment certificates issued before January 20, 2027, do not automatically become invalid. But, because they cover only the existing requirements, they do not cover the regulation’s new or modified EHSRs. Therefore, for lifts and safety components whose declaration of conformity is issued after January 20, 2027, an additional assessment addressing only the new requirements may be necessary. Assessments for unchanged matters already covered need not be repeated; the smart approach is to review the portfolio against “Does this cover the new EHSRs?” and work only on the delta.

On the standards side, EN 81-20:2020 will continue to be used. However, it does not fully cover the new requirements.

The gap is expected to be closed by standards such as EN ISO 8100-1:2026 for passenger and goods lifts and EN ISO 8102-20:2022 for the cybersecurity of lift control systems. If these are later published as harmonized standards, products designed to them will be presumed to conform to the relevant EHSRs. Tracking the publication status of standards should, therefore, be an integral part of the compliance strategy.

A Final Note: Escalators and Moving Walks

Unlike building lifts, escalators and moving walks are not covered by the Lifts Directive at all and fall entirely and directly under the Machinery Regulation, so there is no “bridge” to reason about. Their detailed mechanical and functional safety is covered by EN 115-1:2017 (Module A, no mandatory NB), while the same new digital EHSRs – cybersecurity, control and parameter security, and resilience to power and communication interruptions – apply directly. Two practical points stand out: Escalator modernization (drive, step chain or controller) falls within the substantial-modification regime, and because escalators run continuously in public spaces, connectivity and interruption resilience make these requirements especially relevant.

Conclusion: Preparing for 2027 Starts Today

The Machinery Regulation (EU) 2023/1230 brings a more far-reaching transformation to the lift industry than it might appear. The key message is that the innovations are not confined to platform and goods lifts within machinery scope; through the EHSR bridge they reach EN 81-20 lifts, as well.

Cybersecurity, control and parameter security, AI and power/ communication interruptions place digital safety, alongside mechanical safety, as a permanent design criterion.

The right reflex for the sector is not to wait but to prepare: Label the product and certificate portfolio by regulatory route, run a gap analysis against the new EHSRs, put cybersecurity and logging infrastructure in place for connected products and plan the transition to the new standards. 2027 may seem distant; but given the design life of a lift, this journey should begin today.

Kısaca
Application: January 20, 2027; the Machinery Directive 2006/42/EC is repealed the same day.
EN 81-20 lifts remain under the Lifts Directive, but the new machinery EHSRs apply to them, too, via the Annex I §1.1 bridge.
New topics: cybersecurity (1.1.9), control/parameter security + 5-year log (1.2.1), AI + 1-year data, power/communication interruption (1.2.6), digital documentation, substantial modification.
Escalators and moving walks fall entirely under the regulation (EN 115-1, Module A); modernization triggers the substantial-modification regime.
EN 81-20:2020 is not enough; EN ISO 8100-1:2026 and EN ISO 8102-20:2022 will be the references.