Updated: 08.11.2026
In brief: From 20 January 2027 the EU Machinery Regulation (EU) 2023/1230 applies and replaces the Machinery Directive 2006/42/EC. A window with an electric actuator is considered a machine. Anyone who assembles or retrofits window and actuator therefore has manufacturer obligations; operators must run the systems safely and have them inspected regularly.
Note: This article provides an overview and is not legal advice. The text of the regulation is binding; in individual cases, trade associations, chambers of commerce or an expert can help.
What changes on 20.01.2027?
- Regulation instead of directive: It applies directly in all EU countries, without national implementing legislation.
- Digital documents: In B2B business, operating instructions may be provided digitally; on request, a paper version must be supplied within one month.
- Distributors and importers have their own obligations: before selling, they check, among other things, marking, declaration and instructions in the national language.
- Substantial modification: Anyone who subsequently modifies a machine in such a way that new risks arise is considered the manufacturer.
Who is the manufacturer of the window?
A window actuator on its own is usually partly completed machinery. Only the finished power-operated window becomes a machine. The manufacturer is therefore whoever assembles and commissions window, actuator and control – usually the window or metal fabricator or the installer. This also applies when retrofitting an actuator to an existing window.
What window fabricators and installers should do now
- Risk assessment for every power-operated window: where can people reach the window, where are there crushing and shearing points at the closing edges?
- Define protective measures: mounting out of reach, limited force and speed, operation with a view of the window, or edge protection.
- Fall protection of the sash – check it, for example with a safety stay.
- Documents of the actuators (declaration of incorporation, assembly instructions): file them with the project and hand them over to the operator.
What operators must observe
- Power-operated windows in workplaces are work equipment; the employer is responsible for their safe condition.
- According to ASR A1.6 they must be inspected regularly, as a rule annually, by a competent person.
- Older systems without fall protection or with open crushing points should be assessed at the next maintenance.
What does this mean for choosing actuators?
Plan safety in from the start: actuators on fanlights and windows out of reach, force matched to the sash instead of “as strong as possible”, and a control that closes in rain and wind. Help with selection is provided by the Window actuator calculator and the guide 10 common mistakes when choosing an actuator.
Read more: risk assessment checklist · Maintenance of window actuators · Lexikon: Declaration of incorporation, Risk assessment, ASR A1.6
Sources
- Regulation (EU) 2023/1230 on machinery, EUR-Lex
- IHK Halle-Dessau (German chamber of commerce): Maschinenverordnung tritt 2027 in Kraft
- baulinks.de (25 June 2026): Neue Maschinenverordnung verschärft Anforderungen an kraftbetätigte Fenster
Frequently asked questions
When does the new Machinery Regulation apply?
From 20 January 2027. It replaces the Machinery Directive 2006/42/EC.
Do I become the manufacturer if I retrofit a window actuator?
As a rule, yes: whoever assembles actuator and window into a power-operated window takes on the manufacturer obligations for this unit, such as the risk assessment. Clarify individual cases with a trade association or expert.
Does a power-operated window have to be inspected?
Yes. For workplaces, ASR A1.6 provides for regular inspection by a competent person, as a rule annually.
Technically reviewed by Dietmar Heiken, Sales, Vent Systems HDI GmbH, Hamburg – around 20 years of industry experience. Questions? Phone +49 40 50694631 or info@ventsystems.de
Last updated: 08.11.2026
Questions? 040 50694631 · info@ventsystems.de
