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From 20 January 2027, a revised Machinery Regulation will come into force across the European Union, setting out explicit rules for autonomous and AI-controlled machines for the first time. For the logistics sector, where the use of AGVs and autonomous mobile robots is growing rapidly, the changes go beyond mere paperwork. The impact will be felt by everyone investing in automated internal transport.
Regulation (EU) 2023/1230 replaces the old Machinery Directive from 2006, which for many years provided the framework for safety requirements for machinery in Europe. The new text was published in the Official Journal of the European Union in June 2023 and will come into full effect at the start of 2027. The difference from its predecessor is significant: whereas the old directive was based on the assumption that machines strictly carry out an operator’s instructions, the regulation recognises that modern machines make decisions independently.
This has a direct impact on the growing market for automated forklift trucks and AMRs. In an increasing number of distribution centres and warehouses across the Netherlands, autonomous vehicles are operating to move pallets, pick orders or replenish stock without human intervention. These applications will soon have to demonstrably comply with stricter requirements regarding cybersecurity, safety functions and risk assessments.
What has changed compared with the old directive
The 2006 Machinery Directive had been transposed into national legislation as a European directive, leaving room for interpretation by each Member State. The new Machinery Regulation applies directly and uniformly across all 27 EU countries. This should put an end to the patchwork of national interpretations that manufacturers and importers of logistics equipment have long regarded as an obstacle.
In terms of content, a number of changes stand out. Autonomous mobile systems are assigned their own risk profile, which obliges manufacturers to take into account, during the conformity assessment, the fact that a machine can determine its own route or task in environments where people are also working. In addition, the regulation sets out cybersecurity requirements for the first time, as an autonomous vehicle that can be hacked poses a direct physical safety risk.
Logistics professionals would be well advised to study the annexes to the regulation. These set out the classification into risk categories, which determines which assessment procedure applies to a specific type of machine. For autonomous forklift trucks and mobile robots in a warehouse, this classification will in many cases be more stringent than for a traditional, manually operated forklift truck.
Staff shortages are accelerating the wave of automation
The timing of the regulation coincides with a period in which the logistics sector in the Netherlands is grappling with structural staff shortages. Vacancies for warehouse staff and forklift truck drivers have consistently been among the hardest to fill for several years now. This labour shortage is forcing companies to invest in technology that is less reliant on manual labour.
The International Federation of Robotics reports that the global installation of service robots, which includes warehouse robots, has grown significantly in recent years. In Europe in particular, demand for autonomous intralogistics systems is on the rise. Dutch distribution centres, ranging from fresh produce logistics to e-commerce fulfilment, are leading the way in this regard.
A company such as Motrac, which, as the exclusive importer of Linde Material Handling, supplies both conventional and autonomous warehouse trucks from several branches across the Netherlands, is noticing this shift in its day-to-day operations. Demand for AGVs and AMRs is growing faster there than for traditionally operated trucks. At the same time, the new European regulations are imposing stricter requirements on what will be permitted for delivery in future.
What logistics managers can do right now
Although the regulation will not come into force until January 2027, it is advisable to review your existing fleet and procurement plans now. Machinery placed on the market before that date under the old directive may remain in use. However, in the event of replacement or expansion, the new standards will apply, including the stricter conformity assessment for autonomous systems.
In practical terms, this means that procurement departments must ask suppliers whether new automated forklift trucks and AMRs are already being developed and tested in accordance with the new regulation. Documentation relating to cyber security, risk analysis and safety functions will become considerably more stringent and must be available upon delivery. This requires suppliers who not only supply hardware, but also have their technical documentation and certification in order.
For companies still at the start of their automation journey, the transition period actually presents an opportunity. By opting now for systems that already meet the new requirements, you can avoid duplicate investments. The coming months are a good time to evaluate pilot schemes involving autonomous warehouse vehicles and to ask suppliers critical questions about their roadmap towards 2027.
A European playing field with local implications
The decision to opt for a regulation rather than a directive is no coincidence. The European Commission wants to prevent Member States from applying their own interpretations, which would fragment the internal market for machinery. For a Dutch logistics service provider that purchases forklift trucks from a German manufacturer and deploys them for a Belgian client, this eliminates a great deal of legal uncertainty.
Nevertheless, questions will still arise in practice regarding the precise application. How is a hybrid situation assessed in which a truck can operate both manually and autonomously? Which authority monitors the cybersecurity requirements during the operational phase? These answers should become clearer in the coming months as national regulators publish their enforcement frameworks.
What is certain is that the regulatory burden surrounding autonomous intralogistics is increasing. That is no reason to postpone investments, but it is a reason to approach them more carefully. Those who choose equipment and partners now that are prepared for the 2027 requirements will be in a stronger position than those who have to make last-minute adjustments.
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