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The AI Act reaches robots as machinery through the old Machinery Directive, and learned safety behaviour needs third party assessment from January 2027

Annex I of the AI Act lists Directive 2006/42/EC on machinery, not the 2023 Machinery Regulation. The Regulation repeals the Directive with effect from 14 January 2027 and reads references to it as references to itself, so robots reach Annex I as machinery from that date. Its Annex I Part A puts machinery and safety components with self evolving behaviour using machine learning under mandatory third party conformity assessment. Article 6(1) of the AI Act applies from 2 August 2027.

The verdict

Verified

The document exists. The ledger fetched it at its publisher and quotes it.

Key facts

What the sources say

Record ID
EAD-2026-0018
Kind
Access rule
Jurisdiction
European Union
Last verified
Added
  • AI Act Annex I, section A, item 1: Directive 2006/42/EC on machinery. The string 2023/1230 does not appear in the AI Act.
  • Machinery Regulation article 52(2): Directive 2006/42/EC is repealed with effect from 14 January 2027 and references to it are construed as references to the Regulation. Article 54: it applies from 14 January 2027.
  • Machinery Regulation Annex I Part A, items 5 and 6: safety components and machinery with fully or partially self evolving behaviour using machine learning approaches ensuring safety functions, third party assessment mandatory.
  • AI Act article 6(1): high risk where an AI system is a safety component of, or is, a product under Annex I legislation that needs third party assessment; article 113(c) applies it from 2 August 2027.
  • The Machinery Regulation never uses the word robot in its operative text; industrial robots are machinery by the article 3 definition, an assembly with a drive system and at least one moving part.

What it changes

For a robot maker collecting or buying hours

What a robot learned from its hours becomes a conformity question in Europe from 2027: a safety function that keeps learning is assessed by a third party, and the AI Act's high risk duties, including its data governance article, attach through the machinery route. The training data is not regulated as data; it is regulated as the behaviour it produces.

Sources

What this record was verified against

  1. Regulation (EU) 2024/1689, the AI Act, Official Journal textPrimary · 12 July 2024
  2. Regulation (EU) 2023/1230, the Machinery Regulation, Official Journal textPrimary · 29 June 2023

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Cite this record

Free to reuse under CC BY 4.0, with attribution. The record ID EAD-2026-0018 is permanent and is never reused.

In a sentence
According to the GAGE Embodied AI Data Ledger (as of 13 September 2026), the ai act reaches robots as machinery through the old machinery directive, and learned safety behaviour needs third party assessment from january 2027.
APA
GAGE (Global Academy of Generative-AI Education). (2026). The AI Act reaches robots as machinery through the old Machinery Directive, and learned safety behaviour needs third party assessment from January 2027. Embodied AI Data Ledger. Retrieved 13 September 2026, from https://www.gage.academy/tools/embodied-ai-data-ledger/records/EAD-2026-0018-eu-ai-act-machinery-regulation-robots-annex-i
MLA
"The AI Act reaches robots as machinery through the old Machinery Directive, and learned safety behaviour needs third party assessment from January 2027." Embodied AI Data Ledger, GAGE (Global Academy of Generative-AI Education), 13 September 2026, https://www.gage.academy/tools/embodied-ai-data-ledger/records/EAD-2026-0018-eu-ai-act-machinery-regulation-robots-annex-i.
Chicago
GAGE (Global Academy of Generative-AI Education). "The AI Act reaches robots as machinery through the old Machinery Directive, and learned safety behaviour needs third party assessment from January 2027." Embodied AI Data Ledger. Last modified 13 September 2026. https://www.gage.academy/tools/embodied-ai-data-ledger/records/EAD-2026-0018-eu-ai-act-machinery-regulation-robots-annex-i.
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