Digital Twins, Retrofits and the Machinery Regulation 2023/1230
The shift in machine tooling is accelerating: the focus has moved from hardware sales to outcome-based contracts and continuous operational optimization. This transition is rests on the promise of the Digital Twin but regulatory changes that redefine liability could slow down growth. For OEMs and end-users, understanding both the technical and legal implications is key for mitigating risk and maximizing competitive advantage.
PART I - THE DIGITAL TWIN: ENABLING PERFORMANCE AND OUTCOME
A Digital Twin (DT) is a continuously synchronized, real-time virtual model of a physical machine or process, driven by live sensor data and simulation capabilities. It is the engine for first-time right engineering and advanced servitization strategies.
Core Applications and Value
Virtual Commissioning: DTs allow comprehensive testing and optimization of control logic and toolpaths in a simulated environment, streamlining the design-to-production workflow before any capital expenditure. For complex lines, the DT is used to model, test, and validate multi-machine processes, minimizing commissioning time, simulating line throughput, and ensuring deterministic material flow across various workcells.
Return on Investment: virtually verifiable performance metrics allow OEMs to guarantee service level agreements metrics beforehand. Integrated production chains benefit the most by reduces bottlenecks, increases in OEE and deliver significant reductions in maintenance costs.
Real-Time Safety: digital twins can monitor operations to provide continuous collision prevention during operation, catching errors missed during offline programming or manual movement.
Technical and Business Challenges:
While the value proposition is clear, adoption faces specific friction points:
Standardization: A lack of universal DT reference frameworks and standardized procedures (outside of specific protocols like MTConnect and OPC UA) remains an obstacle, particularly for Small and Medium-sized Manufacturers (SMMs).
Data Security: The connectivity required for real-time DTs introduces critical cybersecurity risks, including Distributed Denial of Service (DDoS) attacks aimed at flooding cloud APIs or plant gateways to halt real-time decision-making.
Integration Cost: Establishing a robust, edge-enabled computing infrastructure for real-time analytics is essential but complex, often leading to a high Total Cost of Operation (TCO) if not managed with specialized external partnership.
PART II - REGULATION (EU) 2023/1230: THE DIGITAL COMPLIANCE MANDATE
The new EU Machinery Regulation (EU) 2023/1230, applicable from January 20, 2027, significantly broadens compliance and liability, particularly concerning post-market modifications.
Re-defining "Substantial Modification:
The Regulation defines a 'substantial modification' as a change made to machinery, by physical or digital means, after it has been placed on the market, which was not foreseen by the original manufacturer.
Specifically, this modification is only deemed substantial if it affects the machine's safety by creating a new hazard or increasing an existing risk that requires one of the following:
- The addition of guards or protective devices necessitating the modification of the existing safety control system. The adoption of additional protective measures to ensure the machine's stability or mechanical strength.
- If the increased risk can be eliminated or minimized by simple safeguards without changing the safety control system, the modification is non-substantial.
The Liability Shift from OEM to End-User:
This definition has direct consequences for digital retrofits:
Liability Transfer: Any natural or legal person, whether an OEM applying a remote performance upgrade or an end-user integrating a new digital control system, who performs a substantial modification is considered as a manufacturer for the purposes of the regulation.
Re-Certification Obligation: This new manufacturer must assume the obligations of Article 10, which includes performing a new conformity assessment, ensuring full technical documentation, and applying a new CE marking for the affected part or the entire machine. Even post-market software or firmware updates can trigger this reassessment if they impact safety functions.
OUR SOLUTIONS FOR THE MACHINE TOOLING INDUSTRY
W12 Digital Twin: the world’s first fully simulated photoelectric sensor
The next generation of our W12 launches with a fully simulated digital twin, at no charge. The digital twin contains a description of all properties and behavior of the sensor including optical properties, light path and optical scatter, optical properties of the reflector and return signal simulation. This allows manufacturers to test how well objects will perform in their production environment.
Navigating safety regulations
We have several (free) resources available on our website [here].Should you have any questions, you can request support from our safety and regulation experts at the bottom of this page.
Our sensors for the machine tooling industry
- SEC110 for remote monitoring
- IMX for reducing tolerance requirements
- Weld-safe inductive sensors
