Software that makes a mistake on a screen is one thing. A robot arm, a delivery vehicle or a warehouse system that makes a mistake can injure someone. That is why AI in physical products falls first under product safety law.
European Union
Machinery Regulation. Regulation (EU) 2023/1230 replaces the Machinery Directive from 20 January 2027. It addresses machinery with self-evolving behaviour and safety functions that rely on machine learning, and requires third-party conformity assessment for some of them.
AI Act. AI that is a safety component of a product covered by EU product legislation, including machinery, is high-risk. After the 2026 amendments, those obligations apply from 2 August 2028. The two sets of rules are designed to be assessed together.
Liability. Under the new Product Liability Directive, from December 2026, software in a product is itself a product, and manufacturers can be liable for defects arising from updates or cybersecurity weaknesses.
United Kingdom
Machinery is governed by the Supply of Machinery (Safety) Regulations 2008, retained from EU law, which do not yet reflect the new EU regulation. The Automated Vehicles Act 2024 creates a separate regime for self-driving vehicles. Products sold into the EU must meet the EU rules.
United States
There is no federal robotics law. Workplace safety rules, product safety regulators and state product liability law apply, along with sector rules for vehicles, drones and medical devices.
For a manufacturer, AI compliance is product compliance. The conformity file has to cover the model as well as the motor.
What to do
If you sell AI-enabled machinery into the EU, plan for the January 2027 machinery rules now, and design your technical file so it can also serve the AI Act assessment in 2028.
This article is general information on the law as at November 2026. It is not legal advice and has not been updated since that date. See the terms of use.