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EU AI Act for manufacturing teams

*Engineering guidance, not legal advice. Your legal team decides how the Act applies to your products.*

Where this sector lands

Manufacturing meets the Act through two routes:

• Machinery (Art. 6(1) and Annex I, Section A). Machinery legislation is listed in Annex I. AI that is a machine's safety component, or is itself such a product, and must undergo third-party conformity assessment under that legislation, is high-risk. A vision system that stops a collaborative robot when a person enters its zone is the typical example. A defect-detection camera that rejects parts is usually not a safety component.
• Workers (Annex III point 4(b)). Systems that allocate tasks by individual behaviour or monitor and evaluate operators' performance are high-risk, and emotion recognition at work is banned by Article 5(1)(f).

Predictive maintenance, demand planning and process optimisation agents are otherwise not listed.

The logging duties that follow

• Art. 12 (providers): automatic recording of events, whether the provider is the machine builder or the integrator who places the AI function on the market.
• Art. 19 (providers): keep logs under your control for at least six months.
• Art. 26 (deployers), the plant: use per instructions, competent human oversight (Art. 26(2)), monitoring and serious-incident reporting (Art. 26(5)), logs kept for at least six months (Art. 26(6)), and for worker-facing systems, informing workers' representatives first (Art. 26(7)).

On timing: the Digital Omnibus agreement moves Annex I (product-embedded) obligations to August 2028 and Annex III ones to December 2027 (details and caveats).

What counts as evidence

After a workplace injury, the labour inspectorate and the insurer ask the same things: what the safety function detected, how fast it reacted, and whether anyone had overridden it.

Abbreviated ledger excerpt (prev, hash and sig omitted):

{"seq":1,"ts":"2026-09-22T13:02:11.204Z","type":"tool.result","data":{"name":"zone_monitor","output":{"cell":"WELD-3","person_detected":true,"distance_mm":820}}}
{"seq":2,"ts":"2026-09-22T13:02:11.231Z","type":"tool.call","data":{"name":"robot_speed","input":{"cell":"WELD-3","mode":"safe_stop"}}}
{"seq":3,"ts":"2026-09-22T13:04:40.118Z","type":"policy.decision","data":{"kind":"tool.call","action":"block","hits":[{"rule":"no-resume-while-occupied"}]}}
{"seq":4,"ts":"2026-09-22T13:05:02.577Z","type":"tool.call","data":{"name":"resume","input":{"cell":"WELD-3","supervisor":"sup_A6","zone_clear":true}}}

The blocked resume attempt matters as much as the stop. A chain shows it was not deleted after the incident.

How Vetro Attest fits

Vetro Attest accepts an OpenTelemetry GenAI trace (OTLP/JSON) or a native Vetro ledger, with nothing to install. Verification is free. For 29 USD per ledger, one-off:

• a full EU AI Act report (Markdown and HTML) mapping the run onto the logging obligations, with an explicit list of what the log cannot show;
• an ed25519 countersignature over the ledger digest, event count and timestamp, verifiable by anyone with our published public key.

A practical pattern: countersign safety-relevant runs per shift, and keep attestations with the machine's technical file and incident records.

Limits, stated plainly: the countersignature proves the log verified clean at a time, not that the safety function met its performance level. The report supports a compliance conversation; it is not a conformity assessment. Paid ledgers are deleted after 7 days, and the report and attestation are emailed to you to keep.

Next steps

• Run the free EU AI Act Art. 12/14 checker against your current setup.
• Verify a trace free, then get the countersigned report for 29 USD.
• Compare approaches: vs. WORM storage, vs. OpenTelemetry alone.

See a sample ledger verified in one click, check your own logs free or get the countersigned EU AI Act report.