EU AI Act for logistics and manufacturing

Where AI enters the warehouse and the plant

• Shifts, task allocation, productivity

  Software that plans rotas, assigns missions or measures performance. When its output weighs on a decision about a worker, Article 41 of Italian Legislative Decree 179/2026 applies.

• Safety and work organisation

  Computer vision, collaborative robots, systems that set the pace of work: under Article 42 of the same decree they enter the risk assessment required by Legislative Decree 81/2008.

• AI in products and machinery

  Where an AI system is a safety component of a product covered by EU harmonisation legislation, such as machinery, the AI Act treats it as high risk.

• Traceability and quality

  Anomaly detection, quality control, demand forecasting: usually minimal risk under the AI Act, with consequences nonetheless for contracts, liability and data.

What the rules ask

Legislative Decree 179/2026, Article 41. AI-assisted decisions about staff must be taken by a natural person with effective authority, and the worker is entitled to an explanation — including when the software comes from a vendor.

Legislative Decree 179/2026, Article 42. The workplace risk assessment must cover AI systems that affect work organisation, pace or safety, with information and training for workers.

AI Act. Classification by intended purpose and role; AI literacy for staff (Article 4); for high-risk systems, human oversight (Article 14) and, for providers, a quality management system (Article 17), for which EN 18286 is a voluntary reference.

Product liability. Directive (EU) 2024/2853 applies from 9 December 2026 and covers software. For anyone integrating AI into machines, plants or products, supplier contracts and technical evidence become decisive.

Legislative Decree 160/2026. A new AI-related predicate offence under Legislative Decree 231/2001, so the company’s 231 model needs updating. Italian AI law compliance.

What Dynamics Consulting does

• System inventory

  WMS, MES, ERP, workforce management platforms: where there is AI, who supplies it, what it decides.

• Human decision procedures

  Who confirms a rota, an appraisal or a measure proposed by a system, and how that is recorded.

• Risk assessment and training

  With the employer and the health and safety officer: AI-specific risks, preventive measures, worker training.

• Contracts and liability

  What an AI vendor must deliver — documentation, logs, updates — for the company to be able to show its own diligence.

Experience in the sector

LogiTrack — end-to-end logistics traceability with RFID, AI anomaly detection and SAP integration. ERP and data platform for a multi-site manufacturing group — migration to Dynamics 365 Finance & Operations and a cloud lakehouse. Corrado Patierno is the author of Logistica Fluida.

The full service is described under AI Act consulting in Italy; for healthcare, see AI Act for healthcare and pharmacy.

Frequently asked questions

Is shift-planning software a high-risk AI system?

It can be: the AI Act lists systems used for work-related decisions, such as task allocation and performance monitoring, among high-risk uses. In any case, in Italy, if the output weighs on decisions about staff, Article 41 of Legislative Decree 179/2026 requires an effective human decision and an explanation to the worker.

Does AI belong in the warehouse risk assessment?

Yes, when an AI system affects work organisation, pace or safety: Article 42 of Legislative Decree 179/2026 requires it, together with worker training on the specific risks.

We build machines with AI features. What changes?

If the AI system is a safety component of the product, the AI Act treats it as high risk, with provider obligations including a quality management system (Article 17). Directive (EU) 2024/2853 brings software into product liability from 9 December 2026.

Is EN 18286 mandatory for a manufacturer?

No. It is a voluntary standard for the Article 17 quality management system: it gives a presumption of conformity for the requirements it covers, but it does not remove liability.

We only use off-the-shelf software. Do we still have obligations?

Yes, as a deployer: an inventory, AI literacy for staff (Article 4 of the AI Act), use in line with the vendor’s instructions and, in Italy, the Article 41 rules for decisions about staff.