Sector
AI literacy training for manufacturing and supply chain.
Quality inspection, demand forecasting and scheduling systems ship with AI by default. The people who rely on them need to know where they go wrong, which is what your Article 4 measures are for. Machinery safety and worker monitoring bring two other parts of the Act into view.
Where AI is already in the work
- Visual quality inspection and defect detection on the line
- Demand forecasting, inventory and scheduling optimisation
- Predictive maintenance alerts on plant and equipment
- Productivity and safety monitoring of operators
- Drafting procedures, reports and supplier correspondence with a general-purpose chatbot
What the AI Act asks of you
Article 4 applies to every organisation whose staff use an AI system at work, and it has applied since 2 February 2025. Supervision and enforcement by national authorities started on 2 August 2026. The duty is to take measures that support the development of AI literacy among your staff and the people using AI on your behalf, calibrated to the tools in use, the people using them and the context. The Commission's Q&A is explicit that no certificate is required and that organisations can keep an internal record of training and guidance.
The Digital Omnibus moved machinery to Section B of Annex I, so AI that is a safety component of machinery is regulated through the Machinery Regulation, which must carry AI requirements matching the AI Act's by 2 August 2028. Annex III point 2 covers AI used as a safety component in the management and operation of critical infrastructure such as water, gas, heating or electricity supply. Most forecasting and inspection tools are in neither category, and Article 4 still covers them.
Where AI monitors and evaluates the performance and behaviour of workers, Annex III point 4 lists it as high-risk, with deployer obligations from 2 December 2027, including a duty under Article 26 to inform workers' representatives and affected workers before it goes into service.
Under Article 111(2), a high-risk system that was already in service before that date is only brought in once its design changes significantly.
Which workshop fits
Manufacturers typically take the half day for supervisors and office staff, with the full day for the engineers and planners who configure forecasting, inspection or monitoring systems and need a policy on what the human check adds.
This is general information about the EU AI Act, not legal advice. Enforcement is proportionate and case by case, and your sectoral regulator may issue guidance that applies to you.
Questions from this sector.
Is our defect-detection camera a high-risk AI system?
Not because it inspects parts. High-risk treatment attaches through the Machinery Regulation where the AI is a safety component of machinery requiring third-party conformity assessment, and under Annex III for listed uses such as worker monitoring. A quality camera usually is neither. The people who rely on it are still inside your Article 4 measures.
Does Article 4 apply to operators who never open a chatbot?
It applies to the people dealing with the operation and use of AI systems on your behalf. An operator who acts on an AI inspection or scheduling output is using the system, and the measure for that role can be brief.
We monitor productivity on the line. What does the Act say?
AI used to monitor and evaluate the performance and behaviour of workers is listed in Annex III point 4 as high-risk. Those deployer obligations apply from 2 December 2027, or once the design changes significantly for a system already in service before then, and Article 26 requires informing workers' representatives and affected workers before such a system goes into service.
Related insights.
Sectors
We did not choose the AI in our HR software. Are we still a deployer?
Yes. You are a deployer of an AI system when you use it under your authority, whether or not you chose the feature. The Article 4 duty follows the use, not the purchase decision.
Records
What record should we keep to show we met Article 4?
Keep an internal record of the training and guidance you provided: what was covered, who attended, when, and why that depth suited those roles. The Commission says no certificate is required and that organisations can keep an internal record instead.