CECE, FEM and Orgalim voice industry’s concerns on the Commission’s proposal for a machinery products regulation at the European Parliament

Around 130 people followed the webinar, including MEPs and stakeholders representing the industry, the consumers’ interests and notified bodies. The representatives of CECE, FEM and Orgalim had the chance to speak during the event to voice their concerns.

The agenda of the event was developed around three building blocks:

• High-risk machinery products & conformity assessment procedures;
• The empowerment of the Commission to establish technical specifications as substitute for harmonised standards;
• Artificial Intelligence (AI) in the proposed Machinery Products Regulation.

All stakeholders agree that the 2006 Machinery Directive has been fundamental in ensuring a high level of safety across the EU. As such, there doesn’t seem to be a safety deficit identified by the European Commission that would require mandatory third-party certification for high-risk machinery. As pointed out by Olivier Janin (FEM Secretary General), there hasn’t been identified a higher number of accidents with self-assessed machines compared with machines assessed by third parties. In other words, there doesn’t appear to be a quality issue of self-assessed machines, as the conformity assessment standards and procedures are the same. After all, non-conformity can also be found in products certified by third parties.

The proposal of the Commission to make third- party certification mandatory would have negative consequences, as it would increase costs for manufacturers and the time to market. Furthermore, it would be a disincentive for manufacturers to develop harmonised standards if they cannot use them to self-certify.  In light of these arguments, the machinery industry calls on the European Parliament to restore manufacturers’ choice to self- assess high-risk machinery as long as relevant harmonised standards are used.

The European standardization process has proved to be successful in developing harmonised standards within a consensus-based and transparent framework, with balanced representation of stakeholders from the authorities, industry and users. To address the issue of bottlenecks and delays, the public authorities and stakeholders should work together to enhance the standardisation process and make it more effective. The substitution of the standardisation process by the development of technical specifications drafted by the European Commission is not the solution. On the contrary, new harmonised standards developed in the future should eventually replace technical specifications, pointed out Stefan Nielson (Chair of the CECE Technical Commission and Global Director Laws & Regulations at Volvo Construction Equipment). Besides, the process for technical specifications has not yet been defined in the Commission’s proposal.

Moving to the parallel application of the Machinery products and the AI Regulations, these two regulations must be applied coherently in their scope, without unclear overlaps. Furthermore, the definitions and obligations of economic operators from these two regulations need to be fully aligned to ensure regulatory coherence with NLF legislation, pointed out Thomas Kraus (VDMA Machinery Directive expert and Chairman of the Orgalim Machinery Taskforce).

This stakeholder’s event was the result of a fruitful advocacy and collaboration between CECE, FEM and Orgalim with the Rapporteur Ivan Štefanec.

This week will see the release of the draft report by the Rapporteur Ivan Štefanec with the deadline for amendments set on 9 November. The official IMCO vote is supposed to take place in February/ March 2022. CECE will keep engaging with the key actors involved in the discussions about the Machinery Products Regulation.

Read more about the industry’s priorities on Machinery Products Regulation in this joint statement cosigned by CECE with other 15 industrial organisations.