Internal Market: Orgalim comments to proposals for the revision of the Machinery Directive 2006/42/EC tabled at the Commission Working Group meeting of 9-10 November 2020

Orgalim recognises that the current economic, political and technological developments are raising questions around the Machinery Directive, leading the European Commission to look at options for a revision. We welcome the opportunity to provide comments and react to the proposals tabled by the Commission.

General Comment: Proposals to amend or extend the health and safety requirements of Annex I of the Machinery Directive should use wording which does not require the use of a particular technology or which favour the use of a particular technology.

When amending the requirements of Annex I, it is essential to take account of enforceability by market surveillance authorities. Ambiguity should not be to the detriment of economic operators who have properly carried out and documented the conformity assessment procedure. The same applies by analogy to the standardisation process and the assessment of draft standards by HAS-Consultants.

To read our comments in full, please download the document above.