Internal Market: Orgalim input to the European Commission Consultation on the proposal for a new Machinery Products Regulation “Machinery Directive Revision”

Published: 16 August 2021

Policies & Issues: Internal Market - Product Safety Legislation

Orgalim represents Europe’s technology industries, a dynamic and highly competitive sector that relies on European Union harmonisation legislation for its success. Orgalim also acts as an industry platform (our Machinery Task Force includes stakeholders from outside our membership) and adviser to the European Commission on the machinery topic. Our industries welcome the Commission’s proposal for a Regulation on machinery products (hereafter “the Regulation”), but also have a number of concerns. This input into the Commission’s consultation addresses key points for our industry.

We welcome:

  • Alignment to the New Legislative Framework (NLF) and transposition into a Regulation

  •  Digitalisation of instructions, EU Declaration of Conformity and technical documentation

We call for changes on the following points:

  • Preserve module A for Annex I machinery manufactured in accordance with harmonised standards

  • Remove the misleading description “high-risk machinery” in favour of a more neutral term and better rules for the amendment of the list in Annex I

  • Ensure coherence between the AI and Machinery Regulations for conformity assessment

  • Clarify the characteristics of substantial modification

  • Ensure essential health and safety requirements that are technology-neutral

  • Remove the Commission’s power to develop technical specifications via implementing acts instead of relying on harmonised standards

  • Extend the use of digital formats to the declaration of incorporation and assembly instructions

  • Amend provisions for entry into force and the transition period


To read the position in full, please download the document above.


Le Goff-Jedrzejowicz
Helena Le Goff-Jedrzejowicz
Adviser - Internal Market

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