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.

Authors

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

Related Position Papers

Internal Market: Orgalim input to the European Commission Consultation on the proposal for a new Machinery Products Regulation “Machinery Directive Revision” [16 August 2021]

Internal market: Orgalim comments on the draft delegated act for internet-connected radio equipment and wearables [10 March 2021]

Internal Market: Orgalim comments on policy options identified after the OND Evaluation [26 February 2021]

Internal Market: Orgalim comments to the 2020 public consultation on the review of the Construction Products Regulation [23 December 2020]

Internal Market: Orgalim comments on the upcoming delegated act for internet-connected radio equipment and wearables [11 December 2020]

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 [10 December 2020]

Internal Market: Orgalim comments for the upcoming delegated act for internet-connected radio equipment and wearables [9 October 2020]

Internal Market: Orgalim comments on the final report of the impact assessment study on internet-connected radio equipment and wearable radio equipment [31 July 2020]

Internal Market: Orgalim Comments to EMC Directive Roadmap [21 February 2020]