Orgalim comments on the upcoming Impact Assessment of the Machinery Directive

Published: 8 February 2019

Policies & Issues: Internal Market - Product Safety Legislation

Representing the European technology companies driving the digital transformation of industry and society, Orgalim is certain that artificial intelligence (AI) will be a central pillar of Europe’s future competitiveness. Many of the firms we represent are at the leading edge globally in the development of AI applications integrated in consumer and industrial products (’embedded’ AI), and embedded AI is already widely used across our industries to deliver efficiency gains along the value chain. More broadly, embedded AI is enabling technology solutions to critical societal challenges – from climate change and the energy transition to the future of mobility, an ageing society and security in the digital age.

Although AI has been deployed safely in manufacturing for decades, the rapid pace of technological evolution in recent years has prompted questions regarding the EU legal framework. Against this background, the European Commission has initiated an evaluation of the Machinery Directive (MD) to assess whether it remains fit for purpose in addressing machinery incorporating new technologies such as AI. The MD is a core piece of legislation for our industries, ensuring a high level of safety while providing legal stability to our companies. Given the importance of a stable and predictable legal framework for attracting investment into key future tech like AI, we believe it will be crucial to pursue a prudent approach to regulation in this arena.

As such, we welcome the publication of the Commission’s initial evaluation of the MD, which states that this important piece of legislation remains fit for purpose – primarily thanks to the structure of the Directive and its technology-neutral essential health and safety requirements. Manufacturers can demonstrate compliance with Annex I of the Directive by making use of more than 800 existing harmonised standards, which represent the technological state of the art. Furthermore, our industry continues to actively contribute its experience and technical expertise to the drafting of standards to cover new technologies.

As a further step in the evaluation of the MD, the Commission will perform an impact assessment focusing on new technologies, with the aim of analysing whether the Directive can continue in the years to come to guarantee the placing on the market of safe machines and to ensure that users and consumers trust these machines, even when they integrate embedded new technologies.

As the current MD has performed well, increased occupational health and safety and continues to meet its objectives for both ensuring the placement on the market of safe machines (including those that embed new technologies) and establishing a high level of trust in these machines among users and consumers, Orgalim is strongly recommending that this piece of legislation should not be updated in the near future.

In this position paper, we take a closer look at the definition of the ‘narrow’ artificial intelligence and how this technology is used in our industries today. We then outline in detail how the current Annex 1 of the MD continues to meet its objectives regarding safety and trust, whether or not a piece of machinery incorporates AI elements.

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Eleonora Piccinni
Manager - Technical Regulation

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