Position Papers

Orgalim, along with a wide coalition of European industry stakeholders, urges the EU institutions to recommit to the Single Market as the motor of the twin transitions and the bedrock of European citizenship.

As Europe marks the 30th anniversary of the Single Market this year, Orgalim joins the celebrations and contributes an agenda for strengthening it over the next 30 years. Alongside this agenda, we share the views of leading European industrialists at the forefront of the net zero industry transformation on the internal market problems they encounter and what can be done to fix them.

Orgalim, the voice of Europe’s Technology Industries, would like to thank the European Commission for the opportunity to provide an opinion on the amendment of Annex III on the method of measurement of airborne noise emitted by equipment for use outdoors to adapt it to technical progress.

Orgalim is fully committed to maintaining the current market practice. We believe that an enhanced option 3 would be the most effective solution to address legal clarity for the PED: introducing a provision in the Machinery Products Regulation that would modify the PED. As a fall-back option, if the enhanced Option 3 is not feasible, we could accept Option 2, provided that the new guideline is adopted before the deletion of the notes to the current PED Guideline C-13.

Today, when harmonised standards cover all relevant essential health and safety requirements, manufacturers of so-called ‘high-risk’ machinery can either self-assess conformity or use a third party (known as a ‘Notified Body’) to do so. The proposed new Machinery Regulation removes the self-certification possibility, making third party certification mandatory for all machinery products listed in Annex I. However, the supporting arguments in the European Commission Impact Assessment mainly rely on subjective assumptions not confirmed by any data, and an incomplete measurement of the effects. The proposal is therefore unjustified and disproportionate, as demonstrated below.