Proposal for a Regulation of the European Parliament and of the Council on Machinery Product
Introduction: Revision of the Machinery Directive
CECIMO, representing the machine tool industry and related manufacturing technologies, welcomes the opportunity to share its position on the European Commission’s proposal for a Regulation on Machinery Products – hereafter referred to as the “Regulation”. The current Machinery Directive 2006/42/EC is the core legislation regulating the mechanical engineering industry, and in our view, it is a sound piece of legislation whose revision should be characterized by continuity rather than revolutionary changes. In the context of the ongoing revision of the Machinery Directive, we had expressed in a previous position paper our great satisfaction with the text, which represented an example of successful European Union legislation on harmonization, providing a high level of safety and ensuring the free flow of goods within the Single Market.
Therefore, it is important for our sector that the future legislative framework continues to support harmonization within the Single Market and the development of standards to promote innovation. In this regard, CECIMO has actively engaged in various policy discussions with the aim of coordinating actions and exchanging views with other European Associations on the Commission’s Machinery Regulation Proposal. Throughout this process, we have identified a series of major threats in the draft Regulation, which could potentially create significant hurdles and lead to additional burdens and costs for machine tool manufacturers.
Definition of High-Risk Machinery
In our view, the current definition of “High-Risk Machinery Products” outlined in the draft Regulation risks creating confusion and could negatively impact European machine tool manufacturers. The definition suggests that the machines covered under Article 5 and listed in Annex I, which also include some types of machine tools (Most importantly machine presses), would pose a significant health and safety risk during use. Nevertheless, we contest such definition, since the existing legislation already forbids the sale of machinery products that pose a high risk. In fact, according to the current legal provisions, which have been successfully applied in practice since 1 January 1993, only machines whose risks have been eliminated or minimized to the lowest possible level may be marketed.
Henceforth, we reject the concept that certain machine tools would be labelled “High-Risk” under the draft Regulation, as this would be misleading for customers and potentially damaging to the reputation of European manufacturers. For this reason, we advocate for a clearer definition of the machinery products that would be covered by Article 5, especially considering that the Commission will have the power to amend Annex I on the basis of technical progress. In this regard, the Commission will need to establish clear criteria in order to better understand the process by which new machinery types will be added to Annex I, while fostering transparency and enhancing stakeholder involvement in this process....