FEM Position Paper on the Proposal for a Machinery Regulation
The Machinery Directive is arguably the single most important piece of legislation for our manufacturers. Since its adoption, it has been an effective and successful internal market legislation. Not only has it provided the highest level of machinery safety in the world, but it has also enabled the material handling industry to continue innovating, thriving and taking the lead in many segments.
In this context, our industry’s very first priority is to ensure that the future Regulation maintains such a balance between safety and innovation whilst offering the necessary predictability for manufacturers and users alike.
Whilst FEM welcomes the increased uniformity resulting from the conversion into a Regulation and the flexibility offered by digital documentation, some other aspects of the Commission’s proposal are extremely worrying.
FEM fundamentally disagrees with the mandatory third party certification for high-risk machinery – an obligation that is unjustified and disproportionate in the absence of any identified safety need nor gains of third-party certification compared to self-assessment.
As the Machinery proposal was released together with the AI package, we call for the highest level of coordination in order to avoid contradicting or overlapping requirements between the two pieces of legislation that are connected.
Moreover, the Commission empowerment to adopt technical specifications via implementing acts is undermining the standardisation process, which ought to remain industry-driven.
Finally, some of the new essential health and safety requirements related to emerging technologies would be better addressed through dedicated horizontal legislation (cybersecurity) or standards, in particular to ensure technology neutrality.
Tavola di concordanza estesa Direttiva/Regolamento Macchine
Direttiva macchine 2006/42/CE
Direttiva macchine 2021: la proposta di revisione