Approval and market surveillance of non-road mobile machinery circulating on public roads

Dear Madam, dear Sir, Please below some feedback from TÜV Verband and other Technical Services. The proposed EU-Commission's Regulation to streamline the use of non-road mobile machinery on public roads is welcomed by TÜV Verband, DEKRA, SGS and GTÜ.

Copa-Cogeca welcomes the commissions initiative: COM(2023) 178, for EU type-approval for NRMM (non-road mobile machinery). The preliminary work has been followed closely by Copa-Cogeca in the three NRMM workshops held since 2019. 1. Overall comments to the new regulation Copa-Cogeca welcome common European EU-type approval on NRMM.

EGMF, the European Garden Machinery Federation, welcomes the European Commission proposal on the road approval of non-road mobile machinery. We believe that this legislation is an effective contribution to further deepen the Single Market, by harmonising road circulation requirements for mobile machinery.

The National Federation of Public Works (FNTP) is not in favour of limiting the registration of non-road mobile machinery. Mobile machinery operates only exceptionally on public roads and at very low speed. It is therefore irrelevant that the machinery is registered, with all the constraints that this would entail (insurance, road/administrative constraints).

Filed in French · English published by the European Commission

CEMA, representing the agricultural machinery industry welcomes the initiative of the harmonisation of technical requirements in Europe for road circulation of non-road mobile machinery. It has been a difficult exercise which is reflected in the fact that the file has been brought on and off to the European level for discussion for the past 20 years.

CEETTAR represents the interests of agriculture, rural and forestry contactors in Europe. CEETTAR welcomes the harmonisation proposal, which will make trade of machinery, including for second hand machinery, easier and facilitate the cross border provision of services for contractors. Beyond market surveillance, two additional subjects deserve to be broached.

Climmar welcomes the idea with harmonized EU type approval for all sorts of vehicles, that every member state are obliged to let drive on their public roads without any further requirements, - except for local limitations decided by local circumstances like as example bridges, tunnels etc.

Dear Madam, dear Sir, Please below some feedback from the land-based contractors' association. Land-based contractors do not feel any urgent need in a harmonisation of mobile machinery circulation requirements. They have adapted their business to the non-harmonised situation.

As Italian Association of agricultural machinery manufacturers, we are glad with the initiative to achieve a single market for mobile machinery. We feel a strong necessity for harmonisation of the road circulation legislation taking into account the complexity of existing technical and sector specific requirements.

AGCO SpA based in Italy, part of AGCO Corporation Group, as manufacturer of agricultural machinery, fully supports the European Commission’s initiative to harmonize road circulation requirements for mobile machinery. We detect a real necessity for harmonization of the road circulation legislation taking into account the complexity of existing technical and sector specific requirements.

• Agoria welcomes the initiative to achieve a single market for mobile machinery. • There exists a strong need for a legislation for road circulation harmonisation that takes into account the complexity of existing technical requirements, including from occupational safety, and sector specific requirements.

CECE, the Committee for European Construction Equipment, welcomes the initiative of the Commission to fill one of the remaining gaps in the single market: the harmonisation of technical requirements related to road circulation aspects of mobile machinery. Please find the CECE feedback attached.

Unacea, the Italian construction equipment association, member of the European federation Cece would like to express its position regarding to the Inception Impact Assessment regarding Road Ciculation for mobile machinery. •We welcome the initiative to achieve a single market for mobile machinery.

Introduction As a manufacturer of agricultural machinery, we are glad with the initiative to achieve a single market for mobile machinery. We feel a strong necessity for harmonisation of the road circulation legislation taking into account the complexity of existing technical and sector specific requirements.

This response is on behalf of the Construction Equipment Association (CEA). The CEA is the trade association which represents the UK construction equipment industry, with a value of £11 billion per annum. Member company products include both self-propelled and towed machinery. The CEA welcomes the Commission's initiative to harmonise the requirements for road circulation of mobile machinery.

• We welcome the initiative to achieve a single market for mobile machinery. • There exist a strong need for a legislation for road circulation harmonisation that takes into account the complexity of existing technical requirements, including from occupational safety, and sector specific requirements.