Regulation on machinery products

The Commission´s proposal for a regulation of the European Parliament and of the Council on machinery products aims to update the existing Machinery Directive 2006/42/EC in order to “align the Directive with EU harmonised legislation on product health and safety, and tackle the challenges that may arise from technical progress in digitization”. SPECTARIS welcomes this objective.

SEMI Europe welcomes the opportunity to participate in the open public consultation on the proposed Regulation on Machinery Products. SEMI Europe also appreciates Commission’s efforts to ensure coherence with the new legislative framework (NLF) and to reduce the costs of transposition with the choice of a Regulation.

EUnited welcomes the opportunity to provide feedback on the proposed machinery products regulation COM(2021) 202 replacing the Machinery Directive 2006/42/EC. The Machinery Directive (MD) is a cornerstone and key reference for all industry sectors represented by EUnited.

Executive summary Orgalim represents Europe’s technology industries, a dynamic and highly competitive sector that relies on European Union harmonisation legislation for its success. Orgalim also acts as an industry platform (our Machinery Task Force includes stakeholders from outside our membership) and adviser to the European Commission on the machinery topic.

The European Commission has started the revision of the Machinery Directive (2006/42/EC) with the aim of ensuring a high level of protection for machine users and exposed persons, while taking into account developments related to innovative digital technologies.

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Riese & Müller is a manufacturer of e-bikes with production in Germany (Mühltal). We support the position of CONEBI, which is described in the attached paper. As long as no satisfactory and reliable alternative legislation is in place, EPACs should remain within the scope of the Machinery Regulation.

Dear European Commission, We were forced to insert the following file „COM (2021) 202 and Annexes_ENG_comments TISR_Mr.Paska, Hegyi_ver1.docx“ again. The reason for the re-insertion was that the originally uploaded post file had limited edits. Please confirm to the e-mail address: [email removed] whether the file could be opened without any problems. Thank you for understanding.

Developers Alliance welcomes the opportunity to provide feedback on the proposal for a Regulation on Machinery Products. We limit our observations to elements implicating software and software developers. Software developers are contributing to technological solutions for more and more sophisticated machinery products.

Dear European Commission, TECHNICKÁ INŠPEKCIA, a.s., Slovakia, as an independent inspection, certification organization and notified body (NB 1354), sends you the following document in the attachment: • „COM (2021) 202 and Annexes_ENG_comments TISR_Mr.Paska, Hegyi_ver1.docx“ Comments on the proposal for a Regulation of the European Parliament and of the Council on machinery products and Comments on the Annexes to…

SCOTT Sports SA supports CONEBI's position on the EU Commission's Proposal to revise the Machinery Directive with regard to EPACS action. Excluding EPACS from the Machinery Directive without a well thought-out replacement will lead to uncertainty. SCOTT is of the opinion that EPACs should in no case be combined with personal mobility devices (such as e-scooters, monowheels, etc.) under one Directive.

FLYER AG is a Member of the ZEG Zweirad-Einkaufs-Genossenschaft eG in Cologne, Germany, Europe's largest bicycle retail association with over 1,000 affiliated member companies. As a manufacturer of Swiss Premium E-Bikes under our brand FLYER, we agree with the attached CONEBI's statement and request that EPACs continue to be included in the scope of the Machinery Directive.

French manufacturer of lifting solutions for people or people and loads, under the Machinery Directive We support the European Commission proposal for a EU Machinery Directive revision. We are convinced that no measure should be taken that would increase the limit of the speed of movement of the car, but that the limit of 0.15 m/s or less should be maintained.

The European Commission published its proposal for a new EU Machinery Directive, in which it claims to exclude from the scope of the new directive all “vehicles the sole purpose of which is the transport of goods or persons”. Like the European bicycle industry association CONEBI, the Swiss association velosuisse fears that this will lead to uncertainty in the bicycle industry.

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Grettings, As a global company (EEE manufacturer), we would like to submit comments on the proposed text. We would like to raise Commission attention to Articles 10 and 51 and also to spedific part of Annexes I and III. We gathered all our comments and suggested changes in the document attached. We would like to thank the EU Commission for giving us the opportuniy to submit feedback on this important Legislation.

The competitiveness of European industry and the simultaneous maintenance of the highest level of safety and protection can only be maintained through legislation that is technology-neutral and open. The BDI expressly welcomes the alignment of the proposal for a Regulation on Machinery Products with the New Legislative Framework.

Dear Sir/Madam, as the company FAZUA GmbH, we fully support CONEBI’s opinion and therefore also critically exclude pedelecs from the scope of the Machinery Directive. Alignment with other product standards would have a negative impact on the product safety of pedelecs. [complimentary close] [name removed]H

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BAuA - the German Federal Institute for Occupational Safety and Health thanks the Commission for the opportunity to bring in their comments in the public consultation. BAuA welcomes the proposal as a way to deal with the new technologies that have been established since the time of the entry into force of current the Directive 2006/42/EC.

EFESME is the European Federation for Elevator Small and Medium-sized Enterprises, and it is active at European and international level to support lift SMEs in their daily work and activities. EFESME represents fifteen members in fourteen member states.

The DIN Safety Principles Committee (NASG), as a horizontal committee, carries out standardisation work on basic and multidisciplinary safety requirements. The NASG standards are intended to inform the developer and designer of technical equipment how safety aspects can be taken into account at the design stage.

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The Machinery Directive is undoubtedly a core internal market legislation that has been successfully applied by manufacturers of garden machinery and outdoor power equipment since 2006. This piece of legislation provides our industry with the necessarily stability in the EU legislative framework for more than a decade.

FEM (European Materials Handling Federation) considers the Machinery Directive as one of the most important pieces of legislation for material handling manufacturers. 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.

FME representing Netherlands Technology industries, is relying on the success of a coherent system of European harmonisation legislation and standardisation. Our Netherlands machinery sector, exporting the main outcome of our products in the Single European Market welcomes the European Commission’s proposal for a renewed European Regulation on machinery products and our paper focusses on optimalisation of the…

Proposal for a Regulation on Machinery Products JBCE's position Japan Business Council in Europe (JBCE) welcomes the proposal for the Regulation on Machinery Products, new legislative framework (NLF) and to reduce the costs of transposition with the choice of a Regulation.

CEMA welcomes the Commission' efforts to adapt the Machinery Directive to the state of the art like in relation to autonomous functions or AI. In support of a future proof Machinery Product Regulation there is a request for changes which can be found attached. Each request is accompanied by the necessary argumentation.

Machinery Directive – revision FIEC comments on the proposed revision FIEC, the European Construction Industry Federation, welcomes the revision of the Machinery Directive, which takes into account recent technological developments. These new aspects such as hazardous substances and cybersecurity are particularly welcome.

The EU Machinery Directive is of high importance to the EU Bicycle Industry and therefore also for Bosch eBike Systems, as it legislates the essential health and safety requirements relating to the design and construction of electrically power assisted cycles (EPACs). We have a long standing, good experience with the Machinery Directive to ensure the safety of our products.

Dear Sir/Madam, we would like to make the following comments on the drafts by Alfred Schellenberg GmbH: (1) The Verband der TÜV e.V. calls for recital (24) and Article 21 (4) to be amended to the detriment of SMEs. This concerns the deletion of the mentioned reduction of the conformity assessment fees (Ref. reaction F2660508, line No.5 and No.18).

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The French Federation of Public Works (FNTP) welcomes the revision of the Machinery Directive, which takes into account recent technological developments. These new aspects such as hazardous substances and cybersecurity are particularly welcome.

Fischer bikes, the ebike brand of MTS Marken Technik Service GmbH & Co.Kg in Rülzheim, Germany supports the views of Conebi and ECF on using Option 3 for the future. We see this as the best step forward to ensure a safe market access in the current situation.

Dear Please find below our opinion on the replacement of Directive 2006/42/EC of the European Parliament and of the Council of 17 May 2006 on machinery and amending Directive 95/16/EC (recast) (Text with EEA relevance) into a Regulation of the European Parliament and of the Council on machinery products.

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Preliminary briefing as of 2021-07-30 (English version annexed) The Commission on Occupational Safety and Health and Standardisation (KAN) is the voice of German OSH in standardisation. The KAN is composed of representatives of employers, employees, the Federal Government and the Länder, the statutory accident insurance institutions and DIN (German Institute for Standardisation).

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SICK AG welcomes the revision of the European Machinery Directive and the opportunity to provide feedback for important improvements to the MD. The current MD has not been revised since the NLF and therefore requires many alignments.

The corner represents the Italian mechanical industry, a historically dynamic and innovative sector which relies heavily on the success of harmonised Community legislation. Our industries welcome the European Commission’s proposal for a new Machinery Regulation, but we have a number of concerns on some particular aspects.

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Agoria and its members welcome the European Commission’s proposal for a regulation on machinery products. The proposal will ensure and enhance safety, by establishing ameliorations on the principles, adaptation of the current elements and by adding new elements. It will create a more clear and stable legal framework that will increase the safety of our industry.

Siemens AG as a global manufacturer of machinery and electrical equipment for machinery, and at the same time operator of factories worldwide appreciates the possibility to submit comments on the proposed Regulation on Machinery Products.

We too are concerned with the direction that this proposal is going, and the consequences that may result due to a misunderstanding of the actual situation. The fact is that we (the industry collectively) have been using AI in manufacturing for decades. It’s gaining in popularity and has become the new buzzword – mostly due to advances in cheap sensors and processing capability – but it is absolutely not new.

ECF represents the national cycling associations across the EU, thereby representing the users/riders of bicycles and electric assisted bicycles. We see the Electrically Power Assisted Cycle EPAC/Pedelec as a revolutionary mode of transport that has become, and continues to be, a popular choice of transport across the EU.

Hercules GmbH is a Member of the ZEG Zweirad-Einkaufs-Genossenschaft eG in Cologne, Germany, Europe's largest bicycle retail association with over 1,000 affiliated member companies. As a manufacturer of EPACs of our brands Hercules Bikes and Wanderer, we agree with CONEBI's statement and request that EPACs continue to be included in the scope of the Machinery Directive.

ZEG Zweirad-Einkaufs-Genossenschaft eG in Cologne, Germany, is Europe's largest bicycle retail association with over 1,000 affiliated member companies. As a manufacturer of EPACs of our exclusive brands PEGASUS, BULLS and ZEMO, we agree with CONEBI's statement and request that EPACs continue to be included in the scope of the Machinery Directive.

The Machinery Directive, which imposes technical and safety standards, has been a model of balance, caution and seriousness in defining technical and procedural requirements for manufacturers. It is an important and effective tool for industry and has proved its worth. CPME considers that this regulation is broadly fit for purpose and that it is not appropriate to change its basic approach.

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Madam, Sir, The EU Machinery Directive is of high importance to the EU Bicycle Industry as it legislates the essential health and safety requirements relating to the design and construction of electrically power assisted cycles (EPACs). It is why, as you can read on the attached paper, my company and I would like to keep EPAC under the scope of EU Machinery Directive.

The European Power Tool Association represents European manufacturing companies of the hand-held electrical tool sector (professional and Do-it-Yourself). The Machinery Regulation proposal contains both opportunities and challenges for our sector: Opportunities Foremost, the revision of the directive and its transformation into a regulation as well as the alignment with the rules of the New Legislative Framework was…

Bos — Organisations: Authorities and organisations with security tasks (BOS) are a generic term for: Bodies responsible for the prevention of risks. These are generally referred to as: Operational staff also as blue light organisations Specific requirements for BOS organisations: Staff from these organisations deliberately and voluntarily commit themselves to a high level of intervention. Personal risk (e.g.

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IndustriAll Europe welcomes the proposed Regulation on machinery products and strongly supports the scope and destination route. We also welcome the linkage to the draft Regulation on AI. As the European federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities…

APPLiA would like to use the opportunity given and comment in couple of points on the key elements in the draft Machinery Regulation. This set of comments does not exclude the possibility to deliver additional input in the future as well as improving/modifying certain statements provided here. APPLiA is available for further, especially verbal and bilateral explanation of its comments in more details.

Opinion 1.The legal status change (from directive to regulation) is to be welcomed as well as the combination with a regulation on Artificial Intelligence. 2.The inclusion of “substantial modification” in the text of the Regulation is a correct step.

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The proposition of regulation still contain the same confusions as the actual Machinery Directive (2006/42/CE) : - Article 2) (2) m) should be clarified. Some types of machinery, as service robots (like Pepper or Cruzr models) fulfill the scope and application of Low Voltage and Radio Equipment Directives (2014/35/EU and 2014/53/EU) ; they are radio, video and information technology equipment as computers, with…

CECE welcomes the proposal on the Regulation on machinery products COM(2021) 202 which we hope will bring further legal clarity We fully support the alignment with the New Legislative Framework (NLF) as it brings coherence with the other legislative acts and horizontal transparency.

Confemetal considers that the Machinery Directive has been the main stabilising factor in the manufacture of machinery over the years, ensuring consistency in standards and safety of machinery and equipment placed on the EU market. It has certainly been very useful for industry and regulators.

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Paul Lange & Co OHG is partner of the bicycle industry in Germany and other European Countries. We welcome the possibility to take part in the current discussion about the future of the MD. E-Bikes are an essential part of the bicycle industry being a major source of income for thousands of dealers and offer jobs to ten thousands of people in the local bicycle industry.

The Union Sport & Cycle, the first professional organisation of cycle companies in France, shares the position of CONEBI. Completely excluding pedal cycles with pedal assistance from the scope of the new Machinery Regulation will create uncertainty for industry and for the ongoing standardisation work to bring safe products to the market.

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The Zweirad Industry Association (ZIV) represses the German and international bicycle industry in Germany. Our members are manufacturers and importers of bicycles, EPACs, bike components and accessories. The ZIV fully supports the position of CONEBI which is described in the attached paper.

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FIM welcomes the alignment of the Machinery draft Regulation to the New Legislative Framework, in particular when it comes to the definitions and obligations of economic operators (manufacturer, importer, distributor…) as given in Decision 768/2008. This will bring clarity to the text and reduce possible legal interpretations on the field.

The Baden-Württemberg Chamber of Commerce and Industry (BWIHK) is the umbrella organisation of the twelve Chambers of Commerce and Industry in Baden-Württemberg (bw-IHKs). As eV, it organises and pools the interests of the CCI-Association and its members.

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FAS (French Lift Associatio) representing 180 enterprises for installation and maintenance of lifts and machine directive equipment dedicated to transporting people and goods. We fully support Article 6.2 of Annex III, concerning control devices which allow innovation to close the carrier as soon as the EH & SR are met.

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FAS (French Lift Associatio) representing 180 enterprises for installation and maintenance of lifts and machinery directive equipment dedicated to transporting people and goods. We fully support this regulation project, and to improve safety we propose ti reinforce the EC certification process for equipment described below : "Devices for lifting or transporting people or people and objects, vertical or inclined…

The European Commission presented a proposal on the Machinery Regulation in April 2021. The Regulation is intended to replace the existing Machinery Directive. The proposed rules on machinery aim to ensure that the new generation of machinery products ensures the safety of users and consumers and encourages innovation. Machinery products include a wide range of consumer and professional products — from robots (e.g.

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This feedback is to encourage the EU Machinery Directive to maintain it's regulatory governance on EPAC's. Over many years, this oversight has resulted in a save product embraced by everyone in the community. As an industry, we have been persistent in insuring all brands and product adhere to the EU Machinery Directive and maintain strict quality while integrating key user safety aspects.

As one of the market-leading Notified Bodies (NBs), DEKRA welcomes the European Commission’s proposal for a Regulation on machinery products. We fully support that the proposal enhances the role of independent third parties as providers of testing, certification and inspection (TIC) services for machinery products and proposes to extend their competencies to ensure the safety of machinery products and in the…

CONEBI, the Confederation of the European Bicycle Industry, representing the EU Bicycle, Pedal Assist E-Bike, Parts and Accessories Industries, would like to express its views on the proposal for a new EU Machinery Regulation. CONEBI has been a member of the Machinery Working Group for the past years as well as a member of the respective expert group since its first meeting in March 2021.

Lippe CCI consulted companies from the CCI working group CE/Technical Documentation in Ostwestfalen-Lippe on the consultation of the EU Machinery Directive. We have provided some concrete feedback on this, on the basis of which we provide the following guidance.

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TIC Council, representing the testing, inspection and certification organisations globally, including the notified bodies for Machinery legislation, welcomes the European Commission’s proposal for a Regulation on Machinery Products. You will find below the general comments and attached the table for amendments on the provisions.

The German Social Accident Insurance (DGUV) sees a renunciation of well provisional principles in the proposal of a new Regulation on machinery products, for examination in Article 5 ‘High-risk machinery products’, which is absolutely insufficient to deliver ‘high-risk machinery’ to ‘NOT- high-risk machinery’. All further comments therefore on different aspects, please see the attached comment table.

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In practice, questions of scope, demarcation from requirements from other areas of law, use of partly completed machinery and manufacture for own use are recurrent. This leads to great uncertainty for the parties involved and regularly requires a considerable amount of clarification.

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Introduction Background information On 21 April 2021, the European Commission (EC) adopted its proposal for the Machinery Regulation which will replace the Machinery Directive 2006/42/EC. At the same time, the EC launched a public consultation for feedback on the draft Machinery Regulation. With this document, CEN and CENELEC provide its position on this proposal.

The Essential Health and Safety Requirement (EHSR) 6.2 on control devices has been adapted allowing for control devices authorizing automatic stops at preselected positions instead of hold-to-run buttons, in cases where ‘there is no risk of persons or objects on the carrier colliding or falling and no other risks due to the upward and downward movements of the carrier’.

We have strong concerns about questioning of the fundamental principles of the New Approach, of the New Legal Framework (NLF) and the introduction of vague or undefined concepts that seriously affect the readability of the future Machinery Product Regulation (MPR) (1) MPR is legally binding on the principle of technical harmonisation through harmonised standards The proposal to reshape the self-certification for…

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The MD 2006/42/EC introduced textile ropes for lifting purposes as part of lifting machinery and lifting accessories. Since then, complexity, unclarities and ambiguities have made application of the MD very difficult. The revision of the MD is a singular chance for clarification of utmost importance under the current market circumstances and increasing need for safe and reliable products being put on the EU market.

In our opinion, the possibility that in the Directive of ref. It could be included, for example, what the Guide of the European Commission specifies in point Ҥ82 de la Guide to appication of the Machinery Directive 2006/42/EC edition 2.1.

The MD 2006/42/EC introduced textile ropes for lifting purposes as part of lifting machinery and lifting accessories. Since then, complexity, unclarities and ambiguities have made application of the MD very difficult. The revision of the MD is a singular chance for clarification of utmost importance under the current market circumstances and increasing need for safe and reliable products being put on the EU market.

ACEM, the Motorcycle Industry in Europe, would like to highlight the following 2 points: - The proposal excludes from the regulation's scope vehicles which are not type approved (i.e. offroad vehicles, vehicles for use on private property) but which are currently covered by the Machinery Directive and accompanied by a series of CEN standards used as presumptions of conformity with the Directive.

The TÜV-Association welcomes the proposal for a new Machinery Regulation by the European Commission. Such an update of legislation comes at the right time in order to adapt to technical progress with regard to the connectivity of machines, cybersecurity, artificial intelligence, as well as robotics.

see attached file - Table in English, detailed discussion in German. first topics (extract): Article / Annex: 3 Definitions (1) Comment: Machinery only requiring simple safe guards, especially fixed guards, to be installed at site also shall be treated as machinery and not as partly completed machinery. The manufacturer shall specify the missing safe guards in his manual.

Thanks for the opportunity to express our opinion on the new Regulation. There are some points that, for us, shall be analyzed: 1) Art.21 clause 2: Today’s machinery market asks more and more custom machineries. A type production is going to be reduced to few machineries.

Dear Sir or Madam, In our opinion it would be very targeted, if for future CE assessment procedures specifically in the field of machines and low voltage a Notification Body had to be visited. This would grant the same obligations to every economic actor.

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ABB’s two global Business Units, Business Unit Motors and Generators and Business Unit Drives welcome opportunity to take up aspects that are identified non-productive in otherwise well working directive. These two Business Units produce electrical motors, generators and drives that are intended for industrial use.

The IFA proposes the choice of options 2 and 4. However, as the application of the existing Directive has proved its worth in the vast majority of cases, the scope of amendments should be deliberately kept to a minimum in order to allow all users of the Directive the simplest possible transition in the application of a new Regulation.

Increase in the use of industrial robots as well as the onset of collaborative robots in industry with requirements to increase their artificial intelligence and the use of digital technologies has a considerable impact and pressure on the revision of the existing Machinery Directive.

The Health and Safety Authority (Authority) is the competent Authority in Ireland for implementation of the Machinery Directive. The Authority make the following comments in respect of our initial overview of the Inception Impact Assessment process: • The Authority welcomes the Impact Assessment of the Directive.

Wipotec GmbH, Kaiserslautern/Germany: We support options 2 and 4. The following modifications should be made to the Machinery Directive: — Harmonisation of cable colours with the US National Electrical Code. — Harmonisation of the warnings with North America (Kombbisicon has already been harmonised for some 12 years after Anzi 535.4 and ISO 3864-2, but Chapter 1.7.1 of the Machinery Directive requires always the…

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ANEC welcomes the European Commission’s inception impact assessment on the revision of the Machinery Directive. The Machinery Directive has generally worked well in providing a sufficient level of safety for consumers in the EU, as well as aiding the free movement of machinery products. Consumers benefit from the greater choice of products, and from competition. However, some limitations can still be observed.

PROFLUID, the French association of pump manufacturers, compressors, agitators and taps, is pleased to be able to contribute and express its views on the preliminary impact study on the revision of the Machinery Directive.

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The Machinery Directive provides a well-functioning, stable legal framework for European manufacturers that allows them to be present and remain competitive both in EU and global level – there is no need to amend the Directive itself as it is fit for purpose, even for Machinery embedding new technologies. While there are some challenging areas, e.g.

On behalf of the German Machine Tool Builders' Association (VDW) in Frankfurt (Germany), which represents around 60,000 employees and around 14 billion sales, I am obliged to say the following: The German machine tool manufacturers fully support the VDMA position and the identical CECIMO position.

CEIR, the European Association for the Taps and Valves Industry, welcomes the opportunity to express its views on a possible revision of the Machinery Directive. CEIR supports options 1 and 2 for the reasons listed below. Option 1 (alignment with the NLF) is clear: a directive that articulates itself differently from other legislative acts cannot be retained.

CEN-CENELEC feedback to the EC Inception Impact Assessment 'Machinery Directive – revision' First, as a matter of course, any change of the essential health and safety requirements of the Machinery Directive would have a significant impact on both the published standards (currently 900) as well as on the standards under development (currently 300).

Ceemet response to the European Commission’s Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC Ceemet’s key messages •The industries represented by Ceemet are the aggregation of NACE codes 25 to 30 and 32 and 33.

Robert Bosch answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC. Bosch does not favour Options 0, 1 and 3. The Machinery Directive has to be adapted at least to the New Legislative Framework, especially with the provisions of Decision 768/2008, and need adjustments for clarification in the scope, definitions and content with respect to legal clarity.

PMMI The Association for Packaging and Processing Technologies thanks the EU Commission for the opportunity to comment on the revision of the EU Machinery directive. Please review the attached document. Respectfully Fred Hayes Director, Technical Services

Dear Sir or Madam, Thank you very much for the opportunity to give feedback to the inception impact assessment on revision of the Machinery Directive. EuroWindoor suggests option 2. Please find attached the detailed feedback of EuroWindoor AISBL.

Our observation relates to the proposed methodology of the Impact Assessment. The Option 2 being considered (p.3) mixes in its bullet point on changes to "the essential health and safety requirements" two very different issues: (1) the possibility to submit documentation in digital format, which is easy to discuss and raises no specific issue; and (2) the inclusion of developments in "emerging digital technologies"…

We welcome the continuous work and intention of EU Commission to improve the Machinery Directive. JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the inception Impact Assessment in relation to the revision of the Machinery Directive.

1 For easier ownership by all stakeholders, some concepts could be more explicit in terms of their scope, and promote a better understanding of the definitions (defined application, specific application, machine modification, risk analysis; Intended use).

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1 For easier ownership by all stakeholders, some concepts could be more explicit in terms of their scope, and promote a better understanding of the definitions (defined application, specific application, machine modification, risk analysis; Intended use).

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Position ANIMA on the Inception Impact Assesment — Revision of the Machinery Directive The business organisation in Confindustria Meccanica Varia is the Italian machinery industry. The Commission welcomes the publication of the Commission’s Inception Impact Assesment document on the future revision of the Machinery Directive as it provides a clear summary of the options to be addressed in the revision of the…

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EUROMOT, the European Association of Internal Combustion Engine Manufacturers, welcomes the European Commission’s initiative to consult stakeholders in the process of evaluating and reviewing the Machinery Directive (MD).

Orgalim’s industries represent a wide variety of sectors in the manufacturing industries, the vast majority of which are small and medium sized enterprises for whom the Machinery Directive is the core piece of legislation.

The European Association for Technical Communication – tekom Europe e.V. is a multinational association and a forum for about 9,000 professionals across Europe being active in technical communication and related fields.

SEMI, the association representing the global electronics manufacturing industry, welcomes the opportunity to comment on the revision of the Machinery Directive. AI technologies are already used in semiconductor manufacturing: Using artificial intelligence (AI) tools, today’s semiconductor fabs combine equipment know-how and manufacturing statistics to manage massive fault detection data, increase manufacturing…

Dear Sir/Madam, I agree with the support of option 2. It must be possible to provide instructions in a purely digital format, in particular as regards the supply of moving images (e.g. Videos), which will be legally compliant in individual cases. Another additional concern would be to clarify what is an “almost complete machine”.

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We hope that following matters will be considered when revising the Machinery Directive. - Scope and definitions: o Interface between the Machinery Directive and the Low Voltage Directive  - In the current MD there is a list of electrical appliances in the scope of the LVD that are excluded from the scope of the MD.

FederUnacoma is of the opinion that the Machinery Directive is overall fit for purpose and therefore, does not support changes to its substance which may offset the stability that it has given machine manufacturers for more than a decade. On the other hand, we welcome procedural adaptations such as the alignment with the NLF and the conversion into a Regulation.

Hello, we are a provider of automated and flexible production systems in the automotive industry. In our view, option 2 and option 4 make sense. We would like to see the possibility of providing instructions in digital form. It should be possible to agree with the customer on an EU national language regardless of the place of the movement. Some customers would like to see English instructions for use.

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We welcome the plan to bring the machinery directive into line with the NLF. We propose that the definitions used in the directives should also be adapted. Since the Machinery Directive and the Low Voltage Directive are virtually mutually exclusive, one might consider combining the two directives.

Option 2: Align the Directive with the new legislative framework with possible changes in scope, definitions, BHSR (including digital documentation and new technology (artificial intelligence). This option is the most suitable for the proposals made by the French authorities in its note of 2 December 2016, in particular concerning: Improvement of the definitions and precision of the exclusions (nuclear machinery…

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VdTÜV and its members welcome and support the EU Commission’s initiative to revise the Machinery Directive 2006/42/EC. Since the Machinery Directive is applied to a large number of consumer and industrial products, it is of the utmost importance that the revision will bring the requirements into line with the New Legislative Framework (NLF), clear up any ambiguities and take adequate account of technical progress in…

VdTÜV and its members welcome and support the EU Commission’s initiative to revise the Machinery Directive 2006/42/EC. Since the Machinery Directive is applied to a large number of consumer and industrial products, it is of the utmost importance that the revision will bring the requirements into line with the New Legislative Framework (NLF), clear up any ambiguities and take adequate account of technical progress in…

Caterpillar UK Ltd (UK) is submitting the consolidated feedback of Caterpillar, Inc. (US): 1. We would prefer to combine option 1 (adopt the new legislative framework, but do not make any technical changes) with option 4 (we see the benefits of consistently all over Europe, but we also would prefer an elongated transition period to compensate for the time gained by not obliging the national states to transpose the…

1 In view of the need to adapt the MRL to the digitalisation process, it is urgent to adapt also the archiving and, in particular, the release of the user information or documentation to the users to the digitisation process (e.g. “electronic instructions for use”).

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We welcome the necessity of the revision of the MD as new technologies are indeed emerging and are directly related to health and safety factors, environmental and rational use of energy approaches. Issues occur for new types of machinery seeking product certification according to MD, whilst it is not clarified if they are within its scope and other directives are partly applicable as well.

The UK would like to thank the Commission for publishing this Inception Impact Assessment. We have the following comments: The document mentions that an impact assessment will be carried out based on the information from the evaluation study on the Directive. We would like the Commission explain more about about what this will cover.

We prefer options 2+4 (Inception Impact Assessment). Option 2 will provide for better understanding and better addressing of specific developments, without having to use general (usually understood as ‘vague’) terms. Further, we propose the following improvements: 1.

Option 2 and in combination option 4 is the most appropriate way forward. Alignment with the New Legislative Frame Work will provide higher legal clarity and coherence across European legislations applicable to a specific machinery. This is especially important for cases where several legislations, e.g. directives, are applicable to a machinery.

Scope: ‘Replaceable equipment’ means either machinery or ‘partly completed machinery’ (mostly partly completed machinery). They do not therefore need to be regulated separately. If safety components, lifting accessories, chains, ropes and removable mechanical transmission shafts are to continue to be regulated in the Machinery Directive, this is done by describing separate conformity assessment procedures (including…

Filed in German · English published by the European Commission

VDMA answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC Both the recent publication of the Evaluation report and the Communication on AI respectively underline that the Machinery Directive is fit for purpose and that the EU safety framework is robust enough to provide for machines embedding AI-driven functions.

“Dear Mrs/Mr, talking about the future of the Machine Directive the choise nr. 2 is aligned with the new vision of the EU market. It is our opinion that new aspects as AI, Cybersecurity and IoT will be the near future in developing Machinery, Robots and other Products under the scope of the Directive and for this, they should be take into consideration in the RESSs of the Directive.

From our point of view, option 2, combined with option 4, is the most appropriate alternative. On the one hand, simplification of the MRLs is welcome and, on the other hand, the challenges of digitalisation must be taken into account.

Filed in German · English published by the European Commission

CECIMO welcomes the possibility to comment on the Commission Inception Impact Assessment in relation to the revision of the Machinery Directive. CECIMO members see some benefit in aligning the Directive with the “new legislative framework” (option 1) and in converting it into a Regulation that would be directly applicable and enforceable in all Member States without the need for national transposition (option 4).

Capiel - The Coordinating Committee for the Associations of Manufacturers of Switchgear and Controlgear equipment for industrial, commercial and similar use in the European Union. With regard to the Machinery Directive, stability is our central requirement.

Proposed changes to directive 2006/42/EC: 1. New developments like IoT and AI should be incorporated in the essential health and safety requirements as these phenomena play a role in both threats and solutions. Think of machinery linked to the internet for remote control and data acquisition; this creates opportunities but simultaneously also major threats to health and safety of operators and consumers.

This feedback concerns the exclusion in 2006/42/EC Article 1 (Scope): ” 2. The following are excluded from the scope of this Directive: … (c) machinery specially designed or put into service for nuclear purposes which, in the event of failure, may result in an emission of radioactivity; …” in regard of safety classified cranes and nuclear fuel handling machinery (based on crane technolo-gy).

as eAccessibility and eInclusion are becoming more important by the day, The respective standards (existing and upcoming) concern machinery itself, its operation, the respective manuals and other documentation, etc.

As a mechanical engineering consultant for machines, I consider it important that the following cases be adapted in the context of the new Machinery Directive: — prescribing how risks should be classified (with which risk graph); Preferred hybrid method SIL. User manual changes in the language of the user in the language of the user (e.g.

Filed in Dutch · English published by the European Commission

CEETTAR welcomes the Commission objective to align the machinery directive with some new possibilities concerning Artificial Intelligence and Internet of Things. In order to ensure consistency within EU legislation, CEETTAR is in favour of an alignment between The Machinery Directive and the ‘new legislative framework’.