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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.

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.

With regard to the MRV, in which the CO2 emissions are reported, we have the following comments: Almost 100% of the CO2 emissions are currently calculated from the fuel consumption of the engines / boilers. The consumption is almost never measured directly, but read manually from gauges (before / after) or roughly estimated by sounding the tanks (the accepted tolerance in the bunker process alone is 4%).

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. The VDMA represents around 3300 German and European companies in the mechanical engineering industry.

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.