Anne Claire Rasselet

EGMF joined forces with Orgalim and other sectoral associations to co-sign a statement on the upcoming Cyber Resilience Act (CRA).

As the regulation is in the process of being finalised, we urge the European institutions to take the necessary time to effectively address the remaining concerns of the industrial sector, avoiding rushing this crucial piece of legislation on cybersecurity.

We highlight 5 key points to be considered:

1. Transitional Periods: We advocate for a 48-month transitional period, with an additional 24 months for Non-Road Mobile Machinery (NRMM), to ensure a smooth and thorough adoption process.
2. Product Classification: We endorse the Council’s methodology proposal, emphasising cybersecurity risks as the basis for classifying critical products.
3. Exclusions: The exclusion of spare parts and free and open-source software (FOSS) development from the CRA is crucial to safeguard innovation and the sustainability of long-term investments.
4. Support Periods: A support period aligned with the expected product lifetime, as proposed by the European Parliament, is essential for adaptability and resilience.
5. Cybersecurity Requirements: A refined focus on essential cybersecurity requirements is necessary to meet the specific needs of the industry without stifling growth.
   We are committed to a future where robust cybersecurity and industrial innovation go hand in hand. Let’s ensure the CRA supports this vision.

Read the full statement HERE.

As supporters and contributors to the EU Green Deal objectives, we strive to improve our products and packaging. In order to facilitate that, we need a well-functioning and harmonised internal market.

Therefore, we support the European Commission’s proposal in the Regulation on packaging and packaging waste (PPWR) that ensures that packaging that is compliant with it can be placed in any case on the EU market.

However, we believe that there are still provisions allowing Member States to introduce national labelling systems for extended producer responsibility (EPR) schemes. This regulatory approach will make companies’ management processes more burdensome, and industry will be facing diverging national labelling requirements in different counties, which will lead to re-labelling, shipping back and forth to logistic centres, etc. National labelling requirements, such as those currently in place in France, Italy, or Spain, jeopardize the European Single Market, cause unnecessary greenhouse gas emissions, higher costs for consumers and, in the worst-case, additional waste.

Therefore, for the upcoming trilogues, we propose to the policymakers to:

• Further strengthen the approach to harmonised European labelling rather than national measures by limiting the ability of Member States to introduce national labels for extended producer responsibility schemes.
• Inform consumers about the correct disposal of packaging via standardised labelling.

Download the full statement HERE.

EGMF and EPTA welcome the initiative to promote repair and manufacture products that are long-lasting and repairable by design. We also support the harmonisation of measures on repairability to prevent further proliferation of national rules. However, we would like to underline that there are several aspects that need to be taken into account by the European Parliament, IMCO, and MEPs working on the legislative file.

• Scope: we strongly urge the final report to follow the Europe Commission’s approach to reference and build the scope on already existing or legislation such as Ecodesign, to ensure that the selected product have been subject of impact assessment and consultation with stakeholders. Unless there is specification of the product categories that are under the umbrella of the legislation, there would be massive regulatory overlaps and uncertainty. We also stress that B2C and B2B products need to be viewed differently, and the initiative should focus on the products that cannot be currently repaired, or have a very short lifetime.
• Independent repairers and consumers: we alert that repairs executed by people that are not qualified for electrical and electronic equipment, pose serious safety issues. Therefore, we believe that a horizontal one-size-fits-all approach to repair, access to repair information and spare parts of all products, and especially to consumers, should be avoided and specialists should be consulted in which cases that could be viable.
• Repair duration limit and loan: the proposed deadline of 15 calendar days and providing loans is not reasonable for many types of equipment, as it would require the manufacturer to keep a huge inventory of spare parts and whole products, which would put in jeopardy many repairers and dealer networks.
• Extended guarantee period after first repair: extending the liability period with an additional two years from the moment of repair is unfair to manufacturers, putting excessive burden to repair parts on which the original liability period has expired.

Download the paper HERE.

As European manufacturers of non-road mobile machinery (NRMM) EGMF, alongside, CEMA, CECE and FEM, calls for a longer transition period in the application of the Cyber Resilience Act (CRA).

The current proposed time period of 36-40 months is insufficient and we urge for an extended transition period that allows adequate time for redesign, testing, and compliance.

The implementation of the CRA will require extensive hardware and software modifications on NRMM, affecting the overall architecture of the machinery and we believe this timeline underestimates the complexities of machinery development.

We request an amendment to Article 55 – paragraph 4 extending the application date by an additional 24 months.

Read our full statement here.