EGMF

Gardening from a Professional view

Anne Claire Rasselet

Joint industry call for a realistic timeline to implement the new batteries regulation

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EGMF co-signed an industry statement, together with 9 other associations, calling on the European Commission and the co-legislators to ensure a transition period for the implementation of the Batteries Regulation.

We support the European Commission’s objective to improve the sustainability of batteries, while protecting the competitiveness of the Single Market. We are fully committed to supporting the EU’s transition towards sustainable batteries.

While interinstitutional negotiations are yet to begin, it is already clear that the new Batteries Regulation will have far-reaching impacts on the design, labelling and end-of-life handling of batteries and battery-powered appliances. Given the extent of the changes and the significant uncertainty over the final text of the Regulation, we call on the co-legislators to provide economic operators with the necessary time to duly implement due requirements. This is particularly pertinent for all those market access, CE-mark relevant provisions with design or labelling impacts that currently are foreseen to apply as of entry into force (e.g. Art. 11, 20).

We recommend to:

• Introduce a transition period to ensure individual provisions are applicable no earlier than 24 months after the adoption of the corresponding Guidance, delegated or implementing act; and

• Introduce a 24 month transition period (Art. 79 or 78 of the proposal) between the entry into force of the Regulation and its application, by replacing the current date of application that is set for 1 January 2022.

We remain strongly committed to working together with the European Commission and the co-legislators to ensure that the review of batteries legislation becomes a success.

You can read the full Joint statement on Batteries Regulation here.

Joint EGMF-EPTA comments on the upcoming Sustainable Products Initiative

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On 16 July, EGMF and EPTA issued a joint position paper on the Sustainable Products Initiative. This future legislative framework – currently developed by the European Commission – is expected by the end of the year.  

This joint position paper aims to share the view of the outdoor power equipment and power tools industries on the different measures to make sustainable product the norm. In addition to our responses to the public consultation questionnaire in June, this paper provides inputs for the ongoing Impact Assessment study that is evaluating cost, benefits and impacts of different measures under discussion.

EGMF and EPTA support the Commission’s approach to set sustainability requirements on a European level and a product-by-product basis. However, it is important that the Initiative is built on the existing legal framework, and the extension of the Ecodesign Directive does not produce a parallel legislation.

Furthermore, we argue that materials and substances should be regulated only through existing policies, and all labelling information should be easy to understand and be of added value. Lastly, the Digital Product Passport needs a clear definition, alignment with standardisation and current legislation, and have a measured scope that considers our industries’ complex global value chains.

More information can be found in the EGMF position paper.

EGMF Position on the Machinery Regulation proposal

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The Machinery Directive is undoubtedly a core internal market legislation for manufacturers of garden machinery and outdoor power equipment. This piece of legislation has provided EGMF’s industry with the necessarily stability in the EU legal framework for more than a decade. The entire portfolio of EGMF equipment falls in the scope of the Machinery Directive.

With the Commission proposal for a future Machinery Regulation being tabled, EGMF shared with the key EU policymakers its views on the main provisions of this proposal which have an impact on the garden machinery and outdoor power equipment sector.

EGMF welcomes the goal of ensuring a more coherent and harmonised legal framework for machinery products via the alignment with the New Legislation and the conversion into a Regulation. On the other hand, our industry has strong concerns about new measures to address challenges from emerging technologies or adapt existing requirements. This is particularly valid for the proposed conformity assessment procedure for high-risk machines which will be required to undergo third-party certification. EGMF is not aware of any evidence indicating that products that are self-certified pose any greater risk than those certified by third parties. Since the market for garden and outdoor power equipment is seasonal, any delays in product launches (which could be caused by the obligation of third-party certification for machines listed in Annex I, or inadequate transitional provisions) could have critical implications.

EGMF calls on EU decision-makers to shape a balanced legislation providing an appropriate framework to address emerging technologies and guarantee a high degree of safety for all machinery used by European citizens, while enhancing innovation– an essential element for the EU competitiveness and sustainable growth agenda.

In the light of this objective, EGMF asks decision makers to:

  • Support provisions on digital documentation to achieve a green, modern and future-proof regulation
  • Extend the transition period to 54 months and eliminate the retrospective application in Article 50
  • Ensure consistency with future regulation on Artificial Intelligence, particularly in terms of definition of Artificial Intelligence systems
  • Reinstate the option of self-assessment for machines in Annex I – as currently allowed under the Machinery Directive – rather than impose third-party certification only
  • Clarify the scope of a ‘safety function’
  • Clarify and improve new provisions related to human-machine interface, autonomous mobile machinery, cybersecurity

More information can be found in the EGMF position paper .

EGMF Compliance Guides – 2021 edition

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EGMF has updated its Compliance Guides for both combustion engine and electric powered equipment. These guides are aimed at assisting market surveillance and border control authorities in checking the conformity of various types of garden machinery equipment that enter the EU market.

While EGMF member manufacturers build products that are compliant with EU legislation on safety and the environment, not all products on the market in Europe meet the same stringent levels. Counterfeit and non-compliant products are likely to present a safety hazard to consumers and are damaging to the environment.

The guides focus on the following key areas:

  • Identification of the key parts of the machine
  • The applicable EU Directives and Regulations
  • The applicable EU Harmonised standards
  • The main marking requirements such as CE, Engine exhaust emission, Guaranteed sound power level, WEEE symbol
  • The required warning symbols
  • The documentation that must be provided such as instructions and Declaration of Conformity

The full list of updated Compliance Guides, divided by specific garden machinery products, are now available for download.

To provide some background, EGMF produced its first batch of compliance guides in 2016. Ever since, members and the EGMF Secretariat have produced new guides for different types of equipment and updated the older ones to reflect changes in legislation or other technical requirements. 

EGMF view on batteries and future Ecodesign Working Plan

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In the context of discussion on the Ecodesign and Energy Labelling Working Plan 2020-2024, we shared our views on the concept of universal batteries.

In short, EGMF strongly supports the European Commission’s decision to not include ‘universal batteries’ in the draft list of product groups, in line with the study recommendation.

We strongly believe that the existing initiatives to develop interoperable batteries and systems should remain voluntary in the garden machinery and outdoor power industry. Main reasons are:

  1. The battery is an essential part of cordless garden machinery and outdoor power equipment since it influences the performance and, consequently, efficiency of the machinery;
  2. Free competition is a key driver for innovation and competitiveness;
  3. Safety should remain a priority and cannot be compromised;
  4. The backward compatibility – one of specificities of our industry and the interoperable systems – already contributes to material and energy savings.

Find EGMF position paper here.

The future Machinery Regulation should enhance innovation, not stifle it

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Released on 21 April 2021, the new European Commission’s proposal revising the Machinery Directive includes crucial changes that will have a significant impact on manufacturers of garden, landscaping, forestry and turf maintenance equipment for years to come.

EGMF is very pleased to see the introduction of digital instructions. At the same time, the proposal will stifle European innovation by artificially categorising AI machines as high risk and imposing third party certification without any safety benefits.

The full EGMF statement is available here.