Manufacturers call for Cyber Resilience Act and Machinery Regulation alignment
EGMF and five other co-signing European industry associations have published a joint position on challenges for manufacturers of products falling within both the Cyber Resilience Act (CRA) and the Machinery Regulation (MR).
The paper identifies legal uncertainty concerning the form of the single EU Declaration of Conformity (DoC) required for products subject to more than one Union legal act. The associations interpret the CRA as requiring some form of DoC to physically accompany the product, while the amended Machinery Regulation will require the DoC to be provided in digital format once the relevant Omnibus IV requirements apply. At the same time, the Machinery Regulation requires a single EU Declaration of Conformity where more than one Union legal act applies.
The joint position therefore calls on the European Commission to align the relevant CRA provisions with the Machinery Regulation as amended by Omnibus IV and provide clarification that, for products falling within the scope of both acts, manufacturers can provide a single digital DoC accessed by a mark on the machine, its packaging or an accompanying document, without also being required to provide a simplified DoC.
