EGMF Position on the Machinery Regulation proposal

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