EGMF Position Paper on Road Circulation

We welcome the European Commission’s willingness to harmonise road circulation requirements for mobile machinery. Given that the upcoming regulation will have a considerable image on EGMF non-mobile machinery, we share a paper highlighting the specific concerns and challenges that our sector have identified. 

Main points: 

• Definitions: EGMF requests a more precise definition of ‘non-road mobile machinery’ to prevent misinterpretation. We propose to delete the last part of the sentence from the definition provided by the European Commission. 
• General obligations: EGMF proposes to delete specific wording in the regulation to avoid legal ambiguity regarding non-road mobile machinery placed on the market that is not intended to circulate on public roads. It must be clear that the machines are not intended to circulate on public roads can still be placed on the Single Market, as compliant with the Machinery Directive. 
• Establishment of ‘the forum’: EGMF calls for mandatory, rather than optional, industry representation in the Information Exchange Forum, to facilitate the uniform interpretation and implementation of the regulation.
• Transitional provisions: EGMF requests explicit clarification that machinery outside this regulation can continue following national legislation beyond the 8-year transition period.