CECE letter requests a transitional period to adapt to new amendment of a harmonsied standard

On 9th November, CECE sent a letter to the European Commission about the amendment of EN 474-1:2006 +A6:2019 on Earth-moving machinery. Following the citation of this standard in the Official Journal of the European Union (OJEU) on 14th October, our members identified two issues that needed to be addressed: a transitional period and readdress the warning accompanying the citation.

On the issue of the transitional period, with the citation of A6 in the OJEU, there has been no coexistence period granted between the withdraw of A5 from the OJEU and the inclusion of A6. In practice, on that day manufactures that still have 15 on their documentation have no presumption of conformity anymore. Our members argue that they cannot adapt their technical documentation and declaration of conformity without an appropriate transitional period. Therefore, we request a transitional period of 6 months to allow sufficient time for these administrative issues.

On the warning accompanying the citation, the way it has been drafted, we believe that it extends the previous restriction regarding visibility to backhoe loaders, even though no change has been made to the visibility requirements in A6: the warning concerning visibility shall remain identical to the one published in 2019, i.e. limited to excavators only. Concerning the quick couplers, annex B-Quick couplers, of EN 474-1, is indeed mentioned in the new warning but the latter still refers to the requirements that do not relate to quick couplers.

CECE presented the topic and the arguments during the EC’s Machinery Expert Group meeting of 10th November. As a way forward, the EC proposed to grant a transition period to the harmonised standard and to have a meeting to discuss the content of the warning.