Machinery Directive revision: CECE reacts to Commissions’ presentation of first orientation

During the last meeting of the Machinery Working Group which took place on 9th and 10th November, the European Commission (EC) invited stakeholders to provide feedback to their presentation containing initial proposals for the revision of the Machinery Directive.

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Taking into consideration the EC’s updated views on many of the topics, CECE members participated in a series of meetings to further develop some of the key subjects for the construction equipment industry. Some of the points include:

References to new technologies: CECE reminded the EC that any reference to a specific technology in the text of the future machinery legislation should be avoided.

Responsibilities: our members felt that many of the proposals create a transfer of responsibilities from end users to the economic operators involved in the placing on the market of products and, particularly on OEM (Original Equipment Manufacturer).

Machine learning: our members believe that any “one size fits all” solution for Artificial Intelligence (AI) is disproportionate and unjustified. Machine learning and AI in the field of construction equipment constitutes what is known as ‘narrow AI’, whereby a machine function can only evolve within the boundaries set by the designer/manufacturer.

Empowerment of implementing acts & standardisation: the EC proposed requesting an empowerment to develop Technical Specifications wherever there are delays or unavailable harmonised standards. CECE believes that this process would jeopardise the current principles of development of harmonised standards, which are consensus-based texts, developed under the principles of transparency and balanced representation of all stakeholders with the additional guarantee of the public enquiry.

Internal checks & Annex IV: CECE members place on the market highly complex mobile machinery, such as hydraulic excavators and dump trucks. However, there is no evidence that the safety level is compromised using self-assessment. Stakeholders have been applying this approach without any specific concern for more than 30 years. The removal of this possibility would have a significant impact on costs for manufacturers and users.

Redefinition of Partly Completed Machinery (PCM): CECE members believe there is an added value in keeping the definition of ‘specific application’, as the presence of this term in the PCM definition gives a clear and complementary link to the definition of machinery. A PCM only brings a function to machinery (or to an assembly of machinery) and does not have any final use.

Machinery lifetime: CECE disagrees with the inclusion of the information about the lifetime of the machine in the instructions of each machine. This addition could have an unintended consequence in increasing the number of machines being discarded when reaching the end of their so-called lifetime, while they are still fit for use. Besides that, there are currently no methods to provide an estimate of the life limit of construction equipment.