On 14 July, FEM made public a position paper on the European Commission’s proposed Regulation on the approval and market surveillance of non-road mobile machinery circulating on public roads.
This paper underscores our commitment to active engagement with policymakers and outlines our stance on vital aspects of the proposed Regulation.
First of all, we welcome the proposed Regulation as a crucial step towards harmonising and ensuring safe circulation of non-road mobile machinery across EU Member States, substantially simplifying the process for manufacturers to sell their machines in various Member States.
However, our paper highlights key areas for further consideration:
- We regret the exclusion of towed equipment from this proposal. FEM recommends including harmonised technical requirements for towed equipment to fill the regulatory gap, thus modifying the definition of ‘non-road mobile machinery’ to encompass towed equipment.
- FEM suggests adjustments to general obligations, especially the requirement for EU-type approval for all non-road mobile machinery. As currently phrased, this could also apply to machinery not intended to circulate on public roads, potentially creating legal issues. We propose revisions to restrict the scope to machinery for public road use only.
- We question the necessity for manufacturers to include email addresses on machinery or documentation, as it’s already stipulated in the Machinery Regulation. To avoid duplication, we suggest eliminating this requirement from the proposed Regulation.
- While supporting the 8-year transitional period for national type-approval legislation, we need clarification on the functioning of machinery exempt from the Regulation’s scope after this period.
To learn more about our perspective and detailed recommendations, please refer to the full position paper available HERE.