FEM companies are committed to integrating environmental principles into each stage of the life cycle of their products (from production and transport to use, maintenance and end-of-life recycling). The combined action of regulatory requirements and industrial innovation has substantially reduced the environmental impact of materials handling equipment. For instance an industrial truck or an aerial platform produced today emits 95% less particulate matter and 96% less nitrogen oxide than one produced 10/15 years ago. Consequently, the oldest machines are now responsible for the largest share of pollutant emissions.
We believe that environmental legislation should prioritise the most severe and relevant environmental impacts, and realistically balance them with the impact on companies’ competitiveness. Legislation should take a holistic approach that assimilates the different sets of requirements applicable to the same equipment, to avoid regulatory overshoot.
Key messages
>>> Incentives should encourage users to switch to more environmentally-friendly equipment
>>> Environmental considerations should be balanced against the need to preserve our companies’ competitiveness
>>> A consistent approach must be taken on different types of environmental requirements applying to the same equipment
Emissions from non-road mobile machinery (NRMM)
EU NRMM legislation is particularly relevant for the following product groups: Industrial Trucks, Mobile Cranes and Mobile Elevating Work Platforms.
The original mother’ Directive 97/68/EC regulated exhaust emissions generated by internal combustion engines installed in non-road mobile machinery. More and more stringent limit values have been gradually applied (in stages) since 1999 to diesel-fuelled engines between 37 and 560 kW. Directive 97/68/EC underwent a revision and was repealed by Regulation 2016/1628 on emission limits and type approval for internal combustion engines installed in non-road mobile machinery. This Regulation was published in the Official Journal on 16 September 2016 and entered into force on 6 October 2016. It sets out requirements for a new Stage (Stage V), with stricter emission limit values, and an expanded scope to cover all engines installed in non-road mobile machinery, less than 19 kW and higher than 560 kW.
Regulation 2016/1628 is applicable as of 1 January 2017.
FEM has been very closely involved in the revision process and successfully defended the materials handling manufacturers’ position on this dossier, collaborating with fellow mobile machinery sectors (agricultural, construction and garden machinery). Most FEM requests and concerns weren taken into account in the final text of the Regulation, namely:
- General extension of the transition period by 6 months (24 months in total)
- Specific extension of the transition period granted to the mobile cranes’ sector, by 12 months (36 months in total)
- Replacement engines’ provision for NRE engines (19-560 Kw)
- No modification to the proposed application dates for the EU type-approval and the placing on the market of Stage V engines.
Reference Documentation
• Regulation 2016/1628 on emission limits and type approval for engines installed in non-road mobile machinery – 16 September 2016
• Commission proposal for a revision of Directive 97/68/EC – 24 September 2014
• FEM position on the proposal for a revision of Directive 97/68/EC (+ Annex: Impact study on Mobile Cranes) – December 2014
Waste Electrical and Electronic Equipment (WEEE)
Directive 2012/19/EU (recast of Directive 2002/96/EC) seeks to prevent or diminish the negative environmental impact caused by the management and generation of WEEE and resource use. It came into force on 13 August 2012 and needed to be transposed into Member States’ laws by 14 February 2014. During the transition period (from 14 August 2014 until 14 August 2018) the scope of the old Directive does not change (10 categories of electrical and electronic equipment (EEE)). From 14 August 2018, the scope will be extended to include all EEE that will be grouped within 6 categories instead of 10.
Most materials handling equipment comes under one of the exclusions, notably: non-road mobile machinery made available exclusively for professional use; equipment which is specifically designed and installed as part of another type of equipment that does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment; large-scale stationary industrial tools; and large-scale fixed installations, except any equipment which is not specifically designed and installed as part of those installations.
FEM is monitoring the implementation phase of the WEEE2 directive and a possible future review of the scope.
Reference documentation
• Directive 2012/19/EU on Waste Electrical and Electronic Equipment (WEEE2)
• Frequently Asked Questions on Directive 2012/19/EU (April 2014)
• Guidance on application of WEEE2 and RoHS2 to EOTs (EN, DE)
Restriction of Hazardous Substances (RoHS)
Covering the restriction of the use of hazardous substances in electrical and electronic equipment (EEE), the RoHS Directive 2011/65/EU (recast of Directive 2002/95/EC) restricts the use of 6 substances in EEE since July 2006 and 4 new substances as from 2019.
This key piece of European chemical policy came into force on 21 July 2011 and needed to be transposed into Member States’ laws by 2 January 2013. As a result of the recast process, the so-called RoHS2 Directive extends substance restriction to monitoring and control instruments. It also creates a new scope category including all EEE not covered by the scope.
RoHS2 includes exemptions and also a number exclusions. Most materials handling equipment benefits from one of these exclusions, notably: non-road mobile machinery made available exclusively for professional use; equipment which is specifically designed and installed as part of another type of equipment that does not fall within the scope of this Directive, which can fulfil its function only if it is part of that equipment; large-scale stationary industrial tools; and large-scale fixed installations.
FEM is monitoring the RoHS2 implementation phase.
Reference documentation
• European Commission RoHS2 Frequently Asked Questions (December 2012)
• Commission Delegated Directive 2015/863/EU
• Guidance on application of WEEE2 and RoHS2 to EOTs: EN, DE
