The Machinery Directive is and remains an effective piece of legislation that has proven resilient to industrial evolutions and technological developments. This is a core message from the comments that FEM has provided on the Commission draft proposals presented during the last Machinery WG meeting last month. In addition to specific input on the proposed revisions of the legal text, FEM reiterated the key concerns and views of material handling manufacturers in an accompanying general position paper that notably stresses the need for technological neutrality.
The paper also clearly explains that the robustness of the Directive’s essential requirements is not altered by possible challenges of new technologies. Consequently, materials handling manufacturers have not encountered any issue when developing technological solutions such as AI driven innovations. We therefore recommend addressing specific challenges related to new technologies via horizontal legal acts, and not in the MD itself. FEM also made comments in support of digital instructions as part of the general digitalisation targets. Last but not least, we responded to questions regarding the definition of partly completed machinery and the modification of Annex IV, advocating the need to keep the current requirements and firmly objecting to the option of removing the self-certification procedure for Annex IV machines.
More information can be found in the FEM paper