Position Paper: on the revised draft GPP criteria on Public Space Maintenance

Position Paper: on the revised draft GPP criteria on Public Space Maintenance

EGMF represents the manufacturers of the majority of gardening and outdoor equipment dedicated to gardening products and services. In this context EGMF submitted the following comments to the Joint Research Center for the elaboration of GPP criteria for Public Space Maintenance.

EGMF highlights the need to maintain the technology neutrality of EU legislation. Market trends indicate that products will increasingly be battery driven or electrically powered by cords.

While in EGMF we support developments in battery technologies, it is important to note that for some uses , particularly in professional ground maintenance, products powered by internal combustion engines are technologically better suited for these tasks.

Furthermore, the engine exhaust emissions limits discriminate against equipment with internal combustion engines.

In addition the proposal requires batteries to meet the performance requirements detailed in standard 61960, but this standard is not suitable for certain applications in the garden machinery sector. Furthermore, EGMF does not produce batteries and depends on the availability of batteries in the market, thus the suggested thresholds for heavy metals in rechargeable batteries should be aligned with the batteries directive and REACH regulation.

In conclusion, both battery driven equipment and industrial combustion engines have advantages and disadvantages, and the legislation should remain technology neutral so that the GPP criteria favour the adequate technology for the different uses.