EGMF comments on initial proposals in view of revising the Machinery Directive

EGMF comments on initial proposals in view of revising the Machinery Directive

EGMF submitted its detailed input on preliminary proposals for the revision of the Machinery Directive which were announced at the last Machinery WG meeting in February 2020.

The EGMF contribution reiterates core comments about the MD revision. EGMF stressed that the Directive is fit for purpose, including in terms of emerging technologies. Any possible new requirements on Artificial Intelligence, cyber-security and the like must not have an adverse impact on currently compliant machines.

The EGMF document is also accompanied by detailed comments on 48 points raised so far, mainly from Member States.

In the table of comments:

  • EGMF disagreed with those proposals introducing burdensome requirements, notably on human-robot collaboration, external influences/cyber-attacks, machine learning, software, which are already adequately covered by the MD.
  • EGMF provided highly critical remarks towards proposals re-assessing current definitions (such as for machinery, partly completed machinery, assembly, safety function, state of the art, specific application).
  • EGMF disagreed with the proposals to remove the self-assessment procedure based on harmonised standards for Annex IV machinery, and to update Annex IV with additional machinery categorised as dangerous.
  • EGMF strongly supported the proposals in favour of allowing digital instructions, highlighting as benefits the positive environmental impact, cost savings and the ability to provide updates of instructions more easily.

Please read the full document here