Position paper to the final report evaluation of the DM 2006/42/EC
Orgalime comments to the final report on the evaluation of the Machinery Directive 2006/42/EC
Position Paper 13 November 2017
Orgalime welcomes the Evaluation of the Machinery Directive 2006/42/EC (MD) in the framework of the Commission’s Regulatory Fitness and Performance (REFIT) programme and is pleased to comment on the areas of improvement identified by the consultant, for the purpose of providing support in the evaluation process.
Orgalime represents the engineering industry, which is the largest industrial branch in the EU, with a turnover of around €2,000 billion in 2016. The industry accounts for a quarter of manufacturing output and a third of manufactured exports in the European Union.
In accordance with the consultant’s report, Orgalime firmly believes the Machinery Directive is performing well and has reached its objectives of both providing a high level of safety for machinery users and facilitating the free movement of machinery in the internal market.
The adequate implementation of the Directive in the whole of the EU has helped the EU’s manufacturing industries to remain competitive on the internal and global markets with positive consequences at both economic and social level.
The issues to be addressed which have been highlighted within the Evaluation report are as follows:
1. Adapting the Directive to fit/integrate with the New Legislative Framework
2. Adapting the Directive to ensure suitability for new developments
3. Simplification of risk assessment procedures
4. Improvements to definitions/demarcations between particular types of machinery
5. Improved convergence/harmonisation with other similar Directives/Regulations
6. Ensuring increased/improved inspection and therefore widespread compliance of the Directive
As repeatedly mentioned, keeping an industrial base in Europe will only be possible with a strong and competitive manufacturing industry, at the core of the European economy (see also our core policy statement on the REFIT of the Machinery Directive 2006/42/EC).
To reach the objectives of growth and jobs for the future of Europe, manufacturers need a stable and effective legislative framework. For much of our industry, the Machinery Directive 2006/42/EC is the core piece of product legislation enabling companies to place state of the art and safe machinery on the Single Market. In our view, the legislation is performing as it should. We, therefore, urge decision makers to keep the Directive in its current form with minor modifications, if at all necessary, but not impacting its essential requirements and its basic philosophy.