In support of the Commission evaluation, CEMA provides input to the public consultation on the revision of the Machinery Directive and the issues identified.

The European Commission has started the process of revising the Machinery Directive. On their roadmap they already carried out an initial impact assessment; now, through the  public consultation, stakeholders are consulted to confirm the issues identified by the evaluation of the Machinery Directive and to indicate through facts, data and knowledge, the areas to be improved and/or simplified in the Directive.

In its contribution, CEMA provides input on all relevant issues and agrees with the overall conclusion of many that the Machinery Directive is a very robust legislation, fit for purpose also for many upcoming technologies like robotics. While standards should of course evolve to provide guidance, the current essential requirements on health and safety will suffice. The same can be said for software updates (which are more regular, carried out remotely‚Ķ) and machine learning.  Additionally, the use of a digital user manual only (instead of a mandatory paper one) would be a way to enter the digital age, as well as an added value for the user and our forests.

We believe that the principle of self-certification, even for category IV machines when using harmonised standards, is justified and see no evidence of the contrary.

On the need for a possible adaptation for cybersecurity, a more tricky subject, a distinction must be made between ensuring the security of communication to prevent cyberattacks and addressing possible health and safety risks when there is a breach in that security. The latter can be taken along by the manufacturer in its risk assessment, and there is no need for extra requirements. Of course standards could guide the way. Ensuring the security of communication should be addressed more horizontally providing levels of protection from which to choose and guidance on how to make the appropriate choice.

CEMA is confident that by solving the details in standards, overall and sector specific, future technologies, as depicted, can be covered in the current Machinery Directive.