Orgalim comments on the upcoming Impact Assessment of the Machinery Directive

Published: 8 February 2019

Policies & Issues: Internal Market - Product Safety Legislation

Representing the European technology companies driving the digital transformation of industry and society, Orgalim is certain that artificial intelligence (AI) will be a central pillar of Europe’s future competitiveness. Many of the firms we represent are at the leading edge globally in the development of AI applications integrated in consumer and industrial products (’embedded’ AI), and embedded AI is already widely used across our industries to deliver efficiency gains along the value chain. More broadly, embedded AI is enabling technology solutions to critical societal challenges – from climate change and the energy transition to the future of mobility, an ageing society and security in the digital age.

Although AI has been deployed safely in manufacturing for decades, the rapid pace of technological evolution in recent years has prompted questions regarding the EU legal framework. Against this background, the European Commission has initiated an evaluation of the Machinery Directive (MD) to assess whether it remains fit for purpose in addressing machinery incorporating new technologies such as AI. The MD is a core piece of legislation for our industries, ensuring a high level of safety while providing legal stability to our companies. Given the importance of a stable and predictable legal framework for attracting investment into key future tech like AI, we believe it will be crucial to pursue a prudent approach to regulation in this arena.

As such, we welcome the publication of the Commission’s initial evaluation of the MD, which states that this important piece of legislation remains fit for purpose – primarily thanks to the structure of the Directive and its technology-neutral essential health and safety requirements. Manufacturers can demonstrate compliance with Annex I of the Directive by making use of more than 800 existing harmonised standards, which represent the technological state of the art. Furthermore, our industry continues to actively contribute its experience and technical expertise to the drafting of standards to cover new technologies.

As a further step in the evaluation of the MD, the Commission will perform an impact assessment focusing on new technologies, with the aim of analysing whether the Directive can continue in the years to come to guarantee the placing on the market of safe machines and to ensure that users and consumers trust these machines, even when they integrate embedded new technologies.

As the current MD has performed well, increased occupational health and safety and continues to meet its objectives for both ensuring the placement on the market of safe machines (including those that embed new technologies) and establishing a high level of trust in these machines among users and consumers, Orgalim is strongly recommending that this piece of legislation should not be updated in the near future.

In this position paper, we take a closer look at the definition of the ‘narrow’ artificial intelligence and how this technology is used in our industries today. We then outline in detail how the current Annex 1 of the MD continues to meet its objectives regarding safety and trust, whether or not a piece of machinery incorporates AI elements.

Download the paper by clicking the button above to read our messages in full.  

Authors

Piccinni
Eleonora Piccinni
Manager - Technical Regulation

Related Position Papers

Construction Products Regulation: Orgalim views on shaping a Regulation on Construction Products that strengthens the Internal Market [14 May 2019]

Radio Equipment Directive: Orgalim views on the EC Roadmap for a delegated Act on upload of software to radio equipment [7 May 2019]

Orgalim comments on the upcoming Impact Assessment of the Machinery Directive [8 February 2019]

Orgalim’s answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC [8 February 2019]

Orgalim answer to the stakeholder survey for the evaluation study of the Low Voltage Directive 2014/35/EU [24 January 2019]

Shaping the future of outdoor noise legislation: Orgalime comments to the European Commission’s evaluation and impact assessment of Directive 2000/14/EC on noise emission by outdoor equipment [21 December 2018]

How to modernise Directive 2000/14/EC on Outdoor Noise: Orgalime core policy statements on the public consultation [16 April 2018]

Open public consultation on EU rules for products used in the construction of buildings and infrastructure works [13 April 2018]

Orgalime answer to the Inception Impact Assessment on the revision of the Outdoor Noise Directive 2000/14/EC [22 December 2017]