Urgent : ETUC position paper on the EC proposal for a regulation on machinery products with concrete proposals to compromise amendments  

To: Members of the IMCO Committee at the European Parliament 

Brussels, February 28th, 2022 

Dear MEPs, 

This email is related to the Parliamentary report on the Proposal for a regulation on machinery products. 

In view of the discussion which will take place this afternoon on the new set of amendments agreed by the rapporteur and shadow rapporteurs, as well as the technical meeting of Wednesday morning, I hereby recall you of ETUC observations to this report, which you will find in the annex of the ETUC position enclosed. 

A number of amendments that have been tabled so far risk to demean significant sections of the Commission’s revision, as they either get away with the definition of high-risk or exclude the third-party assessments for high-risk machinery.  

From the new set of compromise amendments, ETUC welcomes that the terminology “machines posing a significant risk", has been removed, but is worrying that the term “high-risk” has not been retrieved from the Commission’s proposal. “High-risk” is a precise, well established and systematically important term in the New Legislative Framework (NLF), which is also used in the draft AI act and in various pieces of legislation under the European OSH acquis. 

Furthermore, ETUC believes that the Commission’s capacity to adopt implementing acts establishing technical specifications as detailed in Article 17 3 (b) of the draft Regulation should be supported as proposed by the Commission, and the compromise amendment should be rejected. If the Commission has to wait 36 months to realise that the standardisation bodies have failed to develop a standard, and if the Commission is only then allowed to start working on a delegated act, this may lead to significant problems and undue delays which may put workers and users at risk or significantly the putting into service of new machinery products 

ETUC deplores that no other demand of the European trade union movement has been considered in the new compromise amendments. Members of the IMCO Committee are therefore asked to kindly integrate all the proposals included in the above-mentioned annex of the ETUC position. 

With best regards, 

Claes-Mikael Ståhl 
ETUC Deputy General Secretary