EUnited, together with six European machinery and equipment associations, has issued a joint press release raising serious concerns about the treatment of the machinery sector under the European Commission’s Omnibus IV proposal on digitalisation and common specifications.
Under the current proposal, sectors covered by the Machinery Regulation (EU) 2023/1230 are the only product sectors excluded from the 24-month transitional period granted to other industries for the introduction of mandatory electronic Declarations of Conformity.
While other sectors would benefit from a two-year adaptation period, machinery manufacturers would be required to comply immediately from January 2027, when the Machinery Regulation becomes applicable. This creates a clear imbalance and raises significant implementation concerns.
Key industry concerns
The joint industry statement highlights that:
- The Machinery Regulation, as adopted, allows manufacturers to provide the Declaration of Conformity either in paper or digital format. Omnibus IV would remove this flexibility without granting a transition period.
- Amendments adopted by the European Parliament introduce a “direct access” obligation via QR code to each individual machine’s Declaration of Conformity, making impossible the use of a centralised secure landing page and increasing version control and other risks.
- Provisions extending the right to request paper instructions from the original Commission proposal create legal ambiguity, particularly due to the unclear definition of “consumer” and the lack of practical means for manufacturers to verify such status.
The machinery sector is characterised by long product development cycles, complex value chains and significant upfront investment. Sudden digital obligations without adequate transition would impose disproportionate costs, particularly on SMEs, and undermine legal certainty.
The co-signatories call on the European Commission, the European Parliament and the Council to ensure that Omnibus IV:
- Grants the machinery sector the same 24-month transitional period as other product sectors;
- Removes the “direct access” obligation to safeguard secure and reliable digital solutions;
- Eliminates provisions that create legal uncertainty regarding paper instructions.
The omnibus provisions should ensure digitalisation simplifies compliance and strengthens Europe’s industrial competitiveness — not create new administrative burdens.
You can download the full press release here together with the Joint industry declaration on the same subject