May was, as always, an active month for me as I represented members’ interests in various regulatory and standardisation activities.
I contributed to a meeting of the EU-facing Committee for European Construction Equipment (CECE) manufacturers, which held a meeting of its task force that deals with strategic aspects of CO2 legislation. An in-depth discussion took place on reliably calculating construction equipment’s product carbon footprint (PCF), especially the in-use phase. The PCF measures a product’s total greenhouse gas emissions over its life cycle, from raw material extraction and pre-processing, manufacturing, and distribution to usage and disposal. This is of critical importance to the users of construction equipment when reporting their Scope 3 CO2 emissions. Hence, it is incumbent on manufacturers to support the development of a robust PCF calculation tool. During the CECE meeting, I also provided an overview of CEA’s response to the recent DESNZ call for evidence on NRMM decarbonisation options.
On the standardisation front, I represented CEA member interests at a meeting of the International Standards Organisation (ISO) where the topic of discussion was rechargeable energy storage systems. This group is collating information on current standards and other relevant documents that construction equipment manufacturers can use in their development of electrified machinery. The finished standard should be of tremendous help to CEA members developing battery-powered machinery.
Another ISO standardisation activity I was involved in was a group meeting that developed a series of standards that set performance-level requirements for the functional safety of construction equipment control systems. I lead this group of international experts, which puts CEA in a very influential position in developing this critical series of standards. Although the first edition of this series has already been published, the standards need to provide that all-important presumption of conformity that is core to members’ compliance activity towards the Machinery Directive/Regulation. Functional safety is a highly complex matter, but these standards will eventually provide construction equipment manufacturers with the exact performance level requirements for functional safety compliance covering all the applications of their products. I’m pleased to report that significant progress was made during the May meeting, but much work remains to be done before the series update can be considered complete.
What key regulatory changes and updates do members need to be aware of?
A highly significant development occurred in the EU during May. The European Commission published a revised version of its official guidance to the Machinery Directive. Although the legal text of the EU Machinery Directive does not mention the form in which specific compliance documentation is to be provided, the official guidance set the expectation that these documents should be in paper form. On behalf of CEA members, I have long campaigned that providing documents, such as the operator instructions, offers many benefits to stakeholders, including ease of use, e.g., search functions, and are more environmentally friendly.
What will this mean for members?
As a result of ongoing advocacy towards the European Commission, the CEA, through CECE, has successfully achieved a revision to the European Commission’s Machinery Directive guidance, which removes any expectation that paper instructions, declaration of conformity, and other documents should be provided in paper form. This means that manufacturers can provide these documents in digital form. This offers tremendous reductions in cost and logistical efforts to CEA members.