Industry bodies have issued a joint statement in response to the European Commission’s Omnibus IV proposals and the European Parliament's amendments. While the sector supports digitalisation and the EU’s ambition to modernise regulation, it warns that these changes must be well designed and allow realistic time for implementation. Otherwise, there is a real risk that Omnibus IV will create new administrative burdens, rushed compliance and immediate costs for businesses, rather than simplifying the system.
A first major concern is the absence of any transition period for the mandatory digital Declaration of Conformity under the Machinery Regulation. This would force manufacturers to change their systems immediately, despite the long development cycles typical in the sector. Other product areas covered by Omnibus IV are being given time to adapt, but the machinery sector is not, making orderly and compliant implementation extremely difficult.
A second concern relates to proposals in the European Parliament to require digital Declarations of Conformity with “direct access”, again with no transition period. This would mean each machine’s QR code must link directly to its specific declaration, rather than to a landing page where users could enter basic details such as a serial number. Industry groups point out that this goes beyond what was agreed in the Machinery Regulation, which allows declarations to be provided either on paper or digitally. Introducing this change less than a year before the rules take effect creates uncertainty, increases administrative pressure, and imposes short-term costs on companies already preparing for compliance, particularly SMEs, with little added value for market surveillance authorities.
A third issue is the proposal to extend the period during which paper instructions can be requested. This is seen as creating legal uncertainty because the term “consumer” is not clearly defined in several of the relevant regulations, including the Machinery Regulation. In practice, manufacturers would also have no reliable way to check whether a request comes from a consumer or a professional user, making the rule difficult to enforce.
Commenting on the joint statement, Viki Bell, CEO of the Construction Equipment Association, said:
“The sector supports digitalisation, but it has to be done in a way that is practical and workable for the businesses that have to implement it. Introducing major changes without a transition period and adding extra layers of complexity at a late stage risks creating cost and confusion rather than simplification. We want to see digital rules that genuinely help industry, not ones that make compliance harder than it needs to be.”
The joint statement calls on EU lawmakers to ensure that Omnibus IV genuinely supports Europe’s industrial competitiveness by delivering practical, secure and workable digital solutions. In particular, it asks for a transition period of at least 24 months for digital Declarations of Conformity, the removal of the “direct access” requirement, and the removal of the extended period for requesting paper instructions. The sector has also said it stands ready to work with EU institutions on solutions that support digitalisation without disrupting manufacturing or undermining the integrity of compliance documentation.
