State of Play
05 November 2019
Oongoing Impact Assessment on MD vs AI and emerging technologies to be finalised in Q2 2020- ongoing targeted interviews.
- Although not officially announced, it is almost certain that the MD will be revised with the objectives of seeking greater legal clarity in scope and definition – revised proposal by end 2020/early 2021:
- Borderline cases with other directives
- Definitions to be reviewed for ‘hot’ issues : PCM, specific application and substantial modification
- Exclusions (machinery on ships and for nuclear purposes)
- High risk machines Annex IV
- Address risks pertaining to emerging digital technologies (cybersecurity, transparency of algorithms, software updates)
- Simplification of administrative burden allowing digital formats for documentation (e.g. manual of instructions)
Preliminary results of opne Public Consultation
- 528 replies of which 372 from industry, 68 citizens, 35 public authorities, 11 NGOs, 5 trade unions, 4 research institutions and 2 consumer organisations
- 92% of the respondents form the EU
- A majority of respondents are in favour of aligning the directive to the New Legislative Framework
- A majority of respondents would like to review the concept of PCM
- A majority of authorities, notified bodies and consumer associations see the need for the MD to better cover the safety of human-robot collaboration, machine learning, software updates etc…
- Opinions are divided about how cybersecurity requirements for manufacturers of machinery should be implemented in the EU
- Opinions are divided among Member States with regards to digital instructions.
