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CECE - Committee for European Construction Equipment

CECE

CECE is the recognized organization representing the European construction equipment industry.

Lobbying Activity

Construction equipment industry urges transition periods for chemical bans

15 Dec 2025
Topic — The consultation concerns restricting persistent organic pollutants to align with international Stockholm Convention commitments.
Message — The industry requests defining land-based motor vehicles to include all non-road mobile machinery. They seek an 18-month transition period for new products to prevent market disruption. They also call for exemptions covering spare parts across machinery types sharing components.123
Why — This would prevent costly premature obsolescence of existing products and allow time to find alternatives.45
Impact — Environmental health suffers as the phase-out of newly banned substances is delayed.6
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

5 Nov 2025 · Participation as speaker and panelist at Annual CECE Summit 2025 “ Smarter Regulations, Stronger Industry”

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

4 Nov 2025 · Participation as speaker at the Networking dinner “In dialogue with EU Institutions on Market Surveillance”

CECE urges delays to European digital and AI regulations

7 Oct 2025
Topic — The European Commission is seeking feedback on simplifying and streamlining digital regulatory frameworks.
Message — CECE members call for a postponement of the Data Act to renegotiate existing contracts. They urge a 24-month delay for AI requirements to address discrepancies in requirement levels. The industry also recommends a single reporting platform to remove double cybersecurity reporting obligations.123
Why — This would reduce legal complexity and help businesses operate efficiently across the Single Market.45
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Response to Revision of the Standardisation Regulation

15 Jul 2025

CECE Input Key Challenges in the Standardisation Process CECE welcomes the opportunity to provide preliminary input to the European Commissions Call for Evidence in preparation for the impact assessment on the revision of the standardisation system. There are several persistent challenges currently affecting the European standardisation process, particularly from the perspective of industry stakeholders such as CECE. Firstly, there is a notable lack of consistency in HAS consultant assessments. This inconsistency is observed both between different consultants and within the same consultants evaluations at various stages of a project. The situation is further complicated by the frequent replacement of HAS consultants during the lifecycle of standardisation projects, which disrupts continuity and delays progress. Another significant issue is the limited cooperation and accessibility of HAS consultants. They are often difficult to reach and rarely available for direct engagement, which hampers effective communication and collaboration with technical experts. Moreover, there is currently no easy-to-use or efficient mechanism to resolve disputes between working groups and consultants. This absence of a clearing body leads to prolonged disagreements and procedural deadlocks. The current approach to amending harmonised standards is inefficient. There is a tendency to reopen entire documents during assessments, even when only specific sections have been modified. This practice discourages timely updates and effectively prevents the implementation of necessary corrections. These operational challenges are compounded by broader structural issues. The increasing number of standardisation requests and activities initiated by the European Commission has significantly expanded the workload of Standardisation Development Organisations (SDOs). A continuation of the current situation will inevitably render the concept of harmonization of standards obsolete. This is a very likely scenario, but certainly not in the interest of all stakeholders. This flow in demand requires more personnel and financial resources. However, without a corresponding increase in EU funding, the financial burden is shifted to stakeholders. If participation fees are raised to cover these costs, SMEs risk being priced out of the process, undermining the goal of stakeholder inclusivenessone of the root causes identified by the Commission itself. While we recognise the Commissions role in shaping the standardisation framework, it remains uncertain how a shift toward technical specifications or alternative instruments would effectively address the current challengesparticularly the resource constraints and procedural inefficiencieswithout first ensuring that these foundational issues are adequately resolved. CECE acknowledges the Commissions introduction of Common Specifications (CS) as a reflection of the growing pressures on the current regulatory framework. While this initiative aims to address existing challenges, it is important to recognise that effective solutions require a balanced approach that draws on both regulatory and industry expertise. There is a concern that the CS approach may unintentionally sideline valuable industry input, suggesting that legislative technical capacity alone is sufficient. Given the increasing complexity of todays regulatory and technological environmentparticularly in areas such as digitalisation, data governance, and sustainabilitycollaborative engagement is more crucial than ever. These issues demand not only technical proficiency but also time and inclusive dialogue to ensure robust and future-proof outcomes. CECE believes that addressing these challenges should be a priority. We remain committed to supporting a robust and efficient European standardisation system and look forward to contributing further.
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Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

10 Jun 2025 · Discussion about the state of play of the Data Act implementation in the construction machinery sector.

Construction equipment industry opposes new reconfigurable radio regulations

26 May 2025
Topic — The consultation seeks to ensure radio equipment stays compliant after software updates.
Message — CECE prefers no action or self-regulation to provide manufacturers with maximum flexibility. They argue that the current EU Blue Guide already provides a framework for managing compliance during software updates. Any new rules should avoid unnecessary duplication or regulatory overreach.123
Why — This would minimize administrative costs and maintain operational flexibility for equipment manufacturers.4
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Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · In the context of the EU-LAC Global Gateway Investment Agenda, the European Commission’s Directorate-General for International Partnerships (DG INTPA) launches an initiative with a view to develop circular economy value chains in Latin America

Meeting with Giorgio Gori (Member of the European Parliament)

20 Mar 2025 · Priorities on steel and CBAM

Construction industry seeks wider exemptions for UV-328 chemical ban

22 Aug 2024
Topic — Amending EU rules to restrict UV-328 as a persistent organic pollutant.
Message — The organization requests that the regulation explicitly include and cover non-road mobile machinery, mining, and power generation. They also stand for a transition period of 18 months to facilitate compliance efforts.12
Why — Broadened exemptions would provide legal certainty and safeguard the supply of replacement parts.34
Impact — Environmental interests are harmed by extended timelines for phasing out hazardous chemical substances.5
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CECE urges explicit machinery exemptions and longer transition period

22 Jul 2024
Topic — Amending EU rules to list Dechlorane Plus as a restricted persistent organic pollutant.
Message — CECE believes exemptions for replacement parts should explicitly include and cover non-road mobile machinery. The industry stands for a transition period of 18 months upon entry into force.12
Why — These changes would confer more legal certainty on the construction equipment industry.34
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Response to Evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD)

20 Jun 2024

CECE welcomes the chance to respond to the call for evidence regarding the current evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD). We believe the PED and SPVD are fit for purpose and recommend against merging them. Maintaining their distinction is crucial for clarity and the prevention of unnecessary disruption to existing compliance mechanisms. Both Directives have consistently proven to be effective and reliable frameworks. The directives have been instrumental in ensuring the safety, quality, and competitiveness of pressure equipment used within the EU. In summary, we strongly believe there is no need to merge the PED and SPVD. Maintaining the distinction between the two directives is crucial to preserving the clarity and specificity that each directive provides to its respective area.
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Response to Implementing Regulation setting out the template for the collection of data under Regulation (EU) 2023/1230

31 May 2024

CECE welcomes the opportunity to provide feedback on the draft implementing act establishing a data collection template under Article 6 of Regulation (EU) 2023/1230. This initiative is crucial for effective EU-wide monitoring of machinery safety. We suggest below a summary of a few recommendations to enhance the clarity and comprehensiveness of the proposed data collection format. For further details, please refer to the attached document. Reporting Period and Data Consistency: - Clarification Needed: The phrase "over five years" is ambiguous and seems inconsistent with Article 6.5(d) of the Machinery Regulation (MR), which states "for at least the preceding four years." - Streamlined Data: Remove sub-columns for individual years and provide a consolidated figure for the entire period. Yearly data over a short period does not yield significant analytical value. Classification of Accidents: - Distinction Clarification: The draft lacks clear criteria for differentiating "accidents at work" from "non-occupational accidents," which impacts the overall risk assessment. - Enhanced Criteria: Provide clear criteria for evaluating each type of accident to enhance the data's effectiveness. Data Collection for Effective Oversight: - Notified Bodies (NBs): Include information on the involvement of NBs in the conformity assessment to identify and address their duties. - Harmonised Standards (hEN): Include references to the harmonised standards used by manufacturers to assess their effectiveness and address non-compliance. - Exclusive Responsibility of Member States: Ensure that data collection is the sole responsibility of Member States, without involving manufacturers in incident data collection. Root Cause Analysis and Misclassification Concerns: - Root Cause Summary: Include a section for a short summary section that captures the root cause of each incident to ensure and facilitate proper risk assessment. - Misclassification Prevention: Address potential misclassification by clarifying that misuse due to a lack of training should not necessarily reflect poorly on the machinery. Definitions and information requirements should be further clarified in the guidance to the Machinery Regulation. Additional Column for Member State Recommendations: - Safeguard Clause Application: Allow Member States to recommend applying safeguard clauses if issues are identified with specific manufacturers. - Formal Objections to Standards: Facilitate urgent revisions of standards when necessary. Machine Category Adjustments: Enable recommendations for adding, transferring, or withdrawing machine categories in Annex I. By addressing these points, the data collection template can be clearer, more effective, and better suited to identifying and mitigating risks associated with machinery and related products.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament, Rapporteur)

26 Apr 2024 · Non-road mobile machinery

Meeting with Beatrice Covassi (Member of the European Parliament)

20 Mar 2024 · European re-industrialisation

Response to Rationalisation of reporting obligations

18 Dec 2023

CECE welcomes the European Commission's proposal 2023/0369 (COD), published on October 17, which proposes amendments to Directive 2000/14/EC, specifically addressing reporting requirements in the field of outdoor noise. This proposal, namely the removal of Article 16 of Directive 2000/14/EC, is a significant step towards reducing the administrative burden on manufacturers, ultimately contributing to a more efficient regulatory framework. This welcoming stance also aligns with the principles outlined in the CECE position paper of May 2009. Article 16 of Directive 2000/14/EC currently imposes administrative obligations on manufacturers, including sending conformity documents to both Member State authorities and the Commission. However, the noise emissions are already clearly communicated through mandatory labelling on equipment in the Declarations of Conformity and are typically readily available in marketing materials. Customers receive noise emission information through instructions provided with construction machinery when also covered by other legislation, which encompasses most equipment categories. Removing Article 16 streamlines processes, reduces redundancy, and alleviates the associated challenges. This shift in reporting requirements is well-founded and advantageous for several reasons. 1. Cost Reduction: The current obligation for manufacturers to send representative Declarations of Conformity (DoC) to both the European Commission and individual Member States results in avoidable costs. These costs include the expense of document preparation, the cost of postage, as well as the time and effort of employees tasked with preparing and sending these documents. By eliminating duplicate reporting, this proposal will allow companies to allocate their resources more efficiently. 2. Incomplete Responsible Member States Authority List: The current legislative framework contains an incomplete and sometimes inaccurate list of responsible Member States' authorities; namely notified bodies and market surveillance agencies. In many cases, there is more than one agency indicated per country, leading to confusion about which is the primary responsible entity. This lack of clarity causes uncertainty among manufacturers regarding the correct authorities to whom they should send their documents. Eliminating this requirement would reduce such uncertainties while fostering a more efficient and transparent regulatory environment. 3. Challenges in Defining First Machine Placement: The existing requirement to send the DoC to the Member State where the first machine is placed on the market presents challenges for manufacturers. Modern manufacturing and distribution processes often involve multiple countries, simultaneous shipments, and changes in market entry points, making it difficult to precisely identify the first machine placed on the market. This complexity is compounded when non-EU manufacturers, authorised representatives, or importers are involved. The proposed changes would ease this burden and promote more straightforward compliance. 4. Ambiguity Surrounding the Purpose of the Noise Database: The proposed amendments would also end the discussion on the necessity of maintaining a database of DoCs: the noise database. If the purpose is to provide customers with access to this data, it is essential to note that many manufacturers already make their noise-related information available on the internet. This practice underscores the possibility of streamlining the reporting processes, emphasizing the importance of the proposed changes while avoiding redundancies in light of modern information accessibility practices. Keeping in mind the direction of the EU in view of digitalisation and the recently published Machinery Regulation, DoCs in digital format can be easily obtained by any authority via the websites of the manufacturers, as these are publicly available documents.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament, Rapporteur)

18 Sept 2023 · general introduction, non-road mobile machinery

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

8 Jun 2023

CECE, the Committee for European Construction Equipment, welcomes the opportunity to provide feedback to the European Commissions consultation on the RED Delegated Regulation 2022/30 on cybersecurity aspects. The postponement of the RED Delegated Act application date until August 1, 2025 is crucial for construction equipment manufacturers to redesign and adapt their products in accordance with the available harmonised standards, while allowing them to complete the appropriate conformity assessment procedure before the Delegated Act becomes applicable. In line with the formal request of the European Standardisation Organisations (ESOs), we believe the delay of the initial schedule for the delivery of harmonised standards should go hand in hand with the proposed amendment to the application timeframe. Manufacturers would not otherwise be able to place radio products on the EU market due to the lack of standards and the lack of sufficient availability of notified bodies under this Delegated Act. We support the updated timeline proposed by the European Commission and highly appreciate the efforts made to launch this initiative.
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Response to Update of the methods of measurement of airborne noise emitted by equipment for use outdoors

1 Jun 2023

CECE welcomes the opportunity to provide input to the public consultation on revision of Annex III of the Outdoor Noise Directive (OND). We would also like to thank the European Commission for incorporating most of our comments during the development process, especially when it comes to Part B of the new Annex. In this context, we express our hope that the proposed noise test codes and the relevant (standard) references will be duly retained. We would also like to bring attention to some remaining proposals that are important for our sector. Please find below a summary, and attached our position paper with further details: 1) CECE suggests the deletion of the last part of the text included in footnote #2 regarding the measurement of engine net power. The current footnote states that In the case of earth-moving machinery, the engine net power shall be measured in accordance with ISO 9249:2007. CECE wishes to emphasise that the use of ISO 9249:2007 is incongruous with EN 474-1, which is harmonised to the EU Machinery Directive 2006/42/EC and refers to ISO 14396:2002. Moreover, the sentence poses a risk of generating inconsistencies in terms of conformity assessment processes. Notably, while EN 474-1 explicitly references ISO 14396:2002, ensuring that the machine's net power is indicated on the type plate in accordance with this standard, the inclusion of the aforementioned sentence endorsing the use of ISO 9249:2007 would necessitate manufacturers to provide a distinct net power value in accordance with the ISO 9249:2007 standard on the test report. Such a disparity could lead to confusion. 2) CECE also recommends removing the following sentence: "when applicable in combination with EN ISO 3744:2010" (Part A, Section 5, on the environmental correction K2A). The statement appears to be misleading, as it is evident that the requirements outlined in Part B should take precedence over those specified in EN ISO 3744:2010, clause 4.3. Hence, it is recommended that this quotation be omitted to alleviate any confusion or misinterpretation while ensuring the mentioned prioritisation. 3) CECE finally suggests replacing the verb "shall" with "may" in the following sentence: "an intermediate steel piece shall be inserted during tests between the appliance and the support tool [...]" (Annex, Part B, item 10(a), support of the appliance). This provision does not have any added value in terms of safety, and if a manufacturer applied the methodology without the intermediate plate, new test results will likely differ, potentially creating confusion on the users side.
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Construction equipment industry calls for narrower Cyber Resilience Act

22 Dec 2022
Topic — New EU legislation setting mandatory cybersecurity standards for all connected digital products.
Message — CECE wants the law limited to products connecting to public networks. They also demand a five-year transition period to adapt complex machinery.12
Why — This would prevent costly technical redesigns and avoid redundant certification processes for equipment.34
Impact — Public security interests are harmed because essential safety protections would be delayed.567
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Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur) and Orgalim – Europe's Technology Industries and

5 Oct 2021 · Machinery regulation

Response to Revision of the Machinery Directive

29 Jul 2021

CECE welcomes the proposal on the Regulation on machinery products COM(2021) 202 which we hope will bring further legal clarity We fully support the alignment with the New Legislative Framework (NLF) as it brings coherence with the other legislative acts and horizontal transparency. We also support the conversion of the Directive into a Regulation as it facilitates uniform application across all European Union Member States and therefore the free movement of goods. On the definition of Artificial Intelligence, CECE believes that the definition as such will impact a larger number of products in its scope than was initially intended by the European Commission. CECE recognizes that the definition of artificial intelligence (AI) currently in the Machinery Regulation proposal is aligned with that of the AI Regulation proposal. However, such definition must be adapted in order to focus only on systems with evolving behaviour and avoid any confusion with non-evolving systems that could incorporate technologies listed in Annex I of the AI Regulation proposal. For example, GNSS (Global Navigation Satellite Systems) use Kalman filtering, which is an algorithm that uses a series of measurements observed over time. On high-risk machinery and conformity assessment procedures, the criteria to include machines under Annex I should be clearly defined and the process well-understood. In addition, we strongly disagree with the removal of the possibility for the manufacturer to self-assess its machine using harmonised standards. Not allowing self-assessment will impose the involvement of a notified body in the conformity assessment procedure, generating only extra burden for the manufacturer. On the concept of substantial modification, CECE members believe that the text as proposed fails to bring the intended clarity to the subject that the EC consider to be lacking in the current Directive. Our members’ intention is to cooperate with the co-legislators to improve the text. On the EC proposal to use its mandate to create delegated acts in order to draft Technical Specifications, CECE believe that the development of technical specifications should not be used to substitute the process of development of harmonised standards. We want to ensure that the respect for the current principles used in standardisation (e.g., a consensus-based text, a balanced representation of stakeholders and transparency, ensured with the public enquiry) will be applied also in the drafting of technical specifications. On the annexes to the proposal, our understanding is that annex III became over-prescriptive and our members question the feasibility of some of these new requirements. For example, it is disproportionate to oblige manufacturers to supply each machinery product with test equipment to allow the user to test the safety functions. Also, some other requirements like data recording, some of the proposed changes on autonomous mobile machinery, assembly instructions and obligations for PCM manufacturers are overly burdensome. In general, requirements must have clear limits and balances to the responsibility of the original manufacturer, other economic operators and market surveillance authorities. On the transitional provisions, CECE believes that article 50 is unclear and misleading. The 12 months granted for making available of products should be converted in a proper transitional period, allowing the placing on the market of Machinery products under the current Machinery Directive, as has always been the case with other legislations. Considering the proposal and annexes of the Machinery Product Regulation (MPR) COM(2020) 202, CECE is planning to publish a position paper addressing in details the identified issues.
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

25 Feb 2021 · ePrivacy

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Feb 2021 · Environment, chemicals

Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

1 Dec 2020

The New Legislative Framework (NLF) for EU product legislation, which consists of Decision No 768/2008/EC and Regulation (EC) No 765/2008, aims to improve the compliance of products with the applicable legislation at the time they are placed on the market. The Decision 768/2008/EC sets out “general principles and reference provisions for the drawing up of Community legislation harmonising the conditions for the marketing of products”. Therefore it does not deal with technologies (of any kind, either new or old) or processes (e.g. remanufacturing). The NLF focuses on the point in time when a product is marketed which, by definition, occurs only once in the product’s lifetime. In the machinery sector, the safety level of a product is guaranteed by the manufacturer at the time it is placed on the market. This safety level is required to be maintained to the original level during the machine’s lifetime as mandated by other legislation (e.g. the Use of Work Equipment Directive (1). Therefore CECE would like to highlight to the Commission that, the first question proposed in the evaluation roadmap, may be misunderstood. CECE will remain available for clarification and to further support the EU Commission effort in any future development of the NLF evaluation. (1) Directive2009/104/CE
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Response to Requirements for Artificial Intelligence

9 Sept 2020

CECE welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on a proposal for a legal act laying down requirements for Artificial Intelligence. Regarding the different policy options proposed, we would like to share the following comments: - POLICY OPTION 1 For the construction machinery sector, we do not see any benefits of additional requirements for AI-enhanced subsystems in our products, since this is already covered by the Machinery Directive 2006/42/EC; we therefore prefer option 1. For the products of our industry – mobile machinery of all sizes – the Machinery Directive 2006/42/EC, having technology neutrality as one of its core principles, already covers safety for those machines using AI-enhancements for operation. According to the Machinery Directive 2006/42/EC, the manufacturer has to take the necessary measures to eliminate any risk throughout the foreseeable lifetime of the machinery, which includes the phases of transport, assembly, dismantling, disabling and scrapping. This includes any machine learning capabilities. - POLICY OPTION 2 For the products under the scope of the Machinery Directive 2006/42/EC, the CE marking already indicates that the risks associated with state-of-the-art AI-enhancements have been sufficiently mitigated, therefore additional labelling is not necessary. - POLICY OPTION 3A + 3B We reserve our position on option 3 depending on the criteria to be defined for the category of ‘high-risk’ applications. We expect stakeholders (especially the industry) to be thoroughly consulted when those criteria are defined. - POLICY OPTION 3C A legislation covering all types of AI use poses the threat of hampering innovation and putting unjustified burden on many narrow AI-enhanced products; where the AI-enhanced function may have tight operational limits, operates in a low-risk application, or is subject to close human oversight during its entire learning phase. - POLICY OPTION 4 No specific statement for policy option 4.
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Meeting with Gwenole Cozigou (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

12 Feb 2020 · Courtesy meeting to introduce themselves and present their priorities

Meeting with Timo Pesonen (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Oct 2019 · Exchange on standardisation policy

Response to Regulation complementing EU type-approval legislation with regard to the UK withdrawal from the EU (Brexit preparedness)

24 Jul 2018

CECE, representing the European construction equipment manufacturers welcomes the Regulation of the European Parliament and of the Council, complementing EU type-approval legislation with regard to the withdrawal of the United Kingdom from the Union (COM(2018)397 FINAL). The Regulation proposed by the European Commission is highly important for manufacturers of construction machinery in order to secure the continued supply of engines that currently hold a UK type-approval. Moreover, machine manufacturers are now in the process of adapting their production to the non-road mobile machinery engine emission regulation (Regulation (EU)2016/1628) so certainty on the engine type-approval procedure and a sufficient lead-time adoption of the new regulation are crucial. As feedback on the regulation proposal, CECE would like to address the following points and related amendments ( see document attached).
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Response to Regulation complementing EU type-approval legislation with regard to the UK withdrawal from the EU (Brexit preparedness)

10 May 2018

Attached CECE comments on the roadmap for a regulation complementing EU type-approval legislation with regard to the UK withdrawal from the European Union (Brexit preparedness) in relation to Regulation (EU) 2016/1628 concerning the type-approval of engines for use in non-road mobile machinery.
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Response to Noise emission by outdoor equipment

19 Dec 2017

CECE welcomes the evaluation of the Outdoor Noise Directive as the directive needs improvement. CECE is not in favour of a full revision as according to CECE, the directive reached its goal: a significant noise reduction of outdoor machinery leading to the improvement of the level of health and safety of workers, consumers and citizens. Please find the CECE feedback attached.
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Response to Road circulation requirements for mobile machinery

18 Dec 2017

CECE, the Committee for European Construction Equipment, welcomes the initiative of the Commission to fill one of the remaining gaps in the single market: the harmonisation of technical requirements related to road circulation aspects of mobile machinery. Please find the CECE feedback attached.
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Meeting with Jyrki Katainen (Vice-President) and

3 Jul 2017 · Regulatory, trade policy and industrial policy issues of relevance to the European Construction equipment sector

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

28 Jan 2015 · Role of the manufacturing industry in Europe