Construction Equipment Association
CEA
Representative trade association for the construction equipment sector in the United Kingdom.
ID: 316041925182-23
Lobbying Activity
10 May 2018
Comments from the UK construction equipment industry
The Construction Equipment Association (CEA) is the trade association that represents the UK construction equipment sector – and is recognized by HM Government, UK, as the voice of our industry. We are represented in Brussels – as active members of the Committee for European Construction Equipment (CECE) – and our influence is felt worldwide through our technical, regulatory and international trade work.
Observations on the roadmap
CEA welcomes the European Commission proposal to establish a legislative solution for the replacement of UK-issued type-approvals by corresponding approvals issued by EU-27 type-approval authorities. In the absence of a trade deal giving full mutual recognition of type-approvals issued by UK and by EU-27 type-approval authorities, such a solution is absolutely essential to avoid our members, whose products are installed with engines that hold UK-issued type-approvals, being severely disadvantaged when Brexit occurs.
The date of UK withdrawal from the EU of 30 March 2019 comes at a critical time for machinery manufacturers as they implement their phase-in plans for Stage V models. The corresponding concerns faced by equipment manufacturers would therefore be as follows,
1. Concern related to UK-issued EU type-approvals that will be invalidated by the UK withdrawal from the EU
2. Concern related to UK-issued EU type-approvals invalidated by a placing on the market deadline prior to the date of UK withdrawal but which are still relied upon by manufacturers for the placing on the market of non-road mobile machinery
3. Remaining exemptions or derogations issued by the UK and relied upon for placing on the market in the EU.
The attached document covers our concerns relating to the above points in greater detail, addresses mitigation for some of these concerns on which we would welcome the Commissions comment, highlights concern over the schedule for any new regulatory instrument and finally reminds that other internationally recognised approvals exist that should provide manufacturers with an alternative path to conformity after the UK withdrawal.
Read full responseResponse to Road circulation requirements for mobile machinery
15 Dec 2017
This response is on behalf of the Construction Equipment Association (CEA). The CEA is the trade association which represents the UK construction equipment industry, with a value of £11 billion per annum. Member company products include both self-propelled and towed machinery.
The CEA welcomes the Commission's initiative to harmonise the requirements for road circulation of mobile machinery. The current situation represents a serious gap in the Single Market as national requirements in each member state need to be applied. This leads to the need for multiple approval procedures and unjustified product variations from one country to another without any real benefit for road safety.
Legislators need to take account of the very different structure of the construction equipment industry in comparison to the automotive industry. Automotive manufacturers typically manufacture in very large volumes, meaning that the costs of homologation can be recovered at a reasonable rate per unit sold. Construction Equipment is produced in much smaller volumes and many producers are SMEs. This means that any new EU regulation should harmonise approval procedures and maintain the application of self-certification under the Machinery Directive 2006/42/EC for all aspects not related to road use, while keeping costs, third party approvals and additional requirements to a minimum. To this end the CEA view is that the drafting of the regulation should be done in the Commission services with expertise in the machinery as well as the road sector suitable for these products rather than the automotive sector. Legislative solutions which are appropriate to the automotive sector must not inappropriately applied to the machinery sector. The Commission should take particular care that requirements are not introduced where there is no evidence of a genuine problem in the field of machinery travelling on roads.
In drafting legislation it is important that it allows for the EU approval of a full machine rather than only approving safety-critical systems. A regulation which still required national approvals of machinery would be of very limited benefit in comparison to the current situation.
It is crucial that the legislation covers two aspects in relation to trailers. Firstly, the towing of tools, equipment and materials by the machine in subject must be covered. This can be done safely and can reduce road traffic. Secondly, legislation needs to cover towed machinery which is not mounted on type-approved trailers in order to remove the need for multiple national approvals.
The CEA supports the concept of a hybrid legislative solution including elements of both self-certification and third party approval. The construction machinery industry benefits from a comprehensive set of European and International safety standards covering both systems and machines. The CEA recognises that legislators may feel it necessary to include some systems in mandatory third party approval regimes, probably only braking and steering, but urges the Commission to include the option of self-certification aligning with the Machinery Directive wherever possible.
The CEA recognises the need for member states to set their own rules on road usage, such as maximum weights for certain bridges. In order to allow its easy acceptance by legislators the new legislation should be without prejudice to such rules.
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