EUnited European Engineering Industries Association
EUnited
EUnited - European Engineering Industries Association is a Brussels-based service provider for European Engineering industries, specifically for equipment suppliers.
ID: 0289344948-82
Lobbying Activity
Response to Circular Economy Act
6 Nov 2025
EUnited, representing European manufacturers of cleaning systems, municipal equipment, and vehicle wash systems, welcomes the European Commissions initiative for a Circular Economy Act (CEA). The Act provides an opportunity to strengthen the EU single market for waste and secondary materials while ensuring fair and proportionate requirements for industry. EUnited supports the Commissions objectives but underlines several priorities that are essential for the CEAs success: EU-wide harmonisation of end-of-waste, by-product, and Extended Producer Responsibility (EPR) criteria. Diverging national approaches currently fragment the market. An EU-level EPR register would simplify compliance and ensure fair competition. Quality and reliability of secondary materials. High-quality recyclates are vital for professional and industrial equipment. Bio-based content targets should be avoided where they risk contaminating recycling streams or reducing recycled plastic availability. Public procurement as a driver of circularity. Circularity criteria should complement, not replace, performance and safety criteria. Functionality and durability must remain central to public tenders. Recognition of water and resource efficiency. Technologies that enable closed-loop water reuse and recovery in cleaning and vehicle-wash systems should be recognised as best-practice examples under the CEA. Proportionality for SMEs. The Act should include simplified templates, phased timelines, and realistic data requirements for smaller manufacturers. EUnited supports a Circular Economy Act that promotes harmonisation, high-quality recycling, and balanced implementation across all sectors. Our full contribution is attached for the Commissions consideration.
Read full responseMeeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and
29 Jan 2025 · Renew Europe Stakeholder Roundtable: “Elevator Pitch for Better Single Market Rules”
Response to Regulatory measure on the review of ecodesign requirements for industrial fans
25 Oct 2023
EUnited and its Cleaning sector (http://www.eu-nited.net/cleaning) represent the leading producers of floor cleaning machines and high pressure cleaners for commercial and industrial use. Regarding the draft act we would like to submit the below comments. Fans We would strongly recommend to align exemptions within the Ecodesign legislation. In particular, alignment of the Ecodesign Directive Fans No. 327/2011 to the exemptions in Regulation (EU) 2019/1781 "Ecodesign requirements for electric motors". This seems sensible to us, since the fan efficiency refers to the electric input power of the motor-fan system. In this systematic view, regulating individual components of the system does not make sense. Therefore, we ask you again to consider the exemptions of Regulation (EU) 2019/1781, in particular Article 2 (1) a (iv) and Article 2 (2) (j). Consequently, we kindly request the additions of the below exemptions in article 1.3 of the draft implementing act, as follows: (r) non-continuous duty operation and (s) fans in hand-guided mobile equipment moved while in operation; The reasoning put forward in Regulation (EU) 2019/1781 "Ecodesign requirements for electric motors" that led to granting these exemptions is still valid today and thus the draft act should be aligned accordingly, as mentioned above. Machines that use this exemption (for example, high-pressure cleaners (Article 2 (2) j) or blowers of vehicle washing equipment Article 2 (1) a (iv)) have a presence control (shutdown of the machine when not in use) and are used intermittently. This results in a relatively small duty cycle for the motor-fan system. This is offset by increases in weight and size that are associated with increased material consumption. This additional material consumption is in contrast to the resource efficiency, which makes a decisive contribution to the circular economy, and outweighs the small energy savings.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
2 May 2023
EUnited welcomes the proposal for a regulation establishing a framework for setting ecodesign requirements for sustainable products. Improving individual sustainability aspects of a product can have negative consequences on the sustainability of the product in other areas (potential examples can be energy efficiency vs. material increase or long-lasting designs vs. reparability). Therefore, it is important to identify the most appropriate aspects and their interdependences. In particular, we would like to emphasise that we are pleased that the Commission has taken into account the work of CEN-CLC/JTC 10 standards group on standardisation request M/543 while drafting this proposal. Priority products and measures EUnited supports the identified horizontal measures recyclability, post-consumer recycled content and durability (including repair and maintenance according to definition article 2 (21). However, we believe that requirements addressing the maintenance of a product should not be set as a priority. Maintenance requirements are resource intensive to control by Market Surveillance Authorities and furthermore maintenance in our industry is a critical criterion required by the market. Substances of concern Regulating substances of concern under REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and also in the ESPR means double regulating certain substances which should be avoided. For example, the presence of substances of concern (article 5 (g)) is already addressed by the SCIP database as long as they are also identified as substances of very high concern (SVHC). We acknowledge the importance of obtaining the information of the presence of hazardous substances in products to enhance their sustainability but in order to ensure consistency hazardous chemicals shall be addressed by REACH et. al. and the ESPR should focus on substances which negatively affect the re-use and recycling of materials by other means.
Read full responseResponse to Ecodesign requirements for vacuum cleaners (review)
5 Apr 2022
Dear Sir or Madame,
The needs of the users of household and commercial vacuum cleaners are different. Therefore, we advocate taking the differences into account and developing a separate label for commercial vacuum cleaners. In this development, we should draw on the work of the international and European working groups that have dealt specifically with this issue.
An exclusive consideration of energy consumption falls short with regard to the needs of users. In addition to the energy consumption, for commercial users the introduction of a productivity/speed index which is also included in the annual energy consumption calculation, adds considerable value for the customer and user. It creates comparability in the actual core competence of the vacuum cleaner, in cleaning. It has to be ensured, the time to clean the area must be corrected with a cleaning efficiency factor as an effective vacuum cleaner conducts the task a lot faster and uses far more less energy.
Kind regards
Frederik King
Read full responseResponse to Revision of the Machinery Directive
16 Aug 2021
EUnited welcomes the opportunity to provide feedback on the proposed machinery products regulation COM(2021) 202 replacing the Machinery Directive 2006/42/EC. The Machinery Directive (MD) is a cornerstone and key reference for all industry sectors represented by EUnited. Furthermore, the MD has created legal certainty and a high level of harmonisation for our manufacturers over decades when selling into the European Single Market.
Therefore, the proposed machinery products regulation is equally important for the future of our industry in Europe and will determine whether the European Single Market will remain an attractive marketplace for our sectors to invest as well as to deliver jobs, growth and continued innovation.
The harmonised access to the Single Market and legal requirements in the proposed regulation will impact on how the EU compares to other regions in the world at a time when the twin transition towards the green and digital economy transforms our industries. Combined with the impact of the pandemic and economic recovery plans it is of paramount importance to ensure that the machinery products regulation continues to provide first and foremost legal certainty and continued proportionate market access requirements based on Harmonised Standards and presumption of conformity.
In particular Small and Medium Enterprises represented by EUnited, often market leaders in their field, cannot afford to substantially change established procedures and processes that have ensured the highest level of safety and compliance of their equipment over the last decades, unless there are justified and substantial reasons to do so.
Please find attached EUnited’s detailed feedback on the proposed machinery products regulation.
Read full responseResponse to Ecodesign and energy labelling working plan 2020-2024
2 Jun 2021
EUnited Cleaning represents the leading producers of floor cleaning machines and high-pressure cleaners for
commercial and industrial use. It represents the interests of its members in all economic and technical matters with
politicians, legislators, customers, research and education, trade fair companies, the press, and the public.
In regard
to the preparatory study for the Ecodesign and Energy Labelling Working Plan 2020-2024 we want to express the
following opinion.
It is essential for us that the expansion of existing requirements, the inclusion of new requirements and the
judicially verifiability by the market surveillance authorities must be mutually dependent, as otherwise no legal
certainty will be created for all parties involved.
More specific comments are attached.
Read full responseResponse to Requirements for Artificial Intelligence
10 Sept 2020
EUnited is convinced that artificial intelligence (AI) drives and contributes to the digital and green transformation. It can do so across a broad range of sectors from healthcare to manufacturing and beyond, which in turn will lead to badly needed economic growth and the ability to meet numerous other societal challenges.
EUnited supports the principle and pursuit of trustworthy, human-centric, and ethical AI in Europe. Nevertheless, it reminds the Commission that – contrary to the statements made in the Inception Impact Assessment - the reality today is that uptake and investment in AI is greatest in areas of the world where no regulation yet hampers or stifles its deployment. Europe is currently losing the global AI race. The stipulation of trustworthy AI being the major force for gaining a competitive edge vis-à-vis China and the US is unrealistic. We believe it is therefore of vital importance to strike the right balance between EU intervention on the one hand and ensuring the competitiveness and innovation potential of our businesses, whilst protecting the rights of our citizens, on the other. In general, we believe that more work can be done to boost EU businesses by, for example, open-sourcing datasets and sharing ongoing research. Finally, it should also be pointed out that the compliance costs related to - what might appear to be only minor regulatory interventions - may be decisive for the competitiveness of many European businesses, especially SMEs.
EUnited favours Policy Option 1 contained in the Inception Impact Assessment (IIA). We believe that this soft law approach could quickly allow industry to harness the potential of ongoing national initiatives thus increasing uptake of AI systems across many industrial sectors and thereby accelerating the green and digital transformation. A good way to ensure that the complex socio-technical systems being created with AI will in practice adhere to ethical standards is to actively involve all people devising and implementing such systems. Option 1 ensures the involvement of those taking responsibility and accountability for the ethical implications. At this stage a soft law approach is preferable to risking a serious disturbance of this transformation. Such disturbance could arise as a result of a lengthy and difficult legislative procedure borne out of the desire to introduce hard law to regulate only a very few contentious applications, already covered by other parts of EU law (e.g. data, privacy, safety and liability).
Whilst EUnited also believes that there may be some benefit to pursuing regulation for highest risk applications (i.e. Policy Option 3(1)), we think that it is premature given the difficulties we will inevitably face in distinguishing risk levels related to vastly different use-cases of similar or identical applications, all in a rapidly evolving context. To put it another way, an application such a facial recognition could be totally benign or extremely risky depending on the use-case. Sectors such as ours rely heavily on innovation through offering new functionalities to the customer. Indeed, this is the key to remaining competitive. So a one-size-fits-all approach to the regulation of different applications of AI is not in the interest of Europe. EUnited therefore clearly rejects an Option 3(3) approach. It adds no additional benefit while seriously damaging European competitiveness.
The potential for European industry to support the green and digital transformation through uptake of AI shouldn’t be overlooked. The European institutions should keep the competitiveness of Europe at the forefront when considering any legal intervention on AI, particularly given the breadth of coverage of the exiting legal framework. EUnited recommends the approach set out in Policy Option 1 to best strike the balance at this stage.
Read full response30 Jul 2018
EUnited Municipal Equipment, the European Association representing the leading manufacturers of mobile machines used in municipalities and other public areas like road sweepers, refuse collection vehicles, multi-equipment carriers, snow ploughs, salt spreaders and others, welcomes the new proposal of the European Commission for a regulation on EU type-approvals obtained from the UK type-approval authority (COM(2018)397). It is essential for all companies within the municipal equipment industry that they can continue to produce and place their products after the withdrawal of the UK from the EU on both, the EU market and in the UK whereby any discrimination of manufacturers on both sides must be avoided. Therefore, EUnited Municipal Equipment fully supports the draft Regulation and proposes some amendments for its improvement in order to ensure that those already granted but also future type approvals of engines, systems and components for completed vehicles will also be further mutually recognised. It is extremely important for manufacturers to obtain legal certainty with sufficient lead time.
The detailed EUnited Municipal Equipment position is attached.
Read full responseMeeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)
7 May 2018 · EU Trade Policy and potential impact of looming trade wars on European industrial competitiveness