OpenLobby.EU
Explore

European Garden Machinery industry Federation

EGMF

The European Garden Machinery Industry Federation represents manufacturers of garden, landscaping, and forestry equipment.

Lobbying Activity

Garden machinery federation urges exemptions for chemical spare parts

14 Dec 2025
Topic — The initiative restricts medium-chain chlorinated paraffins under the EU's persistent organic pollutants regulation.
Message — EGMF requests including garden machinery in exemptions for repair parts and a higher concentration limit. They also propose an 18-month transition period and an exhaustive substance list.123
Why — These changes would ensure repair part availability and reduce legal risks for manufacturers.456
Impact — Environmental groups lose as higher chemical limits allow more persistent pollutants.7
Read full response

Response to Revision of the 'New Legislative Framework'

1 Sept 2025

The European Garden Machinery Industry Federation (EGMF) welcomes the opportunity to respond to the European Commissions Call for Evidence on the revision of the New Legislative Framework (NLF) and to contribute our perspectives on ensuring that future EU product legislation is both robust and future-proof. Please find attached EGMF's recommendations to the call for evidence in view of the revision of the NLF.
Read full response

Garden machinery industry welcomes delay in battery due diligence rules

30 Jul 2025
Topic — The consultation concerns amending the EU Batteries Regulation regarding due diligence obligation deadlines.
Message — The associations support the two-year postponement and propose a two-stage approach for requirements. They request using self-declarations until official guidelines and accreditation standards are finalized.12
Why — This extension prevents compliance failures while necessary standards and guidelines are missing.3
Read full response

Response to Revision of the Standardisation Regulation

18 Jul 2025

The European Garden Machinery Federation (EGMF) represents large and small manufacturers of garden, landscaping, forestry, and lawn maintenance equipment. EGMF welcomes the opportunity to provide input to the European Commissions Call for Evidence on the revision of the Regulation (EU) No 1025/2012 and would like to share our thoughts regarding the current process for the harmonisation of standards. Further details can be found in the attached document providing EGMF recommendations for the revision of the Standardisation Regulation and the future of the ESS.
Read full response

Meeting with Elisabetta Gualmini (Member of the European Parliament)

11 Jun 2025 · AGRI Committee

Meeting 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”

Garden machinery federation seeks UV-328 spare parts derogation

21 Aug 2024
Topic — Amending the Persistent Organic Pollutants Regulation to include UV-328 as a restricted substance.
Message — EGMF requests an exemption for spare parts for garden and outdoor power equipment. This would allow the repair and reuse of machines placed on the market before the restriction.12
Why — This allows manufacturers to avoid costly re-engineering and testing of replacement components.3
Impact — Environmental advocates lose as persistent pollutants remain in circulation via replacement parts.4
Read full response

Response to Rationalisation of reporting obligations

13 Dec 2023

Introduction EGMF, the European Garden Manufacturing Industry Federation, represents the major manufacturers of garden, landscaping, forestry and turf equipment. Through its 31 European corporate members and 7 National Associations, EGMF represents over 18 million units placed on the European market, accounting for around 80% of garden machinery, and EGMF members employ over 120,000 people in the EU. EGMF wishes to express its positive reaction to the proposed Directive and would like to support it by highlighting the implications such a Directive would have on European garden machinery manufacturers, specifically in the field of outdoor noise. Proposed amendments to Directive 2000/14/EC Under Article 2, the proposed Directive amends Directive 2000/14/EC by deleting Articles 16 and 20(1), point (a). The mentioned articles introduced the requirement for the manufacturer, or their authorised representative established in the Community, to send to the responsible authority of the Member State where they reside or where they place on the market or put into service the equipment in scope of the Directive, and to the European Commission, a copy of the European Commission declaration of conformity of each type of equipment falling under the scope of the Directive. EGMF is very supportive of the proposal of the European Commission to delete such requirements. Currently, they represent a financial, administrative, and time-consuming burden that we believe is disproportionate to the benefits they provide. The database, established 20 years ago, aimed to offer an online resource for consumers to assist in choosing quieter equipment. However, this benefit was never actually realised. Currently, the online tool is nearly obsolete and rarely visited by end users. The interest of stakeholders has simply never been strong enough to actively change this situation. The removal of these requirements would streamline the process for manufacturers, reducing unnecessary bureaucracy and allowing for a more efficient allocation of resources. EGMF members estimated that the mentioned reporting requirements are currently weighing for a total of approximately 1 million euros per year. Such a figure was calculated by multiplying the average number of yearly hours utilised by a manufacturer to fulfill the reporting requirements per the average hourly cost of the human capital, per the total number of EGMF manufacturing companies (31). In addition to the above-mentioned financial burden, manufacturers are also required to spend time finding the correct address when attempting to email the declaration of conformity to member states. Our experience shows that these addresses periodically change but our members are not advised of the change and only find out when their emails bounce back. They are then required to spend up to several hours trying to find the correct, updated address. This adds to the reporting burden without providing any benefit. Conclusion The significant financial burden, when considered alongside the administrative load, clearly illustrates the need for a more streamlined and efficient approach. The proposed amendments would not only alleviate these burdens but also enable manufacturers to redirect their resources towards more productive and innovative endeavors. This reallocation could lead to advancements in technology, improvements in product quality, and heightened environmental standards, ultimately benefiting consumers and contributing to the EUs broader sustainability goals. Moreover, the proposed amendments can lead to a more efficient regulatory environment. By eliminating redundant and overly burdensome reporting requirements, regulatory bodies can focus their efforts on more critical areas that require oversight. This shift can lead to a more effective regulatory framework that better serves the interests of both the industry and the public.
Read full response

Meeting with René Repasi (Member of the European Parliament, Rapporteur) and European Consumer Electronics Retail Council

29 Aug 2023 · Exchange of Views on the Right to Repair/ Recht auf Reparatur (R2R)

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

19 Jun 2023

EGMF, the European Garden Machinery Federation, welcomes the European Commissions proposal to amend the RED Delegated Act on the essential requirements in article 3(3) (d,e,f) in terms of postponing the application date to 1 August 2025. The one-year extension will give manufacturers additional time to complete the required testing and redesign of their products to meet the requirements of the Delegated Act. At the same time, it is crucial that the harmonised standards foreseen to be developed should be made available with no undue delays, so that manufacturers could use them sufficiently in advance before the implementation date, to demonstrate compliance with the three RED essential requirements.
Read full response

Response to Update of the methods of measurement of airborne noise emitted by equipment for use outdoors

1 Jun 2023

EGMF, the European Garden Machinery Federation, wishes to express its gratitude that the European Commission accepted many of our proposals during the development phase of the draft Delegated Regulation. Further, we are grateful for the opportunity to also contribute to the ongoing consultation on the proposed Delegated Regulation covering Annex III of the Outdoor Noise Directive. Our views are stated in the position paper attached below.
Read full response

Response to Road circulation requirements for mobile machinery

26 May 2023

EGMF, the European Garden Machinery Federation, welcomes the European Commission proposal on the road approval of non-road mobile machinery. We believe that this legislation is an effective contribution to further deepen the Single Market, by harmonising road circulation requirements for mobile machinery. We also think the upcoming Regulation will cut unnecessary costs and remove disproportionate administrative burden on mobile machinery manufacturers, including manufacturers of garden machinery and outdoor power equipment. As the European federation representing the interests of major garden, landscaping, forestry and turf equipment manufacturers, we would like to highlight the specific concerns and challenges that our sector identified in the context of this legislation: Definitions: EGMF requests a more precise definition of 'non-road mobile machinery' to prevent misinterpretation. We propose to delete the last part of the sentence from the definition provided by the European Commission. General obligations: EGMF proposes to delete specific wording in the regulation to avoid legal ambiguity regarding non-road mobile machinery placed on the market that is not intended to circulate on public roads. It must be clear that machines not intended to circulate on public roads can still be placed on the Single Market, as compliant with the Machinery Directive. Establishment of the forum: EGMF calls for mandatory, rather than optional, industry representation in the Information Exchange Forum, so to facilitate the uniform interpretation and implementation of the Regulation. Transitional provisions: EGMF demands explicit clarification that machinery outside this regulation can continue following national legislation beyond the 8-year transition period.
Read full response

EGMF Urges Harmonised EU Rules for Packaging and Labelling

30 Mar 2023
Topic — EU review of packaging requirements to support waste prevention and recycling.
Message — They request uniform labels and digital QR codes for disposal information. Companies should register for waste management in one country only. They also request a forty-eight-month implementation delay for the industry.123
Why — Standardisation would lower operational costs by ending the need for country-specific packaging.45
Impact — End users could lose access to information if labels are omitted.6
Read full response

Response to Sustainable Products Initiative

22 Jun 2022

EGMF is the European federation representing major garden, landscaping, forestry and turf equipment manufacturers. Through its 30 European corporate members and 7 National Associations, EGMF represents 18 million units placed on the European market and its members employ over 120,000 people in the EU. As an industry that is already heavily investing into innovation, high-quality and sustainable solutions, we welcome the European Commission’s ambitious push for a more circular and sustainable European economy, facilitating the development of innovative and environmentally friendly products. In this context we also appreciate that the Commission correctly identified that harmonized, common European rules are key in ensuring a level playing field and fair competition. The proposal for an ESPR can avoid fragmented efforts of member states, hindering the free movement of goods in the European single market, and align the different approaches of countries in a multi-speed Europe. The design of the proposal as a regulation and strengthening market surveillance authorities are key in ensuring a level playing field across the single market and help to achieve these goals. However, to make sure these benefits can be realized, it is of great importance to make sure that the ESPR performance and information requirements are enforceable, measurable and comparable across product groups. Furthermore, these requirements should be subjected to a diligent impact assessment, to identify those parameters which have the greatest impact on the sustainability and circularity of a given product group and achieve the best results possible. For these reasons, we support a product-by-product approach, taking into account the specific properties of each product group. These challenges for the ESPR can from our point of view best be solved using the advantages of standardization, which has already proven in the past to be an effective way of assuring measurability and comparability. We recommend setting a ESPR standardization roadmap and support developing these standards in a timely manner to ensure a smooth transition for economic operators and an expedited implementation of the ESPR. To assist this endeavor, we are willing to contribute to the standardization process with our technical knowledge and resources. If the establishment of a Digital Product Passport (DPP) is necessary for a given product group, we appeal those databases like EPREL and SCIP are not duplicated. We also urge the granularity of the data to be assessed on a product-by-product basis and to include information requirements that are only relevant for circularity and sustainability. As product groups differ substantially, it is equally important for the comparability of the information provided by the Digital Product Passport that it is based on standards, which are developed in close cooperation with the industry, and follows a product-by-product approach, including only the information that is applicable to each product group. For these reasons, DPPs should not be introduced for components. As part of the DPP, information on chemicals should remain manageable and proportionate for each product group. To facilitate this, a defined list of substances of concern, hindering circularity, is needed, being based on existing chemical legislation, e.g. REACH, RoHS and POP, to avoid double regulation and fragmentation of requirements. Lastly, to keep the impacts of the ESPR proportionate and maintain the competitiveness of all economic actors, including SMEs, third party verification of conformity should be a last option that needs to be supported by objective data. With the CE Marking and self-assessment the EU already has a valid and well-established instrument in place. We thank the Commission for this chance to be in dialogue and are looking forward to further involvement as stakeholders in the ESPR legislative process.
Read full response

Response to Empowering the consumer for the green transition

23 May 2022

EGMF - the European Garden Machinery Industry Federation, welcomes the opportunity to provide feedback on the European Commission’s legislative proposal on the ‘Empowering the consumer for the green transition’ initiative. We acknowledge the necessity to provide consumers with environmental/sustainability information that is understandable, straightforward, and not misleading, and to make the final legislation fit for purpose. To support these efforts, we would like to raise the following key points: - The issue should be tackled through a unified approach at the European level: all measures must be based on EU standards and law, rather than individual and fragmented Member States’ initiatives and interpretations, with the French Repairability Index being a prime example of such. - We also call for full harmonisaton of the use of standards and EU legislation application, and caution against multiplying and overlapping with other measures, such as the Commission’s proposed revised Ecodesign for Sustainable Products Regulation (ESPR), the upcoming legislative proposal on Substantiating Green Claims using the PEF/OEF methods, and any other labeling requirements. - Lastly, we call for the educational measures, like environmental literacy and awareness-raising campaigns, to complement labels in terms of influencing consumer behaviour. For more details and examples, please read our attached position paper.
Read full response

EGMF urges faster EU electronics exemption renewals

14 Mar 2022
Topic — EU initiative to simplify and improve rules restricting hazardous substances in electronics.
Message — The group wants faster chemical exemption renewals and standardized industry definitions. They support turning the directive into a regulation while opposing a merger with REACH.123
Why — This would provide better business predictability and reduce compliance costs for manufacturers.45
Read full response

Garden machinery federation urges faster electronics exemption renewals

14 Mar 2022
Topic — The European Commission is reviewing rules restricting hazardous substances in electronic equipment.
Message — The federation calls for turning the Directive into a Regulation for better harmonization. They demand a more efficient exemption renewal process to remove business uncertainty.12
Why — This would provide manufacturers with greater predictability and reduce long-term compliance uncertainties.3
Impact — Supporters of a unified chemical policy lose the chance to streamline regulations.4
Read full response

Garden machinery industry urges streamlined EU electronics rules

14 Mar 2022
Topic — This consultation reviews European rules restricting hazardous substances in electrical and electronic equipment.
Message — EGMF requests a more efficient exemption renewal process to reduce manufacturer uncertainty. They support transforming the Directive into a Regulation while opposing its merger into REACH. They also call for a uniform definition of non-road mobile machinery.123
Why — A regulation would provide legal certainty while streamlining the inefficient exemption process.45
Impact — Advocates for streamlined environmental law lose if electronics remain separate from REACH.6
Read full response

Garden machinery industry backs transforming RoHS into EU regulation

14 Mar 2022
Topic — EU consultation on revising rules for hazardous substances in electronic products.
Message — The group supports transforming the Directive into a Regulation to ensure harmonization across Europe. They want to simplify the inefficient process for renewing exemptions and oppose merging RoHS into the REACH Regulation.123
Why — A Regulation would provide manufacturers with greater legal and business predictability.45
Impact — Recycled material suppliers lose market share because rules currently favor virgin materials.6
Read full response

Response to Smartwatches and connected toys

24 Aug 2021

The European Garden Machinery Federation (EGMF) welcomes the opportunity to provide feedback on the European Commission Delegated Regulation concerning the essential requirements for radio equipment referred to in Article 3(3), points (d), (e) and (f), of Directive 2014/53/EU. EGMF believes that the proposed date of application, as identified in Article 3 of the Regulation, does not allow sufficient time for the development of the relevant harmonised standards. The current text proposes an application date that occurs only 30 months after the date of entry into force of the Regulation. This does not allow sufficient time for stakeholders to develop the appropriate and very necessary harmonised standards. Our position is that at least 36 months will be required to develop these harmonised standards, hence we call upon the European Commission to adapt Article 3 to mandate that the date of application of the Regulation occurs at least 36 months after its date of entry into force. Additionally, we would like to point out that there are some editorial matters that need to be corrected. The sequence of the lettered indents in Article 1, paragraph 2, requires attention since there are currently two occurrences of indents with reference “a”. Finally, EGMF is pleased to attach its position paper “EGMF input on draft Delegated Act on RED (2104/53/EU) Article 3 (3) (d) (e) and (f)” that was previously submitted to the European Commission in March 2021. We remain at your disposal should you require any further explanation on the above items.
Read full response

Response to Revision of the Machinery Directive

9 Aug 2021

The Machinery Directive is undoubtedly a core internal market legislation that has been successfully applied by manufacturers of garden machinery and outdoor power equipment since 2006. This piece of legislation provides our industry with the necessarily stability in the EU legislative framework for more than a decade. The European Commission’s proposal revising the Machinery Directive suggests updates for a coherent internal market framework and includes new elements to enhance digitalisation of instructions, which EGMF supports. The Commission also proposes to address new challenges from emerging technologies and to adapt existing requirements, which EGMF has some concerns about since they will have significant consequences for our industry. Please find attached the EGMF position paper in attachment.
Read full response

Response to Standardisation Strategy

6 Aug 2021

EGMF (European Garden Machinery Federation) would like to put forward its views and recommendations regarding the questions outlined in the Roadmap on the upcoming Standardisation Strategy. Please find our input in attachment.
Read full response

Response to Ecodesign and energy labelling working plan 2020-2024

31 May 2021

EGMF – the European Garden Machinery industry Federation, strongly supports European initiatives aiming to encourage sustainability and achieve a circular economy. As an industry close to nature, improving and promoting the sustainability of outdoor power equipment and services is a strategic priority. In the preparation of the Ecodesign and Energy Labelling Working Plan 2020-2024, we would like to submit comments on the concept of universal batteries. EGMF welcomes the absence of such a measure in the European Commission’s Roadmap, in line with the recommendations of the preparatory study. Not the legislation, but innovation, competition and safety should remain the main drivers for the electrification of our industry and the development of interoperable battery systems. Innovation is essential answer to global competition and contribute to the sustainable growth agenda. We strongly believe that interoperable batteries should remain a voluntary initiative. In addition, we would like to further bring attention on key aspects in view of any future discussions regarding universal or interoperable batteries: 1. The battery is an essential part of cordless garden machinery and outdoor power equipment since it influences its performance and consequently efficiency; 2. Free competition is a key driver for innovation and competitiveness; 3. Satefy should remain the first priority and cannot be compromise; 4. Backward compatibility - one of specificities of our industry - contributes to material and energy savings.
Read full response

Response to Sustainable Products Initiative

9 Nov 2020

EGMF - the European Garden Machinery Industry Federation - fully supports the European Commission’s ambition to realise a circular economy. The European garden and outdoor power equipment industry shares with households, municipalities, landscapers, greenkeepers, gardeners and farmers the responsibility for green area maintenance and food production. As an industry close to nature, we depend on the protection of the environment for our jobs and businesses. In addition, our customers rightly expect to maintain their green areas not only efficiently, but also with minimum impact on the environment in general. Quality, safety, resource efficiency and environmental performance are key priorities for our industry. Therefore, manufacturers of outdoor power equippment are already taking measures to minimise the life-cycle impact of their products in the environment. They are addressing some issues targeted in the Sustainable Products Initiative, such as the design of durable and reliable products, application of material efficiency and hazardous substances substitution, reparability and extending product lifetime. In this context, EGMF welcomes the European Commission’s proposal to introduce a sustainable product policy framework to help guide further changes in products to reduce the overall climate and environmental footprint of the products across their entire life-cycle. According to the ‘inception impact assessment’, the Commission envisages setting out this new initiative by expanding the Ecodesign Directive to non-energy related products and apply it to the broadest range of products. From an industry perspective, the Ecodesign framework has played vital role in reaching Europe’s energy efficiency objectives and driving European manufacturers towards more sustainable design characteristics through a holistic approach. We believe that the Ecodesign framework should not be expanded to non-energy related products but maintained for energy related-products to secure investment and legal clarity. The future sustainable product policy should provide a coherent and stable legislative framework, which should fully embrace the technology neutrality principle. Neutrality is essential to support innovation, allowing the widest variety of technology options applicable to sustainable design requirements and choices related to material efficiency. In addition, synergies with other pieces of product legislation and EU acquis, notably chemicals or waste-related policies, should be optimised but should remain addressed under their respective legal frameworks. The European market should not be distorted or hinder innovation by overregulation.
Read full response

Response to Requirements for Artificial Intelligence

9 Sept 2020

EGMF, the European Garden Machinery Federation, would like to provide its feedback in the attachment, on the Commission inception impact assessment regarding a proposal for a legal act on AI requirements.
Read full response

Response to Empowering the consumer for the green transition

1 Sept 2020

EGMF welcomes European initiatives aiming to encourage more sustainable consumption patterns and empower consumers to participate in the Circular Economy and European Green Deal agenda. Quality, safety, and environmental performance are key priorities driving manufacturers of garden machinery and outdoor power equipment. As an industry close to nature and driven by innovation, improving and promoting the environmental sustainability of products and services is a strategic priority for our sector. Our industry manufactures long-life durable products and already provides consumers with relevant repair information and services. In this context, we welcome the opportunity to provide comments to the public consultation on the Inception Impact Assessment on “Empowering the consumer for the green transition”. EGMF supports the European Commission objective to empower consumers to play a more active role in the green transition by enabling an informed purchase decision. EGMF acknowledges the need to provide consumers with environmental/sustainability information that is understandable and straightforward. In addition to clear and precise information, we believe that the process of consumer empowerment through education has great potential. Focusing on empowerment as a process calls for improving access to information and consumer´s ability to assess it. It is vital to improve consumers’ understanding on the various types of information provided to them, so they can make more informed and educated choices on how their purchasing decisions contribute to the EU’s sustainability agenda and environmental objectives. It is important to consider the intended audience of the supplied information, as not all information is appropriate or useful to consumers. Any new information requirements should take into consideration and be adapted to consumer needs. Furthermore, focusing only on remedies, like labels, is not enough to change consumer behaviours. Consumer information needs to be complemented by additional educational measures, like promoting environmental literacy and awareness-raising campaigns. We acknowledge that labels have a significant influence on consumer purchasing decisions. However, labels need to be logical, easily understood, and refer to transparent criteria to be effective. If all data about sustainability aspects, like environmental characteristics, durability and reparability, are aggregated into one label with a single score, there will always be a risk of misinterpretation, false claims and confusion. Moreover, we support a unified approach, at least at the European level, since the outdoor power equipment is often designed for the global market. Today, the proliferation of sustainability logos, labels and marks in the different EU Member States, being voluntary or mandatory, results in more confusion for the consumer. They also damage the functioning of the EU Internal Market as they create new trade barriers. This is particularly true when national requirements impose the use of national logos and marks, while penalising the use of other symbols. Finally, the multiplication of mandatory information, labels, and marks can be challenging, especially for smaller hand-held machines.
Read full response

Response to Modernising the EU’s batteries legislation

8 Jul 2020

EGMF members produce a very wide variety of equipment covering a large range of products, in terms of size and usage, for landscaping, forestry, turf maintenance and food production. Within our product portfolio, a wide range of products are battery operated, such as hedge trimmers, leaf blowers, brush cutters, chainsaws, shrub shears, robotic and walk-behind mowers and golf carts. Driven by innovation, our industry has been developing new solutions to limit the environmental impact of its products for many years. Our companies have been ahead of the curve to develop high performing battery equipment, enhancing the electrification of the garden and outdoor power equipment sector. As an industry close to nature, the garden machinery industry supports the European Commission’s objective to develop more sustainable batteries in Europe. We also support a European legislation addressing challenges posed by the increasing number of batteries placed on the European market. We welcome the opportunity to comment on this initiative. In this context, we would like to highlight key elements the future legislation should consider: 1. The existing battery categories (portable/industrial/automotive) should be maintained, but further clarification on the scope is necessary, particularly between portable and industrial batteries. We strongly discourage such a differentiation by the introduction of weight thresholds as it would create arbitrary distinctions between batteries which are essentially the same. 2. Collection targets should be calculated based on the amount of batteries available for recycling instead of the amount of batteries placed on the market. This is particularly necessary for batteries which are used in products with long lifetimes and experiencing rapid growth such as the ones in our industry. 3. Measures on substances used in batteries should avoid overlaps with existing chemicals legislation. Any new restrictions should be adopted under the REACH Regulation. 4. Communicating information to waste recyclers on battery chemistry is necessary. There are existing standards within our industry such as EN 62841-1 Annex K and EN 62133/ EN 61960 for this purpose. Colour coding schemes on casing should be discouraged as it could merge with the company branding and therefore be indistinguishable. 5. The limitation of primary batteries is a positive goal. However, the European Commission should differentiate between non-reusable portable batteries such as D (Mono), C (Baby), AAAA, AAA (Mikro), AA (Mignon), etc. Within our industry we use non-reusable primary batteries which are designed to last the entire product lifetime, such as batteries integrated in circuit boards. The existing legislation should therefore not penalise these long-lasting and high performance non-reusable batteries. 6. In the development of more sustainable goods, we strongly support the reparability of garden and outdoor power equipment, including the replacement of batteries. However, we would like to draw attention to the important safety risks associated with disassembly / reassembly of batteries linked to fires and overheating. 7. Increasing the amount of recycled content in batteries is a positive goal but it should be aligned with existing market realities. A key barrier to the uptake of recycled content is the quality, purity and availability of secondary raw materials. Before introducing requirements in this respect, it should be ensured that the secondary raw materials are suitable and do not pose any technical and safety risks for the end-users. 8. Lastly, we welcome the initiatives to improve the sustainability requirements for batteries. We note that however some of these requirements, such as interoperability, could stifle innovation while competition should remain the main driver of technological progress.
Read full response

Garden machinery industry urges impact assessments and coherence

19 Jun 2020
Topic — The Commission’s strategy aims to protect citizens and environment from hazardous chemicals.
Message — EGMF requests legislative coherence to eliminate overlapping requirements and conflicting demands. They advocate for detailed impact assessments for bans to ensure functional alternatives exist.12
Why — Mandatory assessments and transition periods would preserve the industry's global competitive position.3
Impact — Environmental advocates lose when economic parity requirements delay the removal of hazardous substances.4
Read full response

Garden machinery federation supports renewing lead solder exemption

28 Aug 2019
Topic — The EU is consulting on lead use exemptions for hand-held engines.
Message — The federation supports renewing exemption 41 for lead in hand-held engines. They argue that suitable alternatives for lead applications are not currently available.12
Why — This allows manufacturers to avoid using substitutes that lack required safety levels.3
Read full response

Response to Revision of the Machinery Directive

8 Feb 2019

Please find in attachment the EGMF (European Garden Machinery Federation) input on the inception impact assessment on the revision of the Machinery Directive.
Read full response

Response to Sustainability requirements for batteries

5 Feb 2019

Please see attached.
Read full response

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

24 Jul 2018

EGMF would like to put forward the enclosed position paper on EC proposal complementing type approval legislation in view of UK withdrawal from the EU.
Read full response

Response to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)

16 Mar 2018

Please find attached the EGMF input on the Commission proposal for a Regulation on enforcement of and compliance with Union Harmonisation legislation.
Read full response

Response to Noise emission by outdoor equipment

20 Dec 2017

EGMF is the European federation representing major garden, landscaping, forestry and turf equipment manufacturers. Through its 30 European corporate members and 7 National Associations, EGMF represents over 17 million units placed on the European market and EGMF members employ over 120,000 people in the EU. Today, more than a quarter of equipment falling under the scope of the Outdoor Noise Directive (OND - 2000/14/EC) is garden and outdoor power equipment. Therefore, EGMF would like to submit its views on the European Commission’s inception impact assessment on the OND review. The inception impact assessment identifies a series of problems related to the OND and its implementation. EGMF believes that it correctly points out the lack of adaptation to technical progress, notably conformity assessment procedures and measurement methods. In line with EGMF comments raised in previous position papers, this document highlights the administrative and reporting burdens and legal issues due to non-alignment with the New Legislative Framework (NLF). Therefore, EGMF supports a full revision of the Directive, including substantial amendments to the current legal act (‘Policy Option’ 3). Indeed, we believe the two alternative options (the status-quo and the NLF alignment together with conversion to a Regulation) will not properly address identified shortcomings. In view of the review, EGMF calls on the European Commission to adapt the conformity assessment procedures: self-certification should be enabled for all product categories. This would reduce administrative burden, simplify the compliance process, reduce time to place products on the market and lower costs for manufacturers. Moreover, EGMF calls for effective and pro-active market surveillance, including physical testing of products. We also support adapting the noise measurement methods (test codes) to technical progress in the industry and European standardisation. Moreover, we suggest removing them from the main body of the legal text to facilitate their regular update. Reference to the same standards in both the OND and the Machinery Directive should become the rule to avoid duplication of measurements and ineffective use of resources. However, EGMF suggests keeping the current scope, including the classification split between equipment subject to noise limits (Article 12) and equipment subject to noise marking only (Article 13). Generally speaking, we ask that current noise limits be maintained. However, the noise limits of specific electrically-powered products, notably lawn trimmers, need to be reviewed in the context of market developments. In addition, we strongly disagree with the ‘Inception Impact Assessment’ statement that a reduction in noise limits will improve working conditions for equipment, in the sense of better performance and reduced emissions. On the contrary, this will negatively impact equipment performance, increase usage time and reduce safety, notably for hand-held tools. In addition, operator exposure to noise emissions is covered by the Machinery Directive, while the OND is aimed at reducing noise in the urban environment to improve general human health and well-being. Finally, we suggest withdrawing the current database since it does not fulfil its objective and merely creates administrative burden for the European Commission, Member States and industry.
Read full response

Response to Road circulation requirements for mobile machinery

14 Dec 2017

Please find the EGMF feedback attached.
Read full response

Response to Ecodesign requirements for electronic displays

18 Jan 2017

EGMF is the European federation representing major garden, landscaping, forestry and turf equipment manufacturers. Several types of EGMF equipment will be impacted by the Ecodesign regulation on electronic displays as currently drafted. Indeed, electronic displays are integrated into various types of garden machinery equipment, notably lawnmowers, such as ride-on-mowers and robotic mowers. Therefore, EGMF would like to provide its views on the draft Ecodesign regulation on electronic displays in the context of the public consultation. First, the Ecodesign Directive (Article 15.4(b)) requires that an assessment be carried out to consider impacts on the environment, consumers, manufacturers, innovation, costs and benefits. This impact assessment has not been done for a vast range of equipment affected by the current scope, including garden and landscaping equipment. In addition, the Ecodesign Directive (Article 15.4(d)) requires an appropriate consultation with stakeholders during the preparation of a draft implementing measure. Product manufacturers integrating displays into other equipment, such as EGMF members, have not been contacted and the present consultation is, in our view, insufficient. Therefore all displays integrated, or intended to be integrated, into other products should be excluded. We suggest amending Article 1.5 of the draft regulation by a derogation for “all displays integrated into or intended to be integrated into other products, except TVs and computer monitors”. We believe that displays “intended to be integrated into” should benefit from a similar exclusion as that which applies to integrated displays. This is necessary to ensure fair treatment of displays placed on the EU market prior to their integration. Otherwise, the regulation may result in market distortions, notably between equipment manufactured in the EU and imported equipment. Our concerns on the need to exclude displays “intended to be integrated into” also arise in the current Article 1.4. The regulation should also exempt displays “intended to be integrated into” industrial machinery (Article 1.4(f)) and equipment whose main function is status display or control and function activation (Article 1.4(g)). As far as resource efficiency requirements are concerned, the current draft regulation raises uncertainties on the share of obligations, notably for displays integrated into other products. It is unclear which requirements should be fulfilled by display manufacturers and equipment manufacturers. Finally, allowing only the use of double-sided adhesive tape to seal some components, such as batteries and display panels, inside the electronic display is far too intrusive and prescriptive. Such a requirement could negatively impact the functionality of the product, notably in harsh environment, and industry’s competitiveness. This conflicts with the criteria for Ecodesign implementation measures, provided in Article 15.5 of the Ecodesign Directive, such as not imposing negative impact on industry’s competitiveness and proprietary technology on manufacturers.
Read full response