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Fédération des Industries Mécaniques

FIM

La FIM a pour objet la défense des droits ainsi que des intérêts matériels et moraux des professions des syndicats membres, notamment : - La représentation commune de ces syndicats auprès des pouvoirs publics ainsi qu'auprès de tous groupements ou organismes en France ou à l'étranger - L'étude des questions professionnelles d'ordre économique, technique, juridique, fiscal, social, commercial qui présentent un intérêt pour les syndicats ou leurs membres

Lobbying Activity

Meeting with Martin Lukas (Director Trade)

9 Dec 2025 · Meeting between FIM and DG Trade, Trade Defence Service

Meeting with Marion Maréchal (Member of the European Parliament)

2 Dec 2025 · Droits de douanes et CBAM

Meeting with Julie Rechagneux (Member of the European Parliament)

2 Dec 2025 · Consultation industrie française sur les mesures de sauvegarde

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis) and

18 Nov 2025 · Competitiveness and simplification

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Response to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252

25 Jul 2025

We identify a risk of double regulation between national measures on circularity and the WEEE Directive, which will soon be revised and is expected to include provisions on critical raw materials. We recommend that, when publishing the list of products, components and waste streams that shall at least be considered as having a relevant critical raw materials recovery potential, the European Commission also specifies that national measures should focus on product categories that fall outside the scope of the WEEE Directive. We also identify a risk of double regulation, overlap or inconsistencies with the ESPR. We urge the European Commission to prevent double regulation, overlaps and inconsistencies between several pieces of legislation pursuing the same goals. In addition, this draft delegated act identifies permanent magnets, but does not specify whether Member States should take into account permanent magnets as such or when they are incorporated into finished products. In addition, it identifies certain categories of products which, apart from the permanent magnets they contain, have low recovery potential (e.g. industrial pumps). In order to achieve the objectives of the Regulation and ensure European supply capacities, we believe that permanent magnets integrated into finished products should be included and products with low recovery potential, such as industrial pumps, should be excluded.
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Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

8 Jan 2025 · Future of the automotive sector

Response to The reporting obligations during the transitional period of the carbon border adjustment mechanism.

10 Jul 2023

Le projet de texte liste dans ses annexes les informations à déclarer à limportation et détaille les méthodes de calcul du contenu carbone des produits. Il apparaît que ces tâches sont complexes et lourdes à réaliser, nécessitant des ressources spécifiques. En conséquence, il est anticipé que limportateur risque de ne pas obtenir lensemble des informations requises auprès des producteurs. La complexité de la mise en œuvre va par ailleurs augmenter le risque de contournement. Dans ce contexte, limportateur va probablement devoir recourir largement aux valeurs par défaut. Or larticle 5 du projet de Règlement dexécution limite considérablement lutilisation de ces valeurs. Il est donc impératif de permettre lutilisation des valeurs par défaut. Nous proposons de supprimer larticle 5 du projet de Règlement d'exécution.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The French trade association of mechanical engineering industries (FIM) represents 11 700 companies of more than 10 employees that design, manufacture, install and maintain production equipment, mechanical equipment and the parts and sub-assemblies thereof. As a general comment, FIM considers the RoHS Directive as effective, efficient, relevant and of added value as a sector specific tool addressing a number of important specificities of the EEE sector in support of a circular economy. This regulation is a standard on which a growing number of countries rely. Nevertheless, areas of improvement can be addressed in order to better meet the objectives of the directive and facilitate its implementation by companies. Below are our main comments on some of the options referred to in the Commission's Call for Evidence paper (full contribution attached): Maintain the RoHS Directive as it stands and introduce certain non-legislative (‘soft’) measures If some difficulties may be resolved by non-legislative documents, as for example the Common understanding paper from the Commission on Reach and RoHS, several difficulties need amendments of the legal text. Therefore, a targeted revision of the RoHS directive is likely to be the proper approach, depending of the provisions considered. Simplify and clarify the RoHS Directive by introducing and revising legislative (‘hard’) measures and soft measures If significant changes were to be made, companies would need sufficient time to adapt their processes. Therefore, any change of the legal text must be well proportionated to the pursued objectives and prevent, as far as possible, any unnecessary burden for duty holders. Pursuing this approach, we identify the following key adjustments to improve the RoHS Directive : - The exemption process needs to be improved in order to be more predictable and consistent with industrial processes. Maximum validity periods should be adjusted to the very long life cycles of engineering mechanical products, taking into account the availability of alternatives and the risk management measures implemented. There is also a need for clear procedure and criteria for granting and renewing exemptions, as well as granting appropriate transition periods when applications to renew an exemption are rejected. In most cases, the actual periods of 12 or 18 months are not sufficient for long (often European or globalized) and complex supply chains. - Regarding the links between RoHS and other pieces of regulation (as REACH, ecodesign, WEEE and POP regulations) and consistency between these texts, it is essential to maintain a clear framework on the objectives of each of these regulations and to prevent any overlap or inconsistency. For example, REACH regulation aims at a proper management of chemical risks along the supply chain of chemicals when RoHS and WEEE directive aims to regulate electrical and electronic equipements or wastes. - regarding the provisions for spare parts we consider the principle of "repair as produced" to be essential in the RoHS Directive and with regards to the EU objectives on Circular Economy. Many products in our sector, including those which contribute to improve energy efficiency, have a long lifespan and can be maintained or even improved during it. Thus, it is necessary to allow that spare parts for a product with a long service life can also be maintained after subsequent changes to the exemptions and substance restrictions under RoHS. - Regarding provisions related to recycled material, it is both necessary to prevent any inconsistency with other pieces of regulation (as the ecodesign directive) and to allow the use of recycled materials where there is no proven risk for the environment or human health. Thus, a derogatory threshold for recycled materials in products should be systematically considered and allowed in the absence of such risks.
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Response to Requirements for Artificial Intelligence

22 Jul 2021

One has to acknowledge that the implementation of software techniques and approaches commonly referred to as "Artificial Intelligence" is not a novelty, as self-driving machinery is already placed on the market and put into service especially in the industrial and agricultural sectors. These advanced techniques also contribute to improve the reliability of components, to implement predictive mon-itoring and maintenance, to increase the lifespan of machinery, to optimise energy efficiency and to adapt production to customer demand. The deployment of these techniques represents a cornerstone for the competitiveness of the European Union, and it is imperative to foster innovation in this sector. In the context of the Artificial intelligence draft Regulation, FIM supports the risk-based approach. Nevertheless, it appears that this text has been developed without considering that many regulated products incor-porating AI as a safety function, notably machinery subject to the provisions of Directive 2006/42/EC, are currently used in several sectors. Currently, the AI is considered in the framework of risk analysis, thus allowing manufacturers to take appropriate protection measures. Therefore, the articulation between this draft Regulation and the revision of Directive 2006/42/EC raises questions. Furthermore, the IA draft Regulation establishes obligations, particularly in terms of risk management and conform-ity assessment, which are already covered by the Machinery Directive, and which go well beyond what the Machinery Directive requires, notably concerning Chapters II and III of Title III. Today, the methodology adopted, for example by the Machinery Directive, is to carry out a risk analysis, to determine the applicable Health and Safety Requirements and to take the appropriate safety measures. In this draft Regulation, the provisions of Chapters II and III must be applied in an absolute manner. While this draft text seems to address legitimate concerns about the use of AI software, prohibiting certain uses, it is not at all adapted to the use in industrial products, especially if the industrial products are already regulated by a New Approach Regulation. This act will have a disproportionate impact on the companies’ competitiveness and will limit the European Union's capacity for innovation in this area. Please find attached our comments.
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Response to Revision of the Machinery Directive

22 Jul 2021

FIM welcomes the alignment of the Machinery draft Regulation to the New Legislative Framework, in particular when it comes to the definitions and obligations of economic operators (manufacturer, importer, distributor…) as given in Decision 768/2008. This will bring clarity to the text and reduce possible legal interpretations on the field. Following previous exchanges during the last two years with the Commission, throughout ad hoc meetings or by means of public consultations, it appears to us that the two main challenges of the revision are the introduction of the concept of « substantial modification » and the capture of new technologies like Artificial Intelligence and cybersecurity. Please find our comments attached.
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Response to Chemicals strategy for sustainability

16 Jun 2020

Please find attached FIM's contribution in French and in English.
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