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CEMA Representing the European
Agricultural Machinery Industry
Dr. Heribert Reiter CEMA - Technical Board Chairman
April 2011 Page 2
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The European Association representing the Farm Machinery Industry in Europe for more than 50 years
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CEMA gathers the whole industry, from multinational companies to thousands of European SMEs
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A strong network of 10 national member associations►
Recognized partner of the European Institutions
CEMA
April 2011 Page 3
The Industry behind CEMA
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4,500 manufacturers
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21 billion Euro production value (2010)
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250,000 Employees►
135,000 persons employed directly
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125,000 persons additional in the distribution network and maintenance
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450 different machine types
April 2011 Page 4
CURRENT WORDING Entry into force: It shall apply from 1 January 2014 onwards (article 64)This means:
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Very ambitious timeline to get all delegated acts ready on time►
No transition period = No more phased introduction for new types
and new Vehicles (1 year later in the 2003/37/EC)
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In the middle of a busy approval period regarding the emission reduction schemes
The implementation date: the right timing?
2014 2015 2017
2 yearsAdaptation periodEmissions approval period
April 2011 Page 5
PROPOSALEntry into force: It shall apply not earlier than 1 January 2017 and 3 years after the date of entry into force of the last delegated act necessary for the whole vehicle type approval of the vehicle categories
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After the latest introduction date for the emissions scheme and taking into account 2 years adaptation to administrative changes: 2015 + 2
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A certain lead time is necessary to prepare the administrative changes and possible technical changes that will be inserted in the period until 2014.
The implementation date: the right timing?
April 2011 Page 6
Proposals for alignment and simplification
Purpose of the regulation:►
To align the type approval procedures for all sectors under the care of the European Commission automotive unit.
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GO for harmonization and simplification
To achieve above mentioned goals:►
CEMA-CECE proposal to retract category U, non road mobile machinery
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CEMA proposal to simplify the scope of the regulation
CECE: European construction equipment association
April 2011 Page 7
Proposals for alignment and simplificationCEMA-CECE proposal to retract category U for mobile machinery
Mother regulation:
Risk assessment by experts Resulting technical
Requirements are included inside the legislation (dir, standards, OECD codes, UN-ECE R)
Fulfillment is checked by type approval authorities (CoC)
New legislative framework:
Risk assessment by manufacturer Harmonized standards to help with conformity Self declaration of conformity (DoC) Market surveillance to check conformity
TYPE APPROVAL SELF CERTIFICATION
TRACTORS NON ROAD MOBILE MACHINERY
April 2011 Page 8
Proposals for alignment and simplificationCEMA-CECE proposal to retract category U for mobile machinery
Mother regulation:Occupational safety
Environmental protection
Road safety
New legislative framework:Occupational safety
Environmental protection
...
Machinery Directive
Emissions directive
Noise directive
TYPE APPROVAL
Road safety NATIONAL TYPE APPROVAL
SELF CERTIFICATION
TRACTORS NON ROAD MOBILE MACHINERY
Current situation
April 2011 Page 9
Proposals for alignment and simplificationCEMA-CECE proposal to retract category U for mobile machinery
Non-road mobile machinery inside the new regulation
Mother regulation:Occupational safety
Environmental protection
Road safety
New legislative framework:Occupational safety
Environmental protection
...
Machinery Directive
Emissions directive
Noise directive
Road safety NATIONAL TYPE APPROVAL
TRACTORS NON ROAD MOBILE MACHINERY
TYPE APPROVAL SELF CERTIFICATION
April 2011 Page 10
Proposals for alignment and simplificationCEMA-CECE proposal to retract category U for mobile machinery
Reasons why the insertion of category U inside the regulation is
not appropriate:
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2 sets of legislation would add confusion and adminsitrative burden: Category U machines are falling under new-approach legislation (Machinery Directive,...) for all safety aspects except road safety.
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When limiting to agriculture and forestry: what with dual use machines?►
Technical requirements for mobile machines of use in agriculture
and construction are much closer to each other then those for tractors and agricultural mobile machines.
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Risk that optional category U will not be used and that requirements will not be drafted.
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Due to the high variety of cat U vehicles, the insertion would delay the progress of the mother regulation.
April 2011 Page 11
Proposals for alignment and simplificationCEMA-CECE proposal to retract category U for mobile machinery
SOLUTION : Non road mobile machinery dealt with separately
Mother regulation:Occupational safety
Environmental protection
Road safety
New legislative framework:Occupational safety
Environmental protection
...
Machinery Directive
Emissions directive
Noise directive
TYPE APPROVAL
Road safety
SELF CERTIFICATION
TRACTORS NON ROAD MOBILE MACHINERY
Machinery Directive?
New regulation?
April 2011 Page 12
Proposals for alignment and simplificationCEMA proposal to simplify the scope
NOW
Speed < 40 km/h Speed > 40 km/h
T1 T5 ?
T2
T3
T4
Ra Rb
Sa Sb
April 2011 Page 13
Proposals for alignment and simplificationCEMA proposal to simplify the scope
PROPOSAL
Speed < 40 km/h Speed > 40 km/h
T1a T1b(legislation in progress)
T2a T2b (no technical content yet)
T3a T3b(no technical content yet)
T4a T4b (no technical content yet)
Ra Rb
Sa Sb
April 2011 Page 14
Proposals for alignment and simplificationCEMA proposal to simplify the scope
Reason for the proposal►
Threat of possible new categories►
Simplification of the scope with subcategories and less categories►
Speed requires specific requirements for steering, braking... All other requirements can be the same for all subcategories
Suitability of the proposal:►
No need for a ‘fast‘
tractor category T5 ►
A T5 deletion should be strictly coupled to the creation of the a & b subcategories. There are requirements necessary for tractors > 40 km/h
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the possibility exist for e.g. ATV’s to be approved as tractors taking into account the higher speed.
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It would give a positive signal to the outside that hereby ATV’s will have to follow the tractors requirements;
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It will also provide opportunities for tractor manufacturers
Prerequisite: ►
Criteria and definitions need to be well defined for any new vehicles entering the agricultural vehicle regulation
April 2011 Page 15
CEMA message
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Proposal regulation for agricultural vehicles concerns:►
Simplification of type approval procedures
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Reduction of administrative burden for EC/MS
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Alignement with rules for the automotive
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Industry is in agreement with most of the content. However:►
Chapter XVI ‘access to vehicle repair and maintenance information‘
is not appropriate
and certainly not assessed for our sector
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Timing should be adapted to provide the necessary lead time
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CEMA proposals for simplification and alignment►
Simplify the scope and make more logical for the future by T a/b
subcategories
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Retraction of the category U and alignement/ EU harmonization of
road safety
requirements for on road mobile machinery aligned with the New Legislative Framework
directives
CEMA aisblBoulevard A. Reyers
80
BE –
1030 BrusselsEmail: [email protected]
Website: www.cema-agri.org
