The European Materials Handling Federation (FEM) says it will support the European Commission's proposed voluntary, centralised eCompliance system if it facilitates procedures to provide documentary evidence of equipment compliance to market surveillance authorities.
In its participation in the Commission's second request for comments on the four proposed provisional options on the eCompliance system to ensure a level playing field for materials handling machinery sold in the EU, FEM says its support is also conditional on the system "genuinely result[ing] in more effective market surveillance controls, compared to the current system".
The Commission drafted the four options after analysing the stakeholder contributions it received. FEM says that while it noted the Commission's efforts to respond to concerns raised in the first consultation, "not enough clarification is provided on how the issues would be addressed in practice".
Building on the arguments it presented in its initial position on the system on 2 September, FEM says the management and co-ordination of the system by the Commission should, in principle, allow a more uniform and coherent structure of the electronic depository of information.
"We would prefer the voluntary option because manufacturers need to have the flexibility to opt out of this system and continue providing the technical documentation upon reasoned request.
"FEM welcomes the Commission's commitment to guarantee that confidentiality is ensured under this option, but no details are given as to how exactly confidentiality leaks and misuse of product compliance documentation will be prevented.
"It is important that the eCompliance system clearly indicates the firm borderline between the market surveillance authorities' possibility to have preliminary and preventive checks upon reasoned request, and the responsibility of manufacturers to ensure conformity of their machines with the applicable legal requirements, solely when they are placed on the market."
FEM is rejecting the option of an obligatory centralised eCompliance system because of its mandatory character, and maintains that a decentralised eCompliance system would generate additional administrative burden on the manufacturers to keep it up-to-date and accurate. "There is a risk that a decentralised depository of information may lead to unwanted errors which would then prevent the system from facilitating and improving market surveillance procedures and from running in an effective manner."
FEM also opposes the option of voluntary standalone e-labelling, which may require substantial investments by companies to equip their products with displays, tags or other electronic identifiers and, in some cases, could lead to a complete redesign of their products to incorporate the new features.
Over the past few years, the European materials handling industry has been alerting decision-makers to the negative impact of ineffective market surveillance on the sector and the entire EU economy (Forkliftaction.com News #587