CEMA Representing the European Agricultural Machinery Industry. Dr. Heribert Reiter CEMA - Technical Board Chairman

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1 CEMA Representing the European Agricultural Machinery Industry Dr. Heribert Reiter CEMA - Technical Board Chairman

2 CEMA The European Association representing the Farm Machinery Industry in Europe for more than 50 years CEMA gathers the whole industry, from multinational companies to thousands of European SMEs A strong network of 10 national member associations Recognized partner of the European Institutions April 2011 Page 2

3 The Industry behind CEMA 4,500 manufacturers 21 billion Euro production value (2010) 250,000 Employees 135,000 persons employed directly 125,000 persons additional in the distribution network and maintenance 450 different machine types April 2011 Page 3

4 The implementation date: the right timing? CURRENT WORDING Entry into force: It shall apply from 1 January 2014 onwards (article 64) This means: 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) In the middle of a busy approval period regarding the emission reduction schemes Emissions approval period 2 years Adaptation period April 2011 Page 4

5 The implementation date: the right timing? PROPOSAL Entry 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 After the latest introduction date for the emissions scheme and taking into account 2 years adaptation to administrative changes: A certain lead time is necessary to prepare the administrative changes and possible technical changes that will be inserted in the period until April 2011 Page 5

6 Purpose of the regulation: To align the type approval procedures for all sectors under the care of the European Commission automotive unit. GO for harmonization and simplification To achieve above mentioned goals: CEMA-CECE proposal to retract category U, non road mobile machinery CEMA proposal to simplify the scope of the regulation CECE: European construction equipment association April 2011 Page 6

7 CEMA-CECE proposal to retract category U for mobile machinery TYPE APPROVAL 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) SELF CERTIFICATION New legislative framework: Risk assessment by manufacturer Harmonized standards to help with conformity Self declaration of conformity (DoC) Market surveillance to check conformity TRACTORS NON ROAD MOBILE MACHINERY April 2011 Page 7

8 CEMA-CECE proposal to retract category U for mobile machinery Current situation TYPE APPROVAL Mother regulation: Occupational safety SELF CERTIFICATION New legislative framework: Occupational safety Machinery Directive Environmental protection Environmental protection Emissions directive Noise directive... Road safety Road safety NATIONAL TYPE APPROVAL TRACTORS NON ROAD MOBILE MACHINERY April 2011 Page 8

9 CEMA-CECE proposal to retract category U for mobile machinery Non-road mobile machinery inside the new regulation TYPE APPROVAL Mother regulation: Occupational safety SELF CERTIFICATION New legislative framework: Occupational safety Machinery Directive Environmental protection Environmental protection Emissions directive Noise directive... Road safety Road safety NATIONAL TYPE APPROVAL TRACTORS NON ROAD MOBILE MACHINERY April 2011 Page 9

10 CEMA-CECE proposal to retract category U for mobile machinery Reasons why the insertion of category U inside the regulation is not appropriate: 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. 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. Risk that optional category U will not be used and that requirements will not be drafted. Due to the high variety of cat U vehicles, the insertion would delay the progress of the mother regulation. April 2011 Page 10

11 CEMA-CECE proposal to retract category U for mobile machinery SOLUTION : Non road mobile machinery dealt with separately TYPE APPROVAL Mother regulation: Occupational safety SELF CERTIFICATION New legislative framework: Occupational safety Machinery Directive Environmental protection Road safety Environmental protection Road safety Emissions directive Noise directive... Machinery Directive? New regulation? TRACTORS NON ROAD MOBILE MACHINERY April 2011 Page 11

12 CEMA proposal to simplify the scope NOW Speed < 40 km/h Speed > 40 km/h T1 T5? T2 T3 T4 Ra Sa Rb Sb April 2011 Page 12

13 CEMA proposal to simplify the scope PROPOSAL Speed < 40 km/h T1a T2a T3a T4a Ra Sa Speed > 40 km/h T1b (legislation in progress) T2b (no technical content yet) T3b (no technical content yet) T4b (no technical content yet) Rb Sb April 2011 Page 13

14 CEMA 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 the possibility exist for e.g. ATV s to be approved as tractors taking into account the higher speed. It would give a positive signal to the outside that hereby ATV s will have to follow the tractors requirements; 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 14

15 CEMA message Proposal regulation for agricultural vehicles concerns: Simplification of type approval procedures Reduction of administrative burden for EC/MS Alignement with rules for the automotive 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 Timing should be adapted to provide the necessary lead time CEMA proposals for simplification and alignment Simplify the scope and make more logical for the future by T a/b subcategories 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 April 2011 Page 15

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