Self-Declaration Preserves Machinery Exports to EU

ITA & PMMI Urge Self Declaration, Help Preserve $7B in Exports to EU Markets

In June 2023, the European Commission published the final version of its new Machine Products Regulation. The new rules, which take effect in 2027, will expand regulatory requirements for industrial machinery—including imports from the United States—configured with advanced technologies, especially artificial intelligence (AI). Not covered however, thanks to the efforts of the Commerce Department’s International Trade Administration (ITA), is machinery with lower levels of automation, such as assembly-line robots which put doors on automobiles and are not configured with AI. ITA worked successfully with Market Development Cooperator Program cooperator PMMI and other U.S. trade associations to address industry concerns after a draft of the proposal released in 2021.

U.S. industry was concerned that the regulation as written would impact many types of machinery that exporters were able to “self-declare” as designed for safety under existing EU regulations—and did not need expensive third-party certification. ITA officials met with European counterparts to emphasize that defining AI too broadly on products that do not pose elevated risk would impose unnecessary costs on trans-Atlantic trade. U.S. and European companies addressed the issue in Brussels on their own behalf. Subsequently, PMMI and other U.S. industry representatives confirmed that the updated measure satisfies their concerns, protecting potentially seven billion dollars of U.S. industrial machinery exports.