Self-Declaration Preserves Machinery Exports to EU

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

The European Commission’s 2027 Machine Products Regulation expands regulatory requirements for industrial machinery—including imports from the United States—configured with advanced technologies, especially Super Intelligence (SI). 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 SI. ITA worked successfully with Market Development Cooperator Program award recipient 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 SI 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.