EU Industry Urges CRA and Machinery Rules Alignment
Six European associations, including FEM, ask the European Commission to harmonize cyber and machinery compliance for dual-regulated products.
Updated on Nov. 2, 2026 in Robotics
Six European industry associations, led by FEM, have published a joint position calling for alignment between the Cyber Resilience Act and the Machinery Regulation. The paper highlights legal uncertainty over how a single EU Declaration of Conformity should be presented for products subject to both acts.
Why it matters
Manufacturers of products falling under both regulations face unclear rules on whether conformity documentation must physically accompany the product or can be provided digitally. Clearer alignment would reduce compliance overlap for robotics and industrial machinery makers operating across the European market.
The position paper comes from six associations and contrasts the CRA's interpreted requirement for a physically accompanying declaration with the amended Machinery Regulation's digital format rule. It remains unclear how the European Commission will resolve this difference or when any alignment will take effect.
The players
FEM (European Federation of Material Handling and Lifting)
FEM is the European trade association representing manufacturers of material handling and lifting equipment, and it co-signed the joint position on regulatory alignment.
The details
The associations ask the Commission to align relevant CRA provisions with the Machinery Regulation as amended by Omnibus IV. They propose that products within both acts carry a single digital Declaration of Conformity, accessible through a mark on the machine, its packaging, or an accompanying document.
Timeline
Omnibus IV digital Declaration of Conformity requirements apply once the relevant provisions take effect.
The Big Picture
The joint position builds on the EU Machinery Regulation (EU) 2023/1230, which introduced a single EU Declaration of Conformity for products subject to multiple Union acts. As the Cyber Resilience Act takes effect alongside it, industry is testing whether that single-declaration model can hold across overlapping digital and safety rules.
Manufacturers and importers of robots and industrial machines sold in the EU may need to decide whether conformity documentation travels with the product in paper form or is accessed digitally. Until the rules are aligned, compliance paperwork and labeling for dual-regulated equipment remains uncertain.
The takeaway
Companies selling machines with connected software should track how the Commission resolves the physical versus digital Declaration of Conformity question before finalizing compliance workflows.
Further reading
For background on how regulation shapes automated equipment, see the Robotics section.
