The VDW has published a position paper on the introduction of the CRA. On the one hand, this important legislation ensures fair conditions for the use of software and ‘products with digital elements’, which is appreciated. However, the timeframe for implementing the CRA is viewed very critically. Machine tools themselves fall under the CRA regulations. At the same time, they integrate many complex subsystems and components to which the CRA also applies. Due to the complex supply chains and typically long lead times for subcontracts and orders in project-based business, there is a real danger that machine tool manufacturers will ultimately have insufficient time to make their products compliant. In the worst case, a sales ban could have existential consequences, especially for SMEs.
The VDW therefore urges politicians and legislators to:
  1. introduce the CRA in an at least two-tiered manner.
  2. Provide machine tool manufacturers, as integrators of complex systems, with an extended timeline until the CRA is to be fully implemented.
  3. Consistently apply the CRA’s risk-based approach and correspondingly reduce requirements for simple and non-critical components and products, which typically installed and used in machine tools.
 
The full text of the position paper is available here.
 
Contact: Dr. Alexander Broos, Director Research and Technology, a.broos@vdw.de