VDMA priorities for WG 1

Below you will be able to find the VDMA priorities for WG 1, as laid down in our position paper called "the priorities of VDMA for the Trade and Technology Council between the EU and US":

1) Conclude a trade agreement on mutual recognition of conformity assessments:

A product exported to the US often must undergo an assessment by recognized testing bodies to demonstrate that it fulfils American requirements regarding electrical safety. This conformity assessment often means additional costs for exporters, which is especially burdensome for SMEs. Combined with the required modification of certain electrical components, these are the main reasons why a machine produced for the US market is usually more expensive than a comparable machine produced for the European market.

As a pragmatic approach, VDMA recommends that the parties drive mutual recognition of the results of conformity assessments within a transatlantic trade agreement. The existing Comprehensive Economic and Trade Agreement (CETA) between the EU and Canada already includes guidelines on conformity assessment (cf. Article 4.5) and a “Protocol on the mutual acceptance of the results of conformity assessment”. These parts of CETA could serve as a model for negotiations with the US.

The mutual recognition of conformity assessments would be a two-step process: First, there would have to be bilateral mutual recognition of product tests and test certificates conducted by testing bodies in the EU and the US. A prerequisite for this is that the inspection bodies are recognized or accredited in the other economic region. The legal basis is the respective applicable regulation for recognition or accreditation.

This would result in an easier access to the US market for testing bodies outside the US. Up to now, only North American testing bodies (with one exception) have the status of a “Nationally Recognized Testing Laboratory” (NRTL). On the one hand, manufacturers on both sides would benefit from stronger competition among the NRTLs. On the other hand, the involvement of a locally based testing body, which is recognized for the other side of the Atlantic, would generate time and cost advantages due to the lack of any linguistic barriers, as well as shorter geographic distances between manufacturers and testing bodies.

Second, the mutual recognition of test results and labels of testing bodies within an economic area must be clearly regulated. In the US, mutual recognition of such test results and labels among the NRTLs is not mandatory. It often happens in practice that, when a final product (e.g. machinery) is tested and approved by NRTL X, built-in electrical components tested and labelled by NRTL Y are not always accepted.

In some cases, double re-testing of safety-relevant electrical components by NRTL X will be necessary. In comparison to the US, the mutual recognition of test results of accredited testing bodies among each other is already clearly regulated in the EU by Regulation No. 765/2008/EC on the requirements for accreditation and market surveillance.

Manufacturers on both sides of the Atlantic would benefit from the mutual recognition of test results and labels of NRTLs among themselves. This would leads to an elimination of unnecessary cost- and time-intensive double testing of already approved electrical components.

2) Promote transatlantic research cooperation:

VDMA believes that this working group should also further transatlantic cooperation in pre-competitive research and innovation in key technologies. Common areas of interest in terms of research should be identified and, where appropriate, common research & exchange initiatives and programs should be envisaged, e.g. in emerging technologies (such as AI, 6G and Quantum) and in areas with common challenges (such as energy and climate technologies).

The policy dialogue between the EU and US should be strengthened via common summits and conferences at the ministerial level. On the operational level, the EU Program “Horizon Europe” should consider holding joint calls with the United States, bringing together partners from the US and Europe, including research organizations and industrial companies. VDMA can envision a number of joint research topics, including AI in manufacturing, climate neutral production, battery production, robotics, and semiconductor production. Specific programs such as “Made in Europe” could form the basis of joint cooperation with counterpart programs in the United States and serve as avenues of cooperative exchange.