CEMA — the European agricultural machinery association; the equipment-maker AI dossier, the August 2024 AI Act position paper, and the sectoral route that arrived in July 2026

Europe (11 national member associations; EU-27 plus neighbouring industry bodies)

Content

The July 2026 funder scan listed CEMA as a unit candidate with a gap for the AI Project Team’s statements (G-204). This unit closes it, and the substance is sharper than the July scan implied: CEMA has the most explicit equipment-maker AI regulatory dossier of any European agrifood association — an August 2024 position paper asking the Commission to align AI Act definitions with the Machinery Regulation — and in July 2026 the AI Act Omnibus moved the Machinery Regulation to the AI Act’s Annex I Section B, adopting something close to CEMA’s sectoral ask. CEMA’s own February 2026 statement records that its concerns had “so far not been reflected”; direct influence on the final text is undocumented.

Headline. The EU’s agri-machinery federation argued from August 2024 that AI Act definitions of “safety component” and “safety function” were too wide for non-road machinery, proposed a five-level classification of self-evolving behaviour, and asked for self-certification. The Digital Omnibus on AI (Regulation (EU) 2026/1744, in force 27 July 2026) moved the Machinery Regulation into the AI Act’s sectoral annex, with AI requirements to be folded into the Machinery Regulation by delegated act by 2 August 2028 — structurally CEMA’s position, according to no document that attributes it to CEMA.

What it is, verified 2026-09

CEMA is the European association representing the agricultural machinery industry, headquartered in Brussels. Its About page states: “With 11 national member associations, the CEMA network represents both large multinational companies and numerous European SMEs”; “about 1,300 manufacturers, producing more than 450 different types of machines with an annual turnover of about €40 billion (EU28 – 2016)” and 150,000 direct employees. Those figures conflict with CEMA’s own 2024 position paper, which claims “about 7,000 manufacturers” and “€60 billion” — both are CEMA’s published numbers, and the discrepancy is unresolved.

Structure: General Assembly → Board of Directors (two-year mandate) → Strategic Committee, Economic Expert Group, Product Groups and a Technical Board, under which “dedicated Project Teams (PTs)” operate. The AI Project Team is a Technical Board project team — which is why CEMA has no public AI sub-page: the dossier runs through the technical channel rather than the regulation-priorities channel.

Board and secretariat: President Stefan Top (AVR/AGORIA); Vice-Presidents Thierry Krier (KUHN/AXEMA), Carlo Lambro (CNH), Alessandro Malavolti (AMA/FederUnacoma); members include Roger Batkin (AGCO), Andreas Kaczmarczyk (KUBOTA), Alessandro Maritano (SDF), Jan-Hendrik Mohr (CLAAS), Heinz Pöttinger (Alois Pöttinger), Gijs Scholman (Lely), John B. Smith (JCB), Olaf Turss (John Deere), Anthony van der Ley (Lemken/VDMA), Giovanni Esposito (Argo), Jorge Calvo (Ovlac/ANSEMAT). Secretary General Jelte Wiersma; Technical Director Ivo Hostens.

Corrections to the July scan: the member-company list is only partly confirmable — Ploeger, DeLaval, Fendt/Massey Ferguson/Valtra and Kverneland do not appear on CEMA’s Board page. Confirmed member associations are VDMA (Germany), AXEMA (France) and FederUnacoma (Italy) plus AEA, AGORIA, ANSEMAT, Danish Agro, Fedecom, Metalltechnische Industrie and PIGMiUR. CEMA’s founding year (1959) is not confirmed from any CEMA primary source. CEMA is a partner of Copa-Cogeca and a member of the Agri-Food Chain Coalition.

The AI Group. Chair: Francesca Hennig-Possenti (John Deere, AI Senior Legal Counsel). The body’s name drifts across CEMA’s own documents — “Project Team on Artificial Intelligence” (2025), “Artificial Intelligence ad-hoc group” (2021), “Artificial Intelligence Group” (Commission agenda, June 2026). Membership is not published anywhere (G-412).

The August 2024 position paper — the substantive AI document

“EU Artificial Intelligence Framework: CEMA calls on the European Commission to adapt the principles to the reality of non-road machinery” (August 2024) is the most explicit equipment-maker AI regulatory position in the corpus:

“The definition of AI in Art 3 of the AI Act is too wide and requires guidance.”

“The definition of ‘safety component’ and ‘safety function’ in Article 6 is unclear”; “by including the potential endangerment of property in its definition of a safety component, the AI Act appears to broaden the scope of Article 6 beyond the Machinery Regulation.”

“Alignment in the interpretation of ‘safety component’ and ‘safety function’ is critical.”

It proposes a five-level staggered classification of “fully or partially self-evolving behaviour” (Level 1 deterministic through Level 5 independently learning without human intervention), argues that Levels 1-4 keep humans “in control”, and asks for self-certification plus “clear, actionable guidelines” from the Commission.

The 13 May 2025 article “AI and the Future of Sustainable Agriculture”, by Hennig-Possenti, is the federation’s most quotable AI text and the July scan’s anchor:

“AI is not a single product but a collection of different techniques — it requires a complete ecosystem: robust infrastructure, machines and sensors, consistent testing practices, quality data, context knowledge and AI output interpretation skills, as well as real-world validation.”

“A good regulation, policy or law is crucial for trust, safety, and fairness. However, overregulation, rules that are impossible to fulfill or laws that are soon overriden by technological evolution, might stifle innovation, prevent market introduction or make novel approaches unaffordable, especially if laws are designed without understanding rural realities.”

“Agricultural education must now expand to include AI literacy”; “Participatory law-making… offers a path to smart, down-to-earth and inclusive regulation.”

The regulatory dossier since 2024

Machinery Regulation and the AI Act — the dates the corpus had wrong

Machinery Regulation (EU) 2023/1230: adopted 14 June 2023, published in the Official Journal 29 June 2023, entered into force 19 July 2023, and applies mandatorily from 20 January 2027, repealing Directive 2006/42/EC. The original text said 14 January 2027; a corrigendum corrected the clerical error. The July scan’s “entered into force January 2027” is wrong on both counts — that is the application date, and it is 20 January.

AI content in the machinery regime: the Commission states the Regulation “integrates provisions for machinery with safety functions that are AI-powered” and “integrates provisions for cyber-safety for compliance-relevant software data and safety control systems”. Annex I items 5 and 6 bring “Safety components with fully or partially self-evolving behaviour using machine learning approaches” ensuring safety functions — and machinery embedding them — into third-party conformity assessment. New autonomous-machinery duties include a supervisor role, defined working areas, post-market behaviour in the risk assessment, and storage of “data related to a software of a safety function taking decision” each time a decision is taken.

Then the Omnibus changed the route. The Digital Omnibus on AI — Regulation (EU) 2026/1744 — was published in the Official Journal on 24 July 2026 and entered into force 27 July 2026. The Commission’s own summary: “High-risk AI embedded in physical products (machinery, toys, lifts, etc.) in Annex I: rules apply starting 2 August 2028”; “High-risk AI systems in Annex III: rules apply starting 2 December 2027.” Recital 42: “it is appropriate to move to a sectoral approach by moving Regulation (EU) 2023/1230 from Section A to Section B of Annex I to Regulation (EU) 2024/1689”, with high-risk AI technical requirements to be folded into the Machinery Regulation via a delegated act by 2 August 2028; pending machinery-specific harmonised standards, “manufacturers should be free to rely on harmonised standards or common specifications referenced or adopted pursuant to Regulation (EU) 2024/1689”. Political agreement was reached on 7 May 2026.

The net effect: for AI performing a safety function in a machine, the Machinery Regulation is designed to become the primary technical-compliance route, displacing a separate AI Act high-risk conformity assessment. No document attributes the outcome to CEMA’s advocacy (G-413) — and CEMA’s own February 2026 statement records non-uptake of its Omnibus IV asks.

Standards and data interoperability

CEMA’s Connected Agricultural Machines in Digital Farming (6 February 2017) remains its standards statement: “the so-called ISOBUS standard (ISO standard 11783 using ISO-XML as data standard) has become the de-facto standard governing interoperability between tractors and implements from different manufacturers”; the Agricultural Industry Electronics Foundation’s scope now covers FMIS, wireless in-field communication, high-speed ISOBUS, electric drives and camera systems; AgGateway is a member of AEF and active in AEF Project Team 9 on FMIS/data management; ISO 11783 Parts 10 and 11 standardise FMIS data exchange. No post-2017 CEMA position on ISO 11783 or AEF was found (G-415), and CEMA maintains no position linking right-to-repair to AI or data governance.

What this unit is doing in the taxonomy

Anchors the EU equipment-maker industry-voice layer and the machinery AI compliance route — the layer where AI Act obligations for agricultural AI are actually decided. Distinguishes from:

Why it matters for talks

Critical context