COMMISSION STAFF WORKING DOCUMENT EVALUATION of the Lifts Directive 2014/33/EU
Date: 2026-01-23
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EC conformity marking, competition, digital technology, energy efficiency, facilities for people with disabilities, lift, maintenance, product safety, safety standard, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.1.2026  SWD(2026) 22 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the Lifts Directive 2014/33/EU {SWD(2026) 23 final}  
 
 
Table of Contents 

1. 

Introduction ............................................................................................................................. 2 

2.  What was the expected outcome of the intervention? ............................................................. 4 

2.1.  Description of the intervention and its objectives ................................................................... 4 

2.2.  Points of comparison ............................................................................................................... 5 

3.  How has the situation evolved over the evaluation period? .................................................... 6 

3.1.  The single market for lifts ....................................................................................................... 6 

3.2.  Safety of lifts ........................................................................................................................... 9 

4. 

Evaluation findings (analytical part) ..................................................................................... 11 

4.1.  To what extent was the intervention successful and why? .................................................... 11 

4.1.1  Cross-cutting NLF issues ...................................................................................................... 13 

4.1.2  Issues specific to the Lifts Directive ..................................................................................... 20 

4.2.  How has the EU intervention made a difference and for whom? .......................................... 24 

4.2.1  Brussels Effect ...................................................................................................................... 24 

4.3.  Is eu action still relevant? ...................................................................................................... 26 

5.  What are the conclusions and lessons learned? ..................................................................... 28 

Annex I – procedural information................................................................................................... 31 

Annex II  – methodology and analytical models used .................................................................... 32 

Annex III – evaluation matrix and, where relevant, details on answers to the evaluation questions 
(by criterion) ......................................................................................................................... 35 

Annex IV – overview of costs and benefits .................................................................................... 55 

Annex V – stakeholder consultations - synopsis report .................................................................. 61 

Annex VI – the lifts directive ......................................................................................................... 78 

Annex VII – annexes to the market analysis................................................................................... 84 

Annex VIII – annex to the brussels effect ...................................................................................... 90 

Annex IX – modernisation and maintenance practices of eu member states .................................. 97 

 
 
 
 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

ASME 

CAB 

CEA 

CEN 

CRPD 

CSB 

CSES 

EHSR 

ELA 

ESO 

ICSMS 

MASM 

NAB 

NB 

NLF 

SESEC 

SITC 

SMEs 

TRIS 

American Society of Mechanical Engineers 

Conformity assessment bodies 

China Elevator Association 

The European Committee for Standardization 

Convention on the Rights of Persons with Disabilities 

Companion standardisation body 

Centre for Strategy & Evaluation Services 

Essential health and safety requirements 

European Lifts Association 

European standardisation organisations 

Information and Communication System on Market 
Surveillance 

Mongolian Agency for Standardization and Metrology 

National accreditation body 

Notified bodies 

New Legislative Framework 

Seconded European Standardization Expert for China 

Standard international trade classification 

Small- and medium-sized enterprises 

Technical Regulation Information System 

 
 
 
1. 

INTRODUCTION 

Lifts  provide  an  essential  means  of  comfortable  and  safe  access  to  different  floors  in 
buildings. By making buildings more accessible, they promote inclusivity. Installing lifts 
supports the social integration of persons with disabilities, including those with temporary 
impairments or reduced mobility. 

The main objectives of Directive 2014/33/EU (the Lifts Directive)1 are (i) to guarantee the 
free movement of lifts and safety components for lifts within the EU, and (ii) to ensure a 
high level of protection for the health and safety of lift users and maintenance staff. The 
Directive governs the design, manufacture and installation of lifts and safety components 
for lifts when they are placed on the EU’s single market.  The Directive is  primarily of 
interest  to  lift  installers  and  safety  component  manufacturers,  but  it  also  has  major 
implications for lift owners and users. 

The Lifts Directive sets out essential requirements (Annex I to the Directive) applicable to 
lifts travelling faster than 0.15 m/s and to the safety components listed in Annex III when 
they  are  first  placed  on  the  EU  market2.  By  laying  down  harmonised  requirements 
applicable  to  lifts  and  safety  components  for  lifts  across  all  EU  Member  States,  the 
Directive has created a single market in this sector. 

The conformity of safety components is assessed independently of the lifts in which they 
will be installed, and those components are CE-marked in their own right. Manufacturers 
place safety components on the market once and may then sell them in any quantity. In 
contrast, lifts are put into service individually after their installation. Accordingly, the Lifts 
Directive lays down obligations for installers in relation to lifts and for manufacturers in 
relation  to  safety  components.  Additionally,  the  Directive  sets  out  obligations  for 
authorised representatives, importers, distributors and notified bodies (NBs). 

The  essential  requirements  are  currently  interpreted  through  14  harmonised  European 
standards (EN) that have been cited in the Official Journal of the European Union. Two of 
these standards form the basis for the others: 

•  EN 81-20:2020  Safety rules for the construction and installation of lifts - Lifts 
for the transport of persons and goods - Part 20: Passenger and goods passenger 
lifts; 

•  EN 81-50:2020  Safety  rules  for  the  construction  and  installation  of  lifts  - 
Examinations and tests - Part 50: Design rules, calculations, examinations and 
tests of lift components. 

1 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0033&from=EN 

2 Many components are essential for lift safety, but those not listed in Annex III to the Lifts Directive are 

only subject to conformity assessment as part of the overall lift. 

2 

 
 
 
 
Lift installers and safety component  manufacturers can choose  from several conformity 
assessment  modules  that  set  out  different  methods  for  assessing  product  conformity 
(Annexes IV to XII). In all cases, a third party, i.e. a notified body authorised by a national 
notifying authority, must be involved. 

If a lift or a safety component is found to be compliant with the Lifts Directive, the installer 
or manufacturer respectively issues a declaration of conformity and affixes the CE mark 
to  the  product.  The  CE  mark  signals  to  the  client  that  the  product  complies  with  the 
Directive. 

The provisions of the Lifts Directive, for example those on the obligations of economic 
operators, the conformity assessment modules and the CE mark are based on the template 
created by the New Legislative Framework (NLF)3. Most EU product legislation is based 
on the NLF, ensuring a high level of coherence across sectors of the single market. 

As  it  is  derived  from  the  NLF,  the  Lifts  Directive  does  not  cover  the  maintenance  and 
modernisation of lifts, meaning what happens to lifts after they are placed on the market. 
Responsibility  for  modernisation  and  maintenance  lies  with  national  authorities  in  EU 
Member States. For a more detailed explanation of the Lifts Directive, please see Annex 
VI. 

Adopted in 2014, the Lifts Directive has been applicable since 20 April 2016, replacing 
Directive 95/16/EC. An evaluation in 2019 concluded that the Lifts Directive was serving 
its purpose effectively4. 

As  the  Lifts  Directive  enters  its  10th  year  of  application,  this  new  evaluation  assesses 
whether the Directive is still fit for purpose, updating the previous evaluation. In particular, 
it  examines  developments  in  the  policy  context  since  2019,  the  legislative  and  non-
legislative measures adopted following the previous evaluation, and any new issues raised 
by stakeholders during the consultation. The evaluation covers the period from 2019 to 
2024. 

In addition to updating the previous evaluation’s assessment of the five standard evaluation 
criteria  under  the  Better  Regulation  toolbox  (effectiveness,  efficiency,  coherence, 
relevance and EU  added value), this  evaluation  also  considers a list  of issues  raised by 

3 The NLF, or the New Legislative Framework, is a set of legislative measures adopted by the EU in 2008 to 
improve the internal market for goods by harmonising conformity assessment procedures, strengthening 
market  surveillance  and  applying  the  CE  marking  to  products,  thereby  ensuring  the  safety  and  free 
movement  of  goods  across  the  single  market.  https://single-market-economy.ec.europa.eu/single-
market/goods/new-legislative-framework_en  

4  Commission staff document: Evaluation of the Lifts Directive 2014/33/EU accompanying the document 
Report from the Commission to the Council and the European Parliament on the implementation and 
functioning of Directive 2014/33/EU of the  European Parliament and of the Council of 26 February 
2014 on the harmonisation of the laws of the Member States relating to lifts and safety components for 
lifts,  22  February  2019,  https://op.europa.eu/publication-detail/-/publication/909d3530-3686-11e9-
8d04-01aa75ed71a1. 

3 

 
 
 
stakeholders, such as cybersecurity, competition issues affecting small and medium-sized 
enterprises  (SMEs),  digitalisation,  the  circular  economy,  alignment  with  the  new 
Machinery  Regulation,  accessibility,  and  the  consequences  of  technological  progress, 
including greater dependence on electronic components. The evaluation also examines the 
‘Brussels  effect’  of  harmonised  European  standards  in  the  lift  sector,  i.e.  the  extent  to 
which  European  lift  standards  have  been  adopted  by  national  or  international 
standardisation organisations, and the associated economic benefits for European and other 
stakeholders. 

This report builds on a study carried out for the Commission by a contractor5. For ease of 
reference, the structure of this staff working document follows the same structure as the 
supporting  study  report.  Throughout  the  supporting  study,  the  contractor  followed  the 
Commission’s Better Regulation procedures for evaluations. The contractor conducted a 
mix  of  data  collection  activities:  document  and  data  analysis,  55  interviews  with  73 
stakeholders, a public consultation that received 47 responses, and targeted consultations 
with main stakeholders (112 responses) and building owners and managers (4 responses). 
Annex V contains a synopsis of these consultations. 

As in the 2019 evaluation, the main limitations of the study were: (i) the limited availability 
of  data,  especially  on  lift-related  accidents  and  on  market  surveillance  and  customs 
controls, and (ii) the low level of stakeholder responsiveness to the consultations. For more 
details on the methodology, please see Annex II. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1.  Description of the intervention and its objectives 

Figure 1 illustrates the intervention logic of the Lifts Directive. The Directive creates a 
single market for lifts and safety components for lifts by harmonising safety requirements 
at  EU  level.  As  with  all  legislation  based  on  the  NLF,  these  requirements  are 
complemented  by  provisions  on  conformity  assessment,  market  surveillance  and 
harmonised standards. The intended outcome is seamless and fair trade in safe lifts and 
safety components within the EU. 

5 

https://op.europa.eu/en/publication-detail/-/publication/8fcd4f57-b865-11f0-b37f-

01aa75ed71a1/language-en  

4 

 
 
Figure 1: Intervention logic of Lifts Directive 2014/33/EU 

2.2.  Points of comparison 

The Lifts Directive has remained largely unchanged since its initial adoption in 1995, i.e. 
30  years  ago.  While  many  lifts  installed  before  that  year  are  still  in  service,  few 
stakeholders remember a time before the Lifts Directive’s harmonised health and safety 
requirements. Therefore, it would not be meaningful to use a hypothetical scenario without 
EU legislation on lifts as a baseline. The 2019 evaluation concluded that the recast Lifts 
Directive was fit for purpose. 

Instead of comparing the effects of the Lifts Directive against a hypothetical baseline, this 
evaluation considers whether the current version of the Lifts Directive is still fit for purpose 
in today’s context in terms of its effectiveness, efficiency, relevance and coherence. The 
focus  is  on  documenting  the  shortcomings  of  the  current  Lifts  Directive  rather  than 
questioning  whether  its  existence  is  justified.  The  2019  evaluation  and  the  contractor’s 
report  for  this  evaluation  already  document  the  aspects  that  work  well.  For  the  sake  of 
brevity, these are not repeated here. 

5 

 
 
3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1.  The single market for lifts 

Since the Lifts  Directive was  evaluated in  2019,  a global pandemic  has  shaken the EU 
market.  As  a  result,  the  economic  data  for  2019-2024  are  not  fully  representative  or 
meaningful in terms of past or future trends. The economic analysis below should therefore 
be read with this limitation in mind. 

The European lift sector is characterised by a handful of multinational manufacturers that 
dominate the global market for lifts, alongside thousands of small companies that maintain 
the  many  millions  of  lifts  used  daily  across  the  EU.  It  should  be  noted  that  the  Lifts 
Directive does not cover lift maintenance. 

As an indicative order of magnitude, 7 000 firms were active in the EU-27 in 2020 in the 
statistical category covering the production of lifts and safety components, modernisation 
and maintenance6. In addition, there are many thousands of firms, often SMEs, involved 
in the daily maintenance of lifts. According to Eurostat data, more than half (56.7%) of 
these firms are located in four Member States: Czechia, Germany, Italy and Poland. 

Eurostat data indicate that the number of firms active in the production of lifts and safety 
components  and  in  lift  modernisation  and  maintenance  in  the  EU-27  declined  by  9.7% 
between 2015 and 2020. Over this period, Eurostat recorded an increase in the number of 
firms only in Belgium, France, the Netherlands, Poland and Slovakia. 

According to the European Lifts Association (ELA), the number of employees in the lift 
sector grew by 4.7% between 2015 and 2022, reaching around 150 000 in the EU-27 plus 
Norway, Türkiye and Switzerland. Most were employed in Türkiye (28 000; 18.8%), Italy 
(25 000; 16.7%); Spain (20 000; 13.3%), France (17 000; 11.3%) and Germany (17 000; 
11.3%). 

Between 2011 and 2023, there was no discernible trend in the value of lifts sold, which 
oscillated around EUR 3 billion (Figure 2)7. By contrast, the value of safety components 
for lifts sold increased markedly, rising from EUR 2.5 billion in 2021 to EUR 4 billion in 
2023 and thereby surpassing the total value of lifts sold (Figure 3). 

6 NACE code 2822 - Manufacture of lifting and handling equipment. 

7 Firms manufacturing lifts often produce other products. Therefore, it is not possible to isolate the production 
of lifts and safety components from their overall output. The data presented here should only be regarded as 
indicative of general trends in the lift sector. 

6 

 
 
Figure 2: Value of sold production of lifts within the scope of Directive 2014/33/EU in EU-27 (nominal values) 

Figure 3: Value of sold production of lift safety components within the scope of Directive 2014/33/EU in EU-27 (nominal 
values) 

Confirming  the  findings  of  the  2019  evaluation,  Spain  continues  to  dominate  lift 
production, while Italy remains the largest safety component manufacturer. Both countries 
have increased their market shares since 20158. 

The European Lifts Association reports that the annual number of lifts installed in the EU-
27 plus Norway, Switzerland and Türkiye increased by 2.2% year-on-year, from 118 531 
units in 2015 to 137 560 units in 2022. Over this seven-year period, the average increase 

8 Lift production in Spain: production value 27% in 2015, 41.5% in 2023; production volume 29% in 2015, 

52.3% in 2023. Production of lift safety components in Italy: 22% in 2015, 54.5% in 2023. 

7 

 
 
 
 
in  the number of newly  installed lifts  was 16.1%, with  outliers of 227% in  Greece and 
160% in Croatia. The total value of newly installed lifts increased by 24.9% over the same 
period. 

According to the Eurostat international trade database, the EU is a net exporter of lifts and 
safety  components  for  lifts.  In  2023,  the  EU-27  exported  lift  products  worth  EUR 2.1 
billion to third countries, while imports of such products totalled EUR 0.6 billion. 

The export value increased from EUR 1.8 billion in 2011 to EUR 2.2 billion in 2016. It 
then  declined  almost  back  to  2011  levels  by  2021.  After  the  Covid-19  pandemic,  it 
recovered quickly, returning to 2016 levels in 2023. 

While exports to third countries grew until 2016 (with an average growth rate of 13.6% 
between 1995 and 2011) and then stagnated, developments in intra-EU trade followed an 
opposite  pattern,  growing  steadily  since  2015,  after  being  stagnant  in  previous  years 
(Figure 4). Within the EU, trade in safety components has grown more strongly than trade 
in lifts (with average annual growth rates of 27.5% and 14.2% respectively between 2015 
and  2023).  In  2023,  intra-EU-27  exports  accounted  for  65%  of  total  exports.  Countries 
with the largest production (e.g. Spain, Germany and Italy) export above  the average to 
countries outside the EU. 

Figure 4: Intra- and extra-EU-27 exports of products within the scope of the Directive between 2011 and 20239 

According  to  the  UN  Comtrade  database,  the  share  of  European  companies  (EU-27, 
Switzerland,  Norway,  Türkiye  and  Iceland)  in  global  exports  increased  from  54.8%  in 
2015 to 60% in 2023. 

9 Data used: EU-27 + Switzerland, Liechtenstein, Norway, Island and Türkiye. Liechtenstein does not have 
any data available for the corresponding SITC (standard international trade classification) codes. 

8 

 
 
 
With a share of 25.7% in 2023 (up from 23.4% in 2015), China was a distant second in 
terms of global exports of lift products. The United States followed in third place, also at 
a considerable distance, with a share of 3.5% in 2023. 

For more information on data sources and aggregation, please consult Annex VII. 

While  it  is  not  possible  to  establish  a  direct  causal  link  with  the  Lifts  Directive,  the 
following conclusions can be drawn. 

-  The number of newly installed lifts is growing slowly but steadily. 
- 
Intra-EU trade in lifts and safety components has grown strongly since 2015. 
-  For  decades,  the  EU  has  had  a  significant  trade  surplus  in  lifts  and  safety 
components for lifts, but exports to third countries have only recently recovered 
after the pandemic. The EU remains the largest global exporter. 

-  The number of firms has consolidated, potentially indicating a trend towards larger 

manufacturing firms. 

-  Lift  manufacturing  is  concentrated  in  Member  States  that  traditionally  have  a 

strong machinery industry. 

3.2. 

Safety of lifts 

As there are no legal  reporting obligations, there are no official  statistics on  lift-related 
accidents.  Therefore,  this  analysis  relies  on  data  provided  by  the  European  Lifts 
Association, i.e. by lift manufacturers. The General Product Safety Regulation10 requires 
manufacturers to report accidents though the Safety Business Gateway11. Besides continued 
dependence  on  self-reporting  by  manufacturers,  lift  installers  are  only  rarely  informed 
about accidents with their products.  

The informational value of the available data is limited, as these data do not distinguish 
between  accidents  according  to  the  age  of  the  lift  or  their  causes.  In  addition,  it  is  not 
possible to verify whether the accident was recorded in the year in which it occurred or 
later. Most importantly, the data depend on what the economic operators choose to share, 
as there is no official, systematic collection of such data. 

Although the observable trends are volatile (Figure 5, Figure 6), the number of fatalities 
and  severe  accidents  involving  lift  users  and  maintenance  personnel  has  significantly 
decreased since the adoption of the Lifts Directive. The number of non-serious accidents 
has increased for lift users but has remained steady for maintenance personnel. 

Given that the number of lifts steadily increased during this period, lift safety appears to 
be improving, especially with regard to serious and fatal accidents. According to data from 

10 Regulation (EU), 2023/988, https://ec.europa.eu/safety-gate/#/screen/pages/productSafetyLegislation. 

11 https://webgate.ec.europa.eu/safety-business-gateway/screen/public/home  

9 

 
 
the European Lifts Association (ELA), the ratio of accidents to the total number of lifts 
decreased for both users and maintenance personnel between 2014 and 2022. 

Figure 5: Number of lift-related accidents involving users (source: underlying study) 

Figure 6: Number of lift-related accidents involving workers (source: underlying study) 

Information  on  accident  causes  is  available  for  2021  and  2022.  For  users,  stopping 
inaccuracy  (such  as  not  levelling  with  the  floor)  and  door  malfunctions  are  the  most 
commonly experienced problems, followed by sudden movements or stops. For workers, 
human  errors  like  inadequate  working  methods  or  tools  and  improper  working  body 
positions  are  among  the  most  common  causes  recorded,  alongside  falling  objects  and 

10 

 
 
 
slipping or tripping. Problems like entrapment or uncontrolled movements or stops of the 
lift are uncommon. 

Considering the vast number of journeys that lifts complete every day, fatal accidents are 
rare. Therefore, European lifts are a safe means of transport. 

4.  EVALUATION FINDINGS (ANALYTICAL PART) 

4.1.  To what extent was the intervention successful and why? 

The  Lifts  Directive  –  and  with  it,  CE-marked  lifts  –  have  been  in  place  for  30  years. 
Successive  evaluations,  most  recently  in  2019,  have  concluded  that  the  Directive  has 
successfully created a single market for lifts by harmonising safety requirements. 

This  evaluation  confirms  these  findings.  As  shown  in  the  previous  chapter,  EU  lift 
manufacturers  are  globally  competitive  and  intra-EU  trade  has  increased  significantly 
since 2011. Stakeholders agree that the Directive has a positive impact on the single market 
by reducing trade barriers (see Figure 7 and refer to the synopsis report in Annex V for 
further details). 

Figure 7: Contribution of the Directive to improving or worsening the situation on the EU single market (lifts sector) in 
the EU (n=86) 

The  previous  chapter  also  showed  that  lifts  in  the  EU  are  safe  and  becoming  safer. 
Participants in the consultations for this evaluation perceive lifts as safe, and over 80%12 

12 In the targeted survey, 83% (93 out of 112) of participants rated lift safety in the EU as satisfactory or very 
good, a view echoed by 79% (37 out of 47) of respondents to the public consultation. Moreover, 77% 
(96 out of 112) of survey respondents believe that lift safety has improved - moderately or significantly 
- over the past decade, and only 16% (18 out of 112) noted some variation in safety standards between 
countries. Over half of the respondents (52%, 58 out of 112) also believe that the number of lift-related 

11 

 
 
 
 
consider safety as improving. Few noted differences between Member States in terms of 
safety.  Respondents  attributed  this  improvement  to  strengthened  regulatory  standards, 
technological  advances  in  safety  controls,  better  lift  design,  regular  maintenance  and 
inspections. 

The  2019  evaluation  concluded  that  the  recast  Lifts  Directive  was  fit  for  purpose. 
Economic operators and notified bodies have confirmed that evaluation’s finding that the 
Directive’s  benefits  outweigh  its  costs.  Generally,  costs  have  increased  for  reasons 
unrelated to the Lifts Directive, such as higher labour and energy costs. Compliance costs 
are higher for SMEs than for larger companies, as larger companies often use conformity 
assessment module H/H1 (‘full quality  assurance’). Under this module,  a notified body 
certifies a company’s ability to ensure product compliance without additional intervention 
by a notified body. The extent of the cost difference between SMEs and larger companies 
cannot be quantified, because of a lack of statistics on conformity assessments. For a more 
detailed discussion of this module, see the next section. 

Economic operators appreciate the creation of a  common EU regulatory framework for 
lifts and safety components, as it has made importing and exporting within the EU easier. 
The cost of doing business in multiple EU Member States is lower than it would be without 
the Lifts Directive, because conformity assessments are recognised across countries and 
no additional authorisations are required. Large companies benefit more than SMEs from 
the internal market, because they tend to operate in more countries. 

Costs for notifying authorities13 and market surveillance authorities mainly stem from the 
NLF  rather  than  the  Lifts  Directive.  Although  the  NLF  has  strengthened  market 
surveillance, the actual costs for market surveillance authorities remain low, as notified 
bodies carry out most of the conformity assessment work before products are placed on 
the market. 

The  following  sections  describe  the  shortcomings  of  the  Lifts  Directive.  Cross-cutting 
issues  that  apply  to  all  legislation  based  on  the  NLF  and  issues  specific  to  the  Lifts 
Directive  are  discussed  separately14.  The  annex  to  the  contractor’s  report  includes  a 
detailed  information  sheet  on  each  issue.  The  Commission  has  recently  evaluated  the 

accidents is decreasing. Similarly, a majority of participants in the public consultation (55%, 26 out of 
47) did not report  any major safety concerns, with most perceiving safety levels as stable across EU 
countries.  

13 The public authorities in the Member States responsible for notifying conformity assessment bodies under 

legislation such as the Lifts Directive. Notifying authorities appoint the notified bodies. 

14 The study report includes an annex containing a detailed information sheet on each of the issues analysed. 

12 

 
 
NLF15 and the Standardisation Regulation16 and is currently revising them.17 An evaluation 
combined  with  an  impact  assessment  of  the  Market  Surveillance  Regulation  is  in 
progress18. The evaluation matrix in Annex III presents an analysis of the evaluation results 
structured according to the evaluation questions that guided the research. 

4.1.1  Cross-cutting NLF issues 

Given the very long lifetime of lifts, their modernisation and maintenance are essential 
for long-term safety. As with other legislation based on the NLF, the Lifts Directive does 
not cover lifts once they are put into service. It only requires lifts to be designed and put 
into service with all the necessary tools and instructions that make it possible to maintain 
them safely. 

During  the  evaluation,  stakeholders  noted  the  positive  impact  of  Commission 
Recommendation  95/216/EC19  on  improving  the  safety  of  existing  lifts.  It  was  adopted 
together with the original version of the Lifts Directive in 1995 to accommodate the fact 
that the Directive did not go beyond placing products on the market. It promoted safety 
upgrades to existing lifts, which encouraged Member States to adopt national rules in this 
area and initiated European standardisation. Currently, 21 Member States have such rules 
in  place  (see  Annex  IX  for  an  overview).  Occasionally,  Member  States  conduct 
modernisation campaigns; for example, Belgium recently took measures to improve the 
safety of historical lifts to an acceptable level.20 

The NLF evaluation found that the fact that product legislation aligned with the NLF only 
covers the placing of products on the market is a shortcoming. Responsibility for regulating 
the  maintenance  and  modernisation  of  these  products  rests  with  national  authorities. 
However, it can no longer  be assumed that a product  will remain safe after it  has  been 
placed  on  the  market.  For  example,  many  products  require  updates  throughout  their 
lifetime  because  of  cybersecurity  risks.  The  transition  to  the  circular  economy  requires 

15  Evaluation  of  the  New  Legislative  Framework  (Decision  No  768/2008/EC  and  Regulation  (EC)  No 
765/2008),  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12654-Evaluation-
of-the-New-Legislative-Framework-for-EU-legislation-on-industrial-products_en. 

16  Evaluation  of  Regulation  (EU)  No  1025/2012:  Staff  Working  Document,  Executive  Summary  and 
supporting  study  [Evaluation  study  of  the  regulation  (EU)  1025/2012  on  European  standardisation  - 
Publications Office of the EU]. 

17  NLF  revision:  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14715-Product-

legislation-ensuring-futureproof-rules-revision-of-the-New-Legislative-Framework-NLF-_en; 
Regulation: 
Standardisation 
say/initiatives/14511-Standardisation-Regulation-revision_en  

https://ec.europa.eu/info/law/better-regulation/have-your-

18  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14807-Market-surveillance-and-

compliance-of-products-evaluation-and-possible-revision-of-Regulation-EU-2019-1020_en  

19 https://eur-lex.europa.eu/eli/reco/1995/216/oj/eng 

20 

https://economie.fgov.be/fr/themes/qualite-securite/securite-des-produits-et/reglementations-

specifiques/ascenseurs-et-installations/ascenseurs/modernisation-des-ascenseurs  

13 

 
 
clear  end-of-life  rules.  Refurbishment  and  repair  –  needed  throughout  the  lifetime  of  a 
product - are also receiving more attention. These developments are especially relevant for 
lifts, which typically remain in use for several decades. 

Spare parts and the replacement of CE-marked safety components are a recurring topic 
in many sectors regulated under the NLF, and the lift sector is no exception. Two thirds of 
the respondents to the public consultation (8 out of 12) reported difficulties in using spare 
parts, especially for older lifts, because technology and standards have evolved. Under the 
Lifts Directive, safety components listed in Annex III must undergo conformity assessment 
and be CE-marked independently. As lifts have a very long lifetime, it is regularly the case 
that CE-marked safety components need to be replaced but are no longer available. These 
components can be replicated, but it is not sufficiently clear what requirements apply and 
how  compliance  should  be  assessed  and  documented.  Two  representatives  of  notified 
bodies  consulted  on  this  topic  considered  the  current  guidance  on  how  to  ensure 
compliance of spare parts too vague, because it hinges on the term ‘compatible’21, which 
can  be  interpreted  in  many  ways.  This  creates  legal  uncertainty  and  leads  to  divergent 
practices across sectors. 

Stakeholders  are  satisfied  with  the  Lifts  Directive’s  conformity  assessment  modules 
(95%;  n=87  out  of  the  91  respondents  to  the  targeted  survey).  Safety  component 
manufacturers and lift installers can choose from several conformity assessment modules 
set  out  in  the Lifts  Directive,  meaning  there is  flexibility in  how product conformity  is 
assessed. Their preferences vary depending on factors such as company size, product and 
Member  State.  According  to  participants  in  the  consultation,  conformity  assessment 
module B (EU-type examination) is the most commonly used module for lifts (69%, n=24 
of  respondents  to  the  targeted  survey)  and  for  safety  components  (84%,  n=26).  It  is 
followed  by  module  G  (unit-type  verification)  and  module  H1  (based  on  full  quality 
assurance and design examination). 

However, one Member State in which conformity assessment module H1  predominates 
noted that the lack of third-party assessment of lifts installed under this module leads to 
too  many non-compliant lifts. Under module H1, a third party assesses whether the lift 
installer  is  qualified  to  verify  installation  conformity  themselves  but  does  not  verify 
whether the  installer has  actually  assessed  the safety  of each lift  they have installed. In 
addition, notified bodies stated that it is insufficiently clear which certificates are required 
for the two parts of module H1 (quality system and design examination), especially when 
different  notified  bodies  are  responsible  for  each  of  these  two  interrelated  parts  of  the 
module.  For  example,  if  a  non-EU  manufacturer  and  an  EU  installer  are  both  certified 
under H1, but by different notified bodies, and each performs one part of the module, it is 
not sufficiently clear which certificates should be issued. In theory, there should be only 

21 Guide to Application of the Lifts Directive, paragraph 8: ‘Where a safety component consists of more than 
one device e.g. devices to prevent uncontrolled movement of the carrier, and not all devices are replaced, 
the person undertaking the replacement should, in compliance with the instructions accompanying the 
lift concerned and the national regulations, ensure that the new device is  compatible with the existing 
devices including specifying any testing requirements needed.’ 

14 

 
 
one  certificate  per  product,  but  under  module  H1  issuing  two  certificates  may  be  more 
intuitive and practical. This problem is exacerbated if the lift model is not entirely aligned 
with  the  harmonised  standards.  The  Lifts  Directive  requires  a  notified  body  to  issue  a 
design examination certificate if products diverge from the relevant harmonised standard, 
while  the  Blue  Guide22  does  not  address  this  issue.  These  concerns  were  confirmed  by 
notified bodies and members of the expert group during the evaluation. 

Representatives of notified bodies  also found it insufficiently clear which tests must be 
performed on each safety component under module E (Annex VI). The Directive (Annex 
VI, point 3.2) states that each safety component for lifts must be inspected, and appropriate 
tests, as set out in relevant harmonised standards or equivalent tests, must be carried out. 
Responses to the targeted survey indicate that there might be differences in understanding 
between  notified  bodies  and  notifying  authorities  in  some  Member  States  about  the 
mandatory tests to be performed on each safety component for lifts (e.g. according to EN 
81-5023 or equivalent). If notified bodies are unclear about test requirements, the playing 
field becomes uneven. After all, manufacturers may choose those notified bodies that offer 
more favourable terms, including lower prices. 

A few notified bodies and industry representatives responding to the targeted survey also 
indicated that, in their view, modules D (17%, n=18 out of 108) and E (15%, n=16 out of 
108)  might  be  considered  superfluous,  given  their  limited  use.  However,  two  national 
authority representatives and one industry representative pointed out that having multiple 
module options available gives economic operators the flexibility to choose according to 
their needs and preferences, and that removing any of them would be counterproductive, 
as they still respond to market needs. 

Stakeholders are  also  concerned  about  how the conformity  assessments required by the 
Cyber  Resilience  Act24  and  the  AI  Act25  will  interact  in  future  with  the  conformity 
assessment under the Lifts  Directive. A complicating factor is  that  the requirements on 
protection  against  corruption  (cybersecurity)  and  self-evolving  behaviour  (AI)  in  the 
Machinery Regulation apply to lifts26. These requirements are closely related to those of 
the  Cyber  Resilience  Act  and  the  AI  Act.  Therefore,  the  Commission  must  provide 

22 The Blue Guide contains guidance on the application of all aspects of the implementation of EU products 
rules, 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.C_.2022.247.01.0001.01.ENG&toc=OJ%3AC%3A2022%3A24
7%3ATOC  

assessments. 

conformity 

including 

23 Cited standard EN 81-50:2020: Safety  rules  for  the  construction  and  installation of  lifts  - Examinations 

and tests - Part 50: Design rules, calculations, examinations and tests of lift components. 

24 Regulation (EU) 2024/2847, https://digital-strategy.ec.europa.eu/en/policies/cyber-resilience-act. 

25 Regulation (EU) 2024/1689, https://digital-strategy.ec.europa.eu/en/policies/regulatory-framework-ai. 

26 The Lifts Directive takes its basic safety requirements from the Machinery Regulation by referring to it in 

Annex I. 

15 

 
 
guidance  on  how  to  navigate  the  conformity  assessment  procedures  set  out  in  different 
pieces of legislation that apply to the same product. 

Across sectors, including the lift sector, there have been cases of notified bodies issuing 
misleading or fraudulent conformity assessment certificates. For example, certificates 
have been issued without authorisation (i.e. not by a notified body) or without appropriate 
conformity assessment. Stakeholders reported difficulties in obtaining information from 
manufacturers on whether products bearing such certificates have been placed on the EU 
market, which makes it difficult to trace these products. Manufacturers have little interest 
in incriminating themselves. For the same reason, enforcement action against the issuing 
notified bodies has proven difficult. The economic operators and notified bodies involved 
do have little incentive to provide evidence to the enforcement authorities. 

In terms of coherence, stakeholders repeatedly underlined the importance of the Guide to 
Application of the Lifts Directive for ensuring continued internal coherence of the Lifts 
Directive. It allows its application to be constantly adapted to new market circumstances, 
especially new technological developments. Nevertheless, stakeholders pointed out that a 
couple  of  concepts  derived  from  the  NLF  lack  workable  definitions.  ‘Substantial 
modification’ is not defined precisely enough. When a lift is substantially modified, e.g. 
when  a  new  floor  served  is  added,  its  conformity  with  the  Lifts  Directive  needs  to  be 
assessed again. Currently, the term can be interpreted so widely that there is a risk that this 
will be abused to avoid renewed conformity assessment. It is too easy to argue that a change 
to a lift does not constitute a substantial modification. The concept of ‘safety component’ 
(see also the lift-specific discussion below) also poses a problem following the adoption 
of the AI Act. While the Lifts Directive lists safety components by name in Annex III, the 
AI Act uses a broader definition of the concept, which determines the scope of the act. As 
both acts apply to lifts, the definitions must be reconciled to ensure coherent application. 

Stakeholders also pointed out a lack of coordination among notifying authorities, which 
leads to an unlevel playing field for notified bodies. Unlike market surveillance authorities 
and notified bodies, notifying authorities have no formal administrative infrastructure for 
regular  meetings  and  exchanges,  even  though  legislation  based  on  the  NLF  requires 
coordination (Article 35 of the Lifts Directive). Since October 2023, the Commission has 
initiated  several  informal  meetings  between  the  notifying  authorities  in  the  lift  sector. 
Stakeholders cited the coordination carried out by the group of notified bodies as a very 
valuable  development  that  has  resulted  in  a  more  harmonised  application  of  the  Lifts 
Directive and increased confidence in the work of notified bodies in the lift sector. Since 
2016,  the  group  of  notified  bodies  for  lifts  has  published  18  recommendations  for  use 
(RfUs), which are notes in which notified bodies clarify how the provisions of the Lifts 
Directive that are open to interpretation should be understood. 

16 

 
The evaluation of the Lifts Directive confirmed many of the findings from the evaluation 
of the Standardisation Regulation27. Stakeholders overwhelmingly agree that harmonised 
standards are instrumental for the effective application of the Lifts Directive. According to 
them, these standards have contributed to a well-functioning single market and have been 
the main driver behind the gradual increase in the level of safety. Stakeholders consider 
that the European standards cited in support of the Lifts Directive adequately reflect the 
state-of-the-art and are sufficiently technology-neutral, as reported by 81% of respondents 
to the targeted consultation, n=60 out of 74. In addition, 85% of survey respondents (n=66 
out of 78) believe the standards are innovation-friendly. 

However, a little over half of the respondents to the targeted consultation were concerned 
about  the  length  and  complexity  of  the  standardisation  process  (57%,  n=49  out  of  163 
responses). Additionally, stakeholders noted that SMEs are underrepresented in the time-
consuming standard development activities. Furthermore, the development of harmonised 
standards  might  not  be  sufficiently  responsive  to  technological  advancements.  For 
example,  stakeholders  observed  that  developments  in  the  field  of  electronics  were 
addressed more promptly at the international level. 

Market  surveillance  differs  widely  in  its  organisation  and  resource  allocation  across 
Member States. Over the years,  the increasing  volume of legislation  applicable to  each 
product has strained authorities’ limited resources, especially in smaller Member States. 
As a result, the enforcement of product safety legislation, like the Lifts Directive, competes 
for resources with the enforcement of legislation pursuing other policy goals. In practice, 
market surveillance authorities in the lift sector mostly work reactively. They benefit from 
the  effective  work  of  notified  bodies,  which  successfully  limits  the  number  of  non-
compliant  lifts  and  safety  components  before  they  reach  the  market.  Joint  enforcement 
across Member States is gradually improving, as illustrated by the increasing number of 
entries in the Information and Communication System on Market Surveillance (ICSMS)28 
and the launch of a joint action in 202529. 

According to information collected through the targeted survey, a few market surveillance 
actions have resulted in fines and sanctions for economic operators over the past 10 years, 
as  reported  by  54%  of  respondents  (n=7  out  of  13).  Respondents  reported  five  non-
compliance cases in which fines had been imposed on manufacturers30. They also indicated 

27  Evaluation  of  Regulation  (EU)  No  1025/2012:  Staff  Working  Document,  Executive  Summary  and 
supporting study [Evaluation study of the  Regulation (EU) 1025/2012 on European standardisation  - 
Publications Office of the EU]. 

28 ICSMS is the IT system used by market surveillance authorities to communicate  with each other about 
https://webgate.ec.europa.eu/single-market-compliance-

non-compliance. 

of 

cases 
space/market-surveillance  

suspected 

29 https://ec.europa.eu/newsroom/eismea/items/863427/en 

30 The fines imposed were less than EUR 5 000 in two cases, between EUR 5 000 and EUR 10 000 in two 

other cases, and more than EUR 10 000 in one case. 

17 

 
 
that,  besides  fines,  market  surveillance  authorities  had  more  often  instructed  economic 
operators to either bring products into compliance or withdraw them from the market. 

As pointed out by the European Commission’s Directorate-General for Taxation and the 
Customs Union (DG TAXUD), lifts are put into service individually, meaning each lift is 
CE-marked after its safe installation has been verified. This implies that lifts are imported 
into  (and  exported  from)  the  EU  before  they  are  CE-marked  following  installation. 
Consequently, customs authorities cannot verify whether lifts have been CE-marked. They 
can  only  verify  the  CE  marking  of  imported  safety  components.  Therefore,  customs 
authorities cannot contribute to reducing the number of non-compliant lifts, as inadequate 
products are not identified before the end of the supply chain. 

Since 2019, the body of EU legislation applicable to lifts and safety components for lifts 
has  doubled  (Table  1,  legislation  adopted  since  2019  indicated  by  red  font)31.  Safety 
requirements from earlier legislation now coexist with product requirements regulating the 
green  and  digital  transitions.  Additionally,  new  EU  legislation  with  operational 
sustainability  requirements  has  been  adopted.  SMEs  are  not  exempt  from  product 
requirements and are only partially exempt from the operational requirements. As a result, 
safety component manufacturers and lift installers face a significantly higher regulatory 
density, meaning they must comply with a greater number of regulatory rules and bear 
additional  bureaucratic  burdens,  compared  with  the  situation  at  the  time  of  the  2019 
evaluation of the Lifts Directive. 

31 This list of legislation is not exhaustive and may vary depending on the product and company. It does not 
include national laws on the modernisation and maintenance of lifts, professional qualifications for lift 
technicians and installers, or national building codes. It also does not cover labour laws, tax laws or other 
regulations that also apply to economic operators in the lift sector at national and/or EU level, such as 
the Posted Workers Directive 96/71/EC. 

18 

 
 
 
Table 1: Legislation applicable to lifts and safety components for lifts and to lift installers and manufacturers. Adapted 
from the VDMA regulatory cockpit32. 

Legislation 

Comments 

Applicable to 
SMEs 

Already 
applicable 

Lifts Directive 2014/33/EU 

Machinery Directive 2006/42/EC - 
Machinery Regulation (EU) 2023/1230 

Product 

ATEX Directive – 2014/34/EU 

Dependent on environment 

Pressure Equipment Directive 
2014/68/EU 

Radio Equipment Directive 
2014/53/EU 

EMC Directive 2014/30/EU 

Low Voltage Directive 2014/35/EU 

Restriction Hazardous Substances 
(RoHS) Directive 2011/65/EU 

REACH Regulation (EC) 1907/2006 

General Product Safety Regulation 
(EU) 2023/988 

Cyber Resilience Act – Regulation 
(EU) 2024/2847 

AI Act – Regulation (EU) 2024/2689 

Data Act – Regulation (EU) 
2023/2854 

NIS-2 Directive 2022/2555 

EU Deforestation Regulation (EU) 
2023/1115 

Packaging and packaging waste 
Regulation (EU) 2025/40 

EU Battery Regulation (EU) 
2023/1542 + implementing acts 

Critical Raw Materials Act – 
Regulation 2024/1525 

Dependent on integrated 
components 

Dependent on integrated 
components 

PFAS restriction proposal 
under development33 

Relevant to lift packaging 

Proposal on preventing 
plastic pellets losses34 

Dependent on integrated 
components 

e.g. magnets in motors 

Operational requirements 

Carbon Border Adjustment 
Mechanism – Regulation (EU) 
2023/956 

Corporate Sustainability Due 
Diligence Directive (EU) 2024/1760 

Corporate Sustainability Reporting 
Directive (EU) 2022/2464 

EU Taxonomy & Sustainable Finance 
Regulation 2020/852  

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Indirectly relevant to manufacturers and installers 

Market Surveillance Regulation (EU) 
2019/1020 

Standardisation Regulation (EU) 
1025/2012 

x 

x 

19 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

2026/27 

2027 

x 

x 

Dec 2025 

2026 

x 

x 

x 

2027 

x 

x 

x 

x 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
SMEs struggle with the complexity and volume of EU and national legislation. They are 
also underrepresented in standardisation, which determines the minimum level of safety 
accepted  in  the  EU.  The  limited  resources  available  to  SMEs  are  a  key  factor  in  both 
problems. 

For this evaluation, the lack of reporting obligations has posed a serious obstacle. The 
Commission has been unable to objectively verify the safety of lifts, which is one of the 
two objectives of the Lifts Directive. As accidents and their causes and consequences are 
not  systematically  or  independently  recorded,  this  evaluation  has  had  to  rely  on  data 
provided  by  ELA,  the  association  of  lift  manufacturers.  The  Machinery  Regulation  has 
recently introduced mandatory accident reporting. The General Product Safety Regulation 
requires manufacturers to report accidents involving their products. However, those data 
will  still  not  enable  an  objective  assessment  as  they  rely  on  evidence  provided  by 
manufacturers, who may not be informed about accidents with their products. 

4.1.2  Issues specific to the Lifts Directive 

Given  the  long  lifetime  of  lifts,  repair  and  maintenance  present  significant  business 
opportunities,  especially  for  SMEs.  To  ensure  lift  safety  and  fair  competition  in  the 
maintenance market, the Lifts Directive provides that ‘machinery must be supplied with 
all the special equipment and accessories essential to enable it to be adjusted, maintained 
and used safely.’ During the evaluation, the association representing SMEs in the lift sector 
reiterated  a  long-standing  complaint:  proprietary  systems  and  tools,  insufficient 
communication on the technical specifications of lifts and restricted access to lift machine 
rooms hinder their participation in the maintenance market. This problem may worsen in 
future, because the Lifts Directive does not regulate access to lifts’ electronic components. 
Some lift installers could prevent other companies from taking over lift maintenance by 
locking such access. 

The Lifts Directive’s requirement on the accessibility of lifts for people with disabilities35 
is  often  interpreted  as  optional,  as  in  its  current  wording  it  applies  only  to  lifts  where 
adaptations are possible. It is also limited to the structural features of the lift. During the 

32 https://www.vdma.eu/en-GB/viewer/-/v2article/render/145420244 (accessed 8 October 2025). 

33 https://echa.europa.eu/-/echa-publishes-updated-pfas-restriction-proposal (accessed 17 December 2025). 

34 https://environment.ec.europa.eu/topics/plastics/microplastics_en (accessed 17 December 2025). 

35 ‘Where the lift is intended for the transport of persons, and where its dimensions permit, the car must be 
designed and constructed in such a way that its structural features do not obstruct or impede access and 
use by disabled persons and so as to allow any appropriate adjustments intended to facilitate its use by 
them.’ 

20 

 
 
 
evaluation, stakeholders noted that the cited standard EN 81-7036 on the construction of 
lifts for people with disabilities is still considered merely an addition to the foundational 
standards EN 81-2037 and EN 81-5038 rather than an integral part of the design of any new 
lift. Consequently, accessibility is not seen as a feature that all lifts should have by default, 
but rather as an add-on to the basic design. In addition, some Member States have adopted 
more  specific  legislation,  such  as  rules  on  the  minimum  width  of  lifts,  which  risk 
fragmenting  the  single  market,  and  suggest  that  the  Lifts  Directive  do  not  ensure  the 
desired  level  of  accessibility.  Finally,  the  evaluation  highlighted  that  for  people  with 
disabilities not only safety, but also reliability is essential. When a lift is out of service, 
people with reduced mobility are prevented from going where they need to go. Currently, 
the Lifts Directive does not contain any provisions on minimising lift downtime. 

Besides lifts, the scope of the Lifts Directive includes safety components for lifts. It sets 
out  requirements  for  such  components,  including  safety  requirements,  manufacturers’ 
obligations39  and  rules  on  the  applicable  conformity  assessment  modules.  Rather  than 
defining the concept of safety components, the Directive lists the safety components within 
its scope in Annex III: 

1.  Devices for locking landing doors. 
2.  Devices to prevent falls referred to in point 3.2 of Annex I to prevent the car from 

falling or moving uncontrollably. 

3.  Overspeed limitation devices. 
4.  (a) Energy-accumulating buffers: 

(i) non-linear, or 
(ii) with damping of the return movement. 

(b) Energy-dissipating buffers. 

5.  Safety devices fitted to jacks of hydraulic power circuits where these are used as 

devices to prevent falls. 

6.  Electric  safety  devices  in  the  form  of  safety  circuits  containing  electronic 

components. 

The Lifts Directive does not give the Commission delegated powers to update this list, so 
it has remained unchanged since 1995. Meanwhile, the Machinery Regulation, to which 

36  Cited  standard  EN  81-70:2021+A1:2022  Safety  rules  for  the  construction  and  installation  of  lifts  – 
Particular applications for passenger and goods passenger lift – Part 70: Accessibility to lifts for persons 
including persons with disability. 

37 Cited standard EN 81-20:2020  Safety  rules  for  the  construction  and  installation  of  lifts  –  Lifts  for  the 

transport of persons and goods – Part 20: Passenger and goods passenger lifts. 

38 Cited standard EN 81-50:2020  Safety rules for the construction and installation of lifts  – Examinations 

and tests – Part 50: Design rules, calculations, examinations and tests of lift components. 

39 For lifts, the Lifts Directive does not define the concept of ‘manufacturers’ for lifts. Instead, it lays down 
obligations for lift installers. In the Lift Directive, the concept ‘manufacturer’ is only relevant for safety 
components.  

21 

 
 
the  Lifts  Directive  refers,  and  the  AI  Act,  which  also  applies  to  lifts,  have  introduced 
separate definitions of safety features and safety components. 

During the evaluation, stakeholders were divided on whether the list  should be revised. 
Based on the consultations, it was concluded that the sector has managed with the current 
situation and is cautious about the consequences of updating the annex. Manufacturers and 
notified bodies have taken it upon themselves to ensure continued lift safety as technology 
advances despite the potential obsolescence of Annex III and, by implication, of the scope 
of the Lifts Directive. Some stakeholders suggested adding items such as car door locking 
devices, stopping devices and safety-related software to Annex III. Others considered that 
the current combination with the essential health and safety requirements of the machinery 
legislation was sufficient. 

The Lifts Directive gives Member States discretion in implementing measures to prevent 
risk of crushing when the lift car reaches one of its extreme positions. Member States may 
require prior approval of the proposed technical solution if there is insufficient free space 
or  refuge  at  the  lower  or  upper  end  of  the  lift  shaft.  Currently,  20  Member  States  and 
Norway have legislation requiring such prior approvals; in 11 of these, market surveillance 
authorities are involved. Participants in the evaluation were divided on the merits of these 
arrangements.  The  main  concerns  were  the  lack  of  an  overview  of  national  provisions, 
whether  they  apply  to  only  existing  or  also  new  buildings,  differing  national  approval 
criteria and processes, and possible differences in safety. Economic operators did not report 
any  negative  impact  of  this  approach  on  the  market  or  innovation.  While  no  data  are 
available to assess the effect of national prior approvals on safety, there is also no anecdotal 
evidence that it causes safety problems. 

The lift shaft, which bears the weight of the lift, and the access routes to and from the lift 
are essential for the safe use of lifts. Consequently, the interface between the building 
and  the  lift  is  a  recurring  topic  of  discussion,  especially  in  standardisation,  and  it 
resurfaced during the evaluation. As building codes are national, meaning requirements for 
buildings  are  not  regulated  at  EU  level,  lift  installers  must  adapt  their  installations  to 
differing  national  requirements  to  ensure  safety.  Some  stakeholders,  particularly  lift 
installers  and  standardisers,  argue  that  provisions  on  buildings  should  be  included 
harmonised  standards  cited  in  support  of  the  Lifts  Directive  to  achieve  greater 
harmonisation  across Member States. However,  this is  not  legally possible,  as it would 
infringe  on  Member  States’  national  competence  over  building  codes.  Nevertheless, 
standardisers are free to develop standards other than those requested by the Commission 
and cited in the Official Journal of the European Union, and Member States are then free 
to refer to these standards in their national building codes. 

During the evaluation, the possible use of national registers of lifts to facilitate market 
surveillance was discussed, as this would provide an overview of all lift installations by 
date and location, making it easier to locate lift models found to be non-compliant after 
installation.  Some  Member  States,  such  as  Germany  and  Italy,  maintain  such  registers. 
Others, such as Denmark and Spain, have discontinued them because the benefits did not 
justify the time and resources invested. 

22 

 
Some terms, such as ‘installer’40, ‘safety circuit’, ‘electric safety devices’, ‘permanent’ and 
‘putting  on  the  market’,  are  not  used  consistently  throughout  the  Lifts  Directive.  This 
creates a need for guidance, as requested, for example, by the group of notified bodies in 
the lift sector. 

For the basic safety requirements generally applicable to machinery, point 1.1 of Annex I 
to the Lifts Directive refers to Annex I to the Machinery Directive 2006/42/EC: 

‘Where the relevant risk exists and is not dealt with in this Annex, the essential health 
and  safety  requirements  of  Annex  I  to  Directive  2006/42/EC  of  the  European 
Parliament and of the Council apply. The essential health and safety requirements of 
point 1.1.2 of Annex I to Directive 2006/42/EC apply in any event.’ 

However,  when  the  Machinery  Directive  was  revised  to  become  the  Machinery 
Regulation,  Annex  I  to  the  Machinery  Directive,  to  which  the  Lifts  Directive  refers, 
changed.  As  a  result,  new  requirements,  such  as  those  on  self-evolving  behaviour  or 
protection  against  corruption  (cybersecurity),  also  apply  to  lifts.  In  this  context,  the 
definition  of  ‘relevant  risk’  has  become  increasingly  significant.  It  remains  to  be  seen 
whether the considerable room for interpretation that this formulation provides will create 
problems, such as safety concerns, when the Machinery Regulation becomes applicable. 

The Cyber Resilience Act and the AI Act address major risks that technological progress 
has created since 1995. To the extent necessary, specifications for lifts will be set out in 
harmonised standards. A few years after the implementation of these two acts, it will be 
necessary to evaluate to which extent they are fit for purpose in the lift sector. 

On energy efficiency, the 2019 study on ecodesign for lifts41 pointed out the lack of energy 
efficiency requirements for lifts and the significant potential for energy savings. The study 
recommended  including  lifts  in  the  list  of  technical  building  systems  in  the  Energy 
Performance of Buildings Directive42. However, this  recommendation  was  not  taken  on 
board in the 2024 revision of that Directive. As a result, there are still no energy efficiency 
requirements for lifts despite an estimated annual electricity saving potential of 3 TWh by 
2045 (comparable to Malta’s annual electricity consumption). In practice, the sector uses 
international standards (EN ISO 25745), and national requirements on energy efficiency 
apply. 

40 Responsibility for placing a CE-marked lift on the market at the end of the ‘manufacturing process’ does 
not lie with the manufacturer, but with the installer, as defined in Article 2, point (6). The Directive does 
not provide a separate definition for ‘lift manufacturer’; this may be the economic operator that requests 
the EU-type examination certificate but does not install the lift. Stakeholders confirmed that the installer 
and the manufacturer usually coincide. Nevertheless, the Directive clearly designates the installer as the 
operator responsible for compliance of the installed product. 

41 VITO, Fraunhofer ISI (2019), Ecodesign preparatory study for lifts implementing the Ecodesign Working 

Plan 2016 -2019, European Commission. 

42 Directive 2009/125/EC establishing a framework for the setting of ecodesign requirements for energy-

related products. 

23 

 
 
4.2.  How has the EU intervention made a difference and for whom? 

Stakeholders responded positively to the EU added value of the Directive. A significant 
majority of respondents considered that the Directive provided benefits to the EU internal 
market, both in terms of free movement and safety. In particular, stakeholders indicated 
that the Directive43: 

•  had increased the safety of lifts for users, with 91% (91/100) either agreeing or strongly 
agreeing, and for lift operators and maintenance personnel as a result of alignment with 
EU safety standards (84%, 84/100); 

•  had contributed to reducing barriers to trade within the single market (83%, 83/100) 
and to creating a level playing field for economic operators (72%, 72/100); 

•  had increased the competitiveness of EU companies in the lift sector on both the EU 
market (71%, 71/100) and the global market (64%, 64/100). 

Moreover,  57%  of  respondents  (57/100)44  disagreed  or  strongly  disagreed  that  similar 
results could have been achieved through national action alone, without EU intervention. 

4.2.1  Brussels effect 

The evaluation gave special attention to what is known as the ‘Brussels effect’. This refers 
to the ability of the European Union to determine, shape or otherwise influence regulatory 
standards and/or behaviour beyond the confines of its jurisdiction45. 

European  lift  standards  play  a  decisive  role  in  shaping  global  lift  standardisation.  The 
foundational EU standards EN 81-2046 and EN 81-5047 were adopted as ISO standards ISO 
8100-1:2019  and  ISO  8100-2:201948.  In  addition,  the  European  Committee  for 
Standardization, (CEN, Comité Européen de Normalisation), leads three of five ongoing 
standardisation processes for the EN ISO 8100 series. 

Membership of, or cooperation with, CEN by national standardisation bodies worldwide 
is an important factor in the global influence of European lift standards. 

43 Including respondents who answered ‘don’t know’. 

44 Including respondents who answered ‘no opinion’. 

45 Anu Bradford, The Brussels Effect: How the European Union Rules the World (OUP 2020). 

46 EN 81-20:2020 

Safety  rules  for  the  construction  and  installation  of  lifts  -  Lifts  for  the  transport  of 

persons and goods - Part 20: Passenger and goods passenger lifts. 

47 EN 81-50:2020 

Safety rules for the construction and installation of lifts - Examinations and tests - Part 

50: Design rules, calculations, examinations and tests of lift components. 

48 These standards are currently being updated.  

24 

 
 
The world's second-largest lift exporter, after the EU, is China. Additionally, the Chinese 
market is important for European lift manufacturers because currently ten times more lifts 
are installed each year in China than in the EU. In 2005, CEN’s technical committee on 
lifts (CEN/TC 10) and the Standardization Administration of China (SAC/TC 196) signed 
a cooperation agreement to align their efforts in developing lift standards. As a result of 
these regular exchanges, China’s lift safety standards have long been based on EN 81-1, 
i.e. the precursor  to  the  current  EN 81-20. According to the Chinese seconded national 
experts  on  standardisation,  over  half  (34  out  of  65)  of  the  currently  active  national  lift 
standards are adopted foreign standards. Of these, 5 are directly EN standards and the other 
29 are ISO standards. The latest set of Chinese standards (the GB/T 7588 series) are based 
on  ISO  8100-1:2019  and  ISO  8100-2:2019,  which  originated  in  the  EU,  as  mentioned 
above.  Additionally,  Chinese  lift  standards  refer  to  European  standards  on  several 
occasions. 

Seven non-EU Member States that are members of CEN have adopted EU standards. For 
example, the Turkish Standards Institute, the TSE, has transposed various EN standards 
into  national  standards,  including  TS  EN  81-1  and  TS  EN  81-2,  which  govern  lift 
construction and installation. 

Some  countries  have  aligned  their  standards  with  those  of  the  EU  on  the  basis  of 
partnerships  with  CEN.  For  example,  Standards  Australia  works  closely  with  CEN  on 
harmonisation and mutual recognition of international standards. As a result, several parts 
of AS 1735 are direct adoptions or adaptations of EU standards. 

Although formal cooperation between India and CEN/TC 10 has been limited, the Bureau 
of Indian Standards (BIS) has mostly aligned its standards with the EN 81 series, which 
are  the  European  standards  for  lifts.  As  confirmed  by  the  seconded  European 
standardisation expert in India, a framework copyright licence agreement between CEN-
CENELEC  and  India’s  national  standardisation  body,  the  BIS,  is  currently  under 
discussion. 

European  lift  standards  also  extend  their  influence  beyond  formal  cooperation.  For 
example, the Eurasian Economic Union’s Technical Regulation on the safety of lifts (TR 
CU  011/2011)  is  influenced  by  EU  and  international  standards,  although  it  is  not 
completely aligned with them. 

Additionally, many producers of lifts around the world have chosen to develop products in 
compliance  with  EU  standards,  even  in  countries  where  these  standards  are  not  legally 
mandatory. For example, Japan has its own national code, but firms such as Mitsubishi and 
Hitachi use EN 81 for export. Similarly, manufacturers in Brazil, Hong Kong, Singapore 
and South Korea often choose to align with EU standards. In the United Arab Emirates and 
Qatar, EN 81 standards are often required in construction tenders. 

Table 2 below provides an overview of the adoption of current EU lift standards by third 
countries, whether identical or adapted. 

25 

 
Table 2: Adoption of current EU lift standards by third countries 

Country 

Adoption of EN standards by TC 10  Total 

Identical 

Modified 

Other 

Armenia 
Australia 
Belarus 
Bosnia and Herzegovina 
China 
Côte d’Ivoire 
Georgia 
Kosovo 
Lebanon 
Malaysia 
Moldova, Republic of 
Montenegro 
Morocco 
Namibia 
Saudi Arabia 
South Africa 
Tunisia 
Ukraine 
Uzbekistan 

2 
4 
1 
21 
1 
2 
36 
7 

26 
24 
2 
1 
5 
2 
1 
30 
2 

Total 

189 

2 

1 

1 

1 

5 

2 
6 
1 
37 
2 
2 
39 
7 
1 
1 
42 
36 
9 
1 
5 
3 
6 
34 
2 

16 

3 

1 

16 
12 
7 

5 
4 

77 

271 

As discussed in Chapter 2, the EU is the largest lift exporter in the world and enjoys  a 
significant trade surplus. However, it is not possible to determine to which extent this is 
due to the international success of European lift standards, or vice versa. Nevertheless, it 
is likely that both aspects are linked. 

The responses to the survey conducted as part of this evaluation share this impression. The 
vast  majority  of  stakeholders  participating  in  the  targeted  survey  believe  that  the  EU 
standards have contributed to global advancements in science and technology (79%, n=68 
out of 86), that the EU is a global leader in setting lift standards (86%, n=74 out of 86); 
and that EU standards have influenced international standards (79%, n=68 out of 86). 

For more detailed information on the Brussels effect, please see Annex VIII. 

4.3. 

Is EU action still relevant? 

Like the 2019 evaluation, the current evaluation confirms that the Lifts Directive’s main 
objectives  remain  relevant  and  aligned  with  stakeholders’  needs.  Approximately  85% 
(n=84 out of 99) of respondents to the targeted survey confirmed the continued relevance 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
of  the  internal  market  objective,  while  88%  (n=91  out  of  103)  supported  the  goal  of 
ensuring a high level of safety for users, and 87% (n=90 out of 103) for lift operators and 
maintenance personnel. 

On  the  scope  of  the  Lifts  Directive  –  particularly  the  speed  criterion  of  0.15 m/s  that 
distinguishes it from the Machinery Directive – 85% (n=81 out of 95) of respondents to 
the targeted survey considered it fully relevant. Nevertheless, two stakeholders proposed 
removing the speed threshold, arguing that any lift capable of transporting people should 
fall  under  the  Lifts  Directive  due  to  similar  safety  risks.  Conversely,  one  stakeholder 
advocated  raising  the  minimum  speed  threshold  to  0.30 m/s,  citing  technological  and 
safety advancements. The same stakeholder noted the potential risk that installers might 
deliberately limit lift speed to remain just below the threshold and thereby avoid the Lifts 
Directive’s application. 

It could be considered a shortcoming that the scope of the Directive includes the safety, 
but not the reliability and accessibility of lifts. As discussed in section 4.1, this of the 
utmost importance for persons with disabilities. Since the Lifts Directive was first adopted 
in 1995, the EU’s ageing society has made this aspect more relevant. Additionally, society 
now places a higher value on the inclusion of people with disabilities. 

Maintenance  and  inspections  were  cited  by  respondents  to  the  targeted  survey  as  the 
fourth most important factor in improving lift safety. In the context of the revision of the 
NLF, questions have emerged about whether the lifetime of products such as lifts should 
be regulated at EU level, particularly in relation to the circular economy and cybersecurity 
updates.  For  lifts,  the  most  salient  issue  is  ensuring  access  to  the  lift’s  electronic 
components for maintenance and repair. 

Due to the long service life of lifts, there are many lifts in operation today that do not meet 
state-of-the-art standards. About one third of respondents to the targeted survey indicated 
that  the  absence  of  EU  rules  on  modernisation  limits  the  Lifts  Directive’s  relevance. 
Similarly, the co-legislators deemed the modernisation of lifts so important that in 1995 
they  adopted  a  recommendation  on  this  subject  alongside  the  first  version  of  the  Lifts 
Directive.  While  there  is  no  evidence  that  old  lifts  pose  major  safety  risks,  data  on  lift 
accidents are not collected systemically and are therefore patchy. 

The scope of the Lifts Directive is partly determined by the list of safety components in 
Annex III. As that annex is arguably outdated, technological progress may have limited 
the relevance of the Lifts Directive in this respect. For a full discussion of this issue, please 
refer to section 4.1. 

Due to technological developments, the concept of ‘means of suspension’ is no longer 
sufficiently technology-neutral. Most notably, the redundancy requirement names specific 
means  of suspension,  such as  ropes  and chains, that are increasingly being replaced by 
more modern alternatives. The Commission updated the Guide to Application of the Lifts 

27 

 
Directive49  in  2025  to  provide  guidance,  but  the  core  issue  within  the  Directive  itself 
remains unresolved. 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

In general, the evaluation confirmed the findings of the 2019 assessment. This time, more 
attention was paid to specific issues that had already been raised in part in 2019. These 
issues were analysed in detail, and stakeholders were consulted on their urgency. 

Overall, the evaluation once again confirmed that the Lifts Directive is fit for purpose. 

It  is  effective  in  the  sense  that  it  has  created  a  single  market  for  lifts  and  trade  among 
Member States continues to grow. The lifts traded within the single market provide a high 
and  consistently  improving  level  of  safety.  Therefore,  the  Lifts  Directive  meets  its  two 
objectives. 

Besides some minor concerns50, the main shortcoming of the Lifts Directive in terms of 
effectiveness is the long-standing issue of unfair competition in the maintenance market, 
stemming  from  restricted  access  to  lifts  and  tools  and  instructions  necessary  for 
maintenance  and  repair.  Technological  progress  has  exacerbated  the  problem,  as  it  has 
become possible to digitally lock access to lifts’  electronic components. With restricted 
access to tools, information and electronic components, it is difficult for the lift owner to 
switch maintenance companies. This creates a market barrier, especially for SMEs offering 
maintenance and repair services. 

In  terms  of  efficiency,  the  Lifts  Directive  does  not  generate  any  costs  beyond  those 
associated  with  the  system  set  up  by  the  NLF.  In  other  words,  the  Directive  does  not 
diverge  significantly  from  the  standard  system  of  essential  requirements,  conformity 
assessment,  responsibilities  of  various  actors,  etc.  Some  economic  operators  reported 
rising  costs,  but  rather  than  being  caused  by  the  Lifts  Directive,  these  increases  reflect 
rising energy and labour costs and inflation in general. 

The evaluation has also reaffirmed the EU added value of the Lifts Directive, and of the 
single market more broadly. 

The need for coherence with new pieces of legislation, notably the Machinery Regulation, 
the Cyber Resilience Act and the AI Act, has made additional guidance necessary.  

The evaluation found that some recommendations from the 2019 ecodesign preparatory 
study  for  lifts,  particularly  the  proposal  to  include  lifts  on  the  list  of  technical  building 

49 https://ec.europa.eu/docsroom/documents/64174 

50 Fragmented implementation across Member States of  the requirement for prior approval to prevent the 
risk  of  crushing  when  the  car  is  in  one  of  its  extreme  positions;  issues  at  the  interface  between  the 
building  and  the  lift;  insufficiently  clear  or  technology-neutral  concepts  (‘installer’,  ‘means  of 
suspension’, ‘permanent’), inconsistent use of terms (‘safety circuit’, ‘electric safety devices’, ‘putting 
on  the  market’);  and  the  potential  for  inconsistent  interpretation  resulting  from  the  reference  to  the 
essential requirements of the Machinery Directive/Regulation. 

28 

 
 
systems under the Energy Performance in Buildings Directive, have not been implemented. 
As a result, there are still no energy efficiency requirements for lifts despite an estimated 
annual  electricity  saving  potential  of  3  TWh  by  2045  (comparable  to  Malta’s  annual 
electricity consumption). 

The Lifts Directive’s current scope may limit its relevance in two ways. First, Annex III 
lists  the  safety  components  for  lifts  that  fall  within  the  scope  of  the  Directive,  i.e. 
components  that  need  to  be  CE-marked  independently.  As  a  result  of  technological 
progress, this list and therefore the scope of the Lifts Directive are outdated. Stakeholders 
are divided over whether that creates a safety problem. 

Second, accessibility for persons with disabilities has become increasingly important since 
the Lifts Directive was adopted. However, accessibility does not fall squarely within the 
scope of the Lifts Directive, which focuses on safety and the single market. Accessibility 
goes beyond safety and also includes reliability, i.e. lifts’ ability to perform their intended 
function without fail. 

Overall, each group of stakeholders mentioned shortcomings of the Lifts Directive – some 
smaller, some bigger  –  that  they would like to see addressed.  However,  those concerns 
were not shared by all stakeholders. Stakeholders expressed doubts as to whether revising 
the Directive to address their concerns, and those of others, would produce a net positive 
outcome for their specific group. 

Some of the shortcomings described in this evaluation are inherent to the NLF on which 
the Lifts Directive is based. As described in section 4.1, those horizontal issues are unclear 
requirements for spare parts, shortcomings in individual conformity assessment modules, 
undefined  concepts  (‘substantial  modification’,  ‘safety  component’)  and  insufficient 
coordination among notifying authorities. In addition, there is a debate about whether, and 
to which extent, maintenance and modernisation should be regulated by legislation based 
on the NLF rather than by national legislation as is currently the case. Finally, the absence 
of reporting obligations on accidents makes it difficult to objectively evaluate lift safety, 
which is one of the two main objectives of the Directive. 

Beyond the NLF, the evaluation confirmed that the lift sector experiences the same issues 
as  those  identified  in  the  evaluation  of  the  Standardisation  Regulation,  such  as  lengthy 
processes  for  updating  standards  and  difficulties  for  some  stakeholders  in  making  their 
voices heard in the standardisation process51. The evaluation showed a significant ‘Brussels 
Effect’ largely driven by both formal and informal, but systematic collaboration among 
national and international standardisation bodies. 

Finally, a significant increase in regulatory density at EU level is stretching the resources 
of  manufacturers,  installers,  notified  bodies  and  market  surveillance  authorities,  all  of 

51  Evaluation  of  Regulation  (EU)  No  1025/2012:  Staff  working  document,  executive  summary  and 
supporting  study  [Evaluation  study  of  Regulation  (EU)  1025/2012  on  European  standardisation  - 
Publications Office of the EU]. 

29 

 
 
whom must ensure compliance with an increasing number of requirements beyond safety. 
Since  2019,  the  number  of  pieces  of  EU  legislation  applicable  to  lifts  and  safety 
components  for  lifts  has  doubled.  Safety  requirements  from  older  EU  legislation  now 
coexist  with  new  product  requirements  intended  to  regulate  the  green  and  digital 
transitions. Additionally, new EU legislation with reporting requirements relating to the 
sustainability of business and production processes has been adopted.

30 

 
ANNEX I – PROCEDURAL INFORMATION 

Lead DG, Decide reference and, if relevant, work programme reference 

DG for Internal Market, Industry, Entrepreneurship and SMEs 

Agenda planning/Work programme reference: PLAN/2023/2666 

Organisation and timing 

Work  started  in  June  2024.  The  Call  for  Evidence  and  the  public  consultation  were 
published on 7 November 202452. An Interservice Steering Group (ISSG) chaired by DG 
for Internal Market, Industry, Entrepreneurship and SMEs was established to this purpose. 
The ISSG met twice (2 October 2024 and 13 May 2025) and was consulted in writing on 
all the draft documents (reports, questionnaires, etc.).  

Use of external expertise 

The Centre for Strategy & Evaluation Services (CSES) carried out a supporting study.53 

52  https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14131-Lift-safety-Evaluation-of-

the-Lifts-Directive_en 

53 

https://op.europa.eu/en/publication-detail/-/publication/8fcd4f57-b865-11f0-b37f-

01aa75ed71a1/language-en  

31 

 
 
 
 
 
ANNEX II  – METHODOLOGY AND ANALYTICAL MODELS USED 

The evaluation builds on the supporting study carried out by an external contractor. The 
study employed a combination of different approaches to gather data and information from 
stakeholders as explained below. 

Desk research 

The desk research conducted focused on three strands: 

•  A  desk-based  analysis  of  the  Directive  and  other  relevant  EU  pieces  of 
legislation  to  assess  their  objectives,  rationale  and  scope,  review  their 
implementation in each EU MS, and compare the main approaches and differences. 
•  An analysis of statistical data on the lift market to collect information required for 
an  analysis  of  the  sector,  its  features  and  trends,  and  information  on  lift-related 
accidents. Market data were retrieved from Eurostat and UN Comtrade, while the 
accident data came from the European Lifts Association. The analysis also covered 
market  surveillance  data  retrieved  from  Commission  databases,  such  as  Safety 
Gate. 

•  A review of the available literature on the lift sector, mainly white papers, reviews 

and articles from industry covering the evaluation period. 

Consultations 

The table below provides an overview of the stakeholder consultations. 

Data 
collection 
methods 

Interviews 

Description 

The  original  interview  programme  planned  for  40  interviews  with 
stakeholders  in  the  sector.  In  the  end,  55  interviews  were  conducted 
with  73  stakeholders  across  various  groups,  including  Commission 
officials, national notifying authorities and national market surveillance 
authorities  (largely  members  of  the  Lifts  Expert  Group),  industry 
from  various  countries, 
associations  and  economic  operators 
representatives  of  the  CEN/TC 10  standardisation  committee  and 
representatives of civil society organisations. 

The  aim  of  these  interviews  was  to:  (i)  investigate  in  detail  specific 
issues raised by stakeholders or identified through other data sources; 
(ii) gain a clearer understanding of stakeholders’ experience with the 
Directive and the implication of any emerging issues for the relevance 
of the Lifts Directive; (iii) complement other research tools, particularly 
in cases where data were limited (e.g. on costs). 

32 

 
 
Description 

Data 
collection 
methods 

It  was  difficult  to  engage  with  stakeholders,  in  particular  SMEs 
(including  maintenance  companies)  and  some  national  authorities, 
which caused delays in the overall study timeline. 

The  Lifts  Expert  Group  meeting  held  in  February  2025  was  used  to 
validate some of the findings and collect additional information. 

Public 
consultation 

The  public  consultation  ran  from  7 November  2024  to  13 February 
2025 and received 47 responses, although not all respondents answered 
every question. 

The  largest  group  of  respondents  by  type  were  EU  citizens  (29 
responses), followed by non-governmental organisations (6 responses). 
Economic  operators  were  encouraged  to  respond  to  the  targeted 
consultation, which was more technical and detailed. 

The 47 responses were received from 13 EU Member States and two 
non-EU countries, Türkiye and the United Kingdom.  With 12,  Spain 
had the largest number of respondents, followed by Lithuania with 6. 

The  aim  of  the  public  consultation  was  primarily  to  investigate 
perceptions of lift safety accessibility and maintenance in the EU.  

The targeted consultation consisted of an online survey, which received 
112 responses. The largest group was composed of economic operators 
(including  manufacturers,  installers  and  maintenance  companies), 
followed  by  conformity  assessment  bodies,  national  authorities  and 
industry associations. As respondents were allowed to select more than 
one  stakeholder  category,  the  number  of  recorded  stakeholder  types 
was higher (142). 

In  terms  of  SME  representativeness,  9  of  the  34  economic  operators 
were small companies and 6 were medium-sized companies, giving a 
total of 15 SMEs. 

In  terms  of  geographic  coverage,  17  respondents  stated  that  they 
operated  across  the  entire  EU,  while  13  indicated  that  they  operated 
globally. Germany was the most represented country (10 respondents), 
followed by Italy (6 respondents). Respondents from non-EU countries 
were based in Switzerland, Türkiye, Serbia, Tunisia and the UK. 

The targeted survey covered all evaluation criteria and topics. Its aim 
was  to  collect  technical  feedback  and  views  from  stakeholders  who 
were  very  familiar  with  the  Directive  and  its  performance  over  the 
evaluation period.  

Another  consultation  targeted  building  owners  and  managers.  The 
objective  was  to  collect  opinions  and  information  on  challenges  and 

33 

Targeted 
consultation 
– sector 
survey  

Targeted 
consultation 
– building 

 
Description 

Data 
collection 
methods 

managers / 
owners 

issues relating  to  lift  maintenance and operation, and  supplement the 
information provided by other stakeholder groups. 

Despite  efforts  to  secure  support  from  national  and  international 
associations of facility managers, only 4 responses were received.  

A summary of the feedback collected through the various consultation activities is included 
in Annex V. 

34 

 
 
 
ANNEX III – EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

• EQ1 - How has the 

European lift market 
evolved since the adoption 
of the Directive in 2014? 
• What is the current situation 

and what are the main 
trends in the European and 
global lift markets? 

• The extent to which the market 
has evolved since the 2019 
evaluation in terms of market 
size and structure, integration 
of digital technologies etc. 

• Market analysis of the lift sector, 
including key trends since 2019 
(e.g. types of lift, market 
structure, manufacturer size, 
sales, production costs, and the 
competitiveness of EU 
companies) 

• Desk and field research to 
identify key technological 
developments with an impact on 
the lift market 

The European lift market 

Quantitative indicators 

Desk research 

•  Total market size, value and 
composition (in terms of 
number and size of 
companies) compared with 
2019 

•  Trends in intra-EU trade in 
lifts and safety components, 
in volume and value, and 
comparison with 2019 data 

•  Comparison of 

competitiveness indicators 
across the EU and major 
trading partners 

Qualitative indicators 

•  Presence of new 

technological developments 
affecting the market since 
2019 and their perceived 
effects on economic 
operators and consumers 
Relevance 

•  Eurostat databases (e.g. 
Prodcom, Structural 
business statistics (SBS) 
and R&D expenditure) 
International databases 
(e.g. UN Comtrade, 
OECD databases); 
•  Publications by EU 

• 

industry associations, 
trade unions and 
consumer associations 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry, SMEs 
and consumers 

• EQ2 – To what extent did 
the initial objective of 
facilitating the functioning 
of the internal market 

• The extent to which the 

Quantitative indicators 

Desk research 

• Desk and field research to analyse 

Directive remains relevant in 
guaranteeing a well-
functioning internal market, 

•  Number of products and/or 
safety components for lifts 
currently outside of the scope 

•  EU policy and 

legislative documents 

•  TRIS database 

market trends and identify 
additional regulations in the 
sector 

35 

 
 
 
 
Question 
correspond to the needs and 
concerns of all 
stakeholders? How far does 
it still do so? 

Judgement criteria 
ensuring the free movement of 
lifts and their safety 
components and avoiding trade 
barriers arising from divergent 
regulations 

• EQ3 - To what extent did the 
initial  objective  of  ensuring 
a high level of safety for lifts 
correspond to the needs and 
concerns of all stakeholders? 
it 
To  what  degree  does 
in 
remain 
needs 
addressing 
today? 

relevant 
these 

• The extent to which the 
Directive still contains 
appropriate provisions to 
ensure a high level of safety 
for users, installers and 
maintenance personnel 

Indicators 

of the Directive that have 
high market potential (e.g. in 
terms of market value) 
•  Number of notifications in 

the Technical Regulation 
Information System (TRIS) 
database 

Qualitative indicators 

•  Degree of alignment between 

stakeholders’ needs and the 
Directive’s objectives, by 
stakeholder group 

•  Relevance of products and/or 
safety components for lifts 
currently outside the scope of 
the Directive, as perceived by 
stakeholders 

•  Presence of new regulatory 
elements that may hamper 
trade in lifts and their 
components 

Quantitative indicators 

•  Number of safety 

components for lifts currently 
outside the scope of the 
Directive 

•  Number of cases of safety 

issues related to lifts reported 
in the EU since 2019 
•  Number and deaths and 

injuries caused by lifts (a 
proxy for assessing the 
impact of the Lifts Directive 
on accidents and injuries over 

36 

Sources of evidence 
•  Publications by EU 

industry associations, 
trade unions and 
consumer associations 

Field research 

Assessment methods 

• Qualitative assessment of the 

‘relevance’ criterion 

• Descriptive statistical analysis 
• Contextual multi-stakeholder 

analysis of perceptions 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers and 
relevant national 
authorities 

Desk research 

•  EU policy and 

legislative documents 

•  Publications by EU 

industry associations, 
trade unions and 
consumer associations 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 

• Desk and field research identify 
and analyse possible safety risks 
linked to lifts, with a focus on 
components within the scope of 
the Directive 

• Qualitative assessment of the 

relevance criterion 

• Comparative assessment of the 

safety requirements of the 
Directive against new emerging 
safety issues reported by 
stakeholders 

• Descriptive statistical analysis 

 
 
 
Sources of evidence 
relevant national 
authorities and 
conformity assessment 
bodies 

Assessment methods 

• Contextual multi-stakeholder 

analysis of perceptions 

Question 

Judgement criteria 

Indicators 

time). 
Qualitative indicators 

•  Evidence of factors 

contributing to accidents 
since the Directive came into 
force, linked to risks covered 
and not covered by the 
Directive 

•  Degree of alignment between 

stakeholders’ needs and the 
Directive’s objectives by 
stakeholder group 

•  Stakeholders’ perceptions of 

the relevance of the 
Directive’s safety 
requirement   in the light of 
current needs and emerging 
issues, including in particular 
any gaps in the list of safety 
components requiring 
conformity assessment 
•  Stakeholders’ perceptions of 
general lift safety in the EU 

Quantitative indicators 

Desk research 

•  Emerging safety issues, 

•  European Patent Office 

• EQ4 - How have innovation 
and new technologies been 
taken into account? 

The extent to which the 
Directive remains relevant to 
new trends in safety and market 
related to: 
• digitalisation 
• cybersecurity 
• other technological 

developments and the 
scientific state-of-the-art. 

database 

•  Relevant CEN/TC 10 

documents 

• Desk and field research to provide 

an analysis of evidence of 
technological developments 
related to lifts and their coverage 
in the Directive 

•  Publications by EU 

• Qualitative assessment of the 

industry associations, 
trade unions and 
consumer associations 

‘relevance’ criterion 

• Contextual multi-stakeholder 

analysis of perceptions 

Field research 

•  Public consultation 
•  Targeted consultations 

related to digitalisation and 
other technological 
developments not covered by 
the Directive, as reported by 
stakeholders 

•  Number of revisions to 

existing European safety 
standards 

•  Trends in patents registered 

in the lift sector 

37 

 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

with representatives 
from industry, SMEs 
and consumers 

•  Number of patents that could 
be linked to the Directive 
(number of patents for safety 
components, from 2019 to 
today) 
Qualitative indicators 

•  Presence of digital and 

technological developments 
that have impacted the lifts 
market, and assessment of 
whether these have been 
accommodated in the 
Directive 

•  Gaps in the provisions and 

requirements of the Directive 
in relation to digital and 
technological developments 
•  Stakeholders’ perceptions of 

the relevance of the 
Directive’s provisions in 
addressing digitalisation, 
technological developments 
and related aspects (e.g. 
product instructions, 
logbooks) 

• EQ5 - Are there any 

• The extent to which the 

Qualitative indicators 

Desk research 

outstanding issues relating 
to the clarity of the 
Directive and its internal 
coherence?  

Directive’s provisions are clear 
to all stakeholders 

•  The clarity of provisions and 
the consistent application of 
the Directive in all Member 
States. 

•  Level of clarity and 
understanding of the 
Directive’s provisions and 
requirements reported by 
stakeholders, by category 

Qualitative indicators 

•  Level of clarity and 

understanding of the scope of 
the Directive, as reported by 

•  Publications by EU 

industry associations, 
trade unions and 
consumer associations 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 

• Desk and field research to 

identify and analyse gaps or lack 
of clarity in the scope, provisions, 
requirements of the Directive 
• Qualitative assessment of the 

‘relevance’ criterion 

• Contextual multi-stakeholder 

analysis of perceptions 

38 

 
Question 

Judgement criteria 
• The extent to which the 

Directive has been able to 
accommodate new 
developments and the 
modernisation of lift practices 

• The extent to which the 

Directive provides all relevant 
definitions  

Indicators 

stakeholders, by stakeholder 
category 

•  Evidence of differences in 

how the relevant 
requirements of the Directive 
are applied across Member 
States 
Qualitative indicators 

•  Presence of gaps or lack of 
clarity in the definitions 
provided by the Directive, as 
reported by stakeholders 
Effectiveness 

Assessment methods 

Sources of evidence 
from industry and 
SMEs, consumers, 
relevant national 
authorities and 
conformity assessment 
bodies 

• EQ6 - What progress has 

• The progress made towards the 

been made towards 
achieving the general and 
specific objectives?  

general objectives 

• The progress made towards the 

specific objectives 

Progress towards general objectives 
Progress towards specific objectives 

Interview feedback 
Targeted consultation 

• Qualitative assessment of the 

‘effectiveness’ criterion 

• EQ7 - What discrepancies 
are there between Member 
States in the implementation 
of the Lifts Directive? 

• EQ8 - Have there been any 

problems with the 
implementation of the 
Directive? 

• The absence of problems in the 

Quantitative indicators 

Desk research 

implementation of the 
Directive 

• The absence of discrepancies in 

the implementation of the 
Directive across Member States 

•  Trends in the lift market 

before and after the adoption 
of the Directive 
•  Number of provisions 

implemented differently by 
different Member States  

Qualitative indicators 

•  Problems and obstacles in the 

implementation of the 
Directive, as reported by 
stakeholders 

•  Evidence of discrepancies in 
national transposition and 
implementing legislation  

•  Eurostat databases (e.g. 
Prodcom, SBS and 
R&D expenditure) 
•  Publications by EU 

industry associations, 
trade unions and 
consumer associations 
•  National transposition 

legislation 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 
relevant national 
authorities 

39 

• Market analysis of the lifts sector, 
including key trends since 2019 to 
identify possible trends linked to 
a discontinuous or divergent 
implementation of the Directive 

• Legal analysis of transposition 

documents 

• Qualitative assessment of the 

‘effectiveness’ criterion 

• Contextual multi-stakeholder 

analysis of perceptions 

 
 
Question 
• EQ9 - How effective has the 
development and use of the 
harmonised European 
standards been for the Lifts 
Directive? 

Judgement criteria 
• The extent to which the use of 

harmonised standards has 
supported the implementation 
of the Directive 

Indicators 

Sources of evidence 

Assessment methods 

• Assessment of the number and 

coverage of European standards 
relevant to the implementation of 
the Directive 

• Qualitative assessment of the 

‘effectiveness’ criterion 

• Contextual multi-stakeholder 

analysis of perceptions 

Quantitative indicators 

Desk research 

•  Relevant publications 
and deliverables by 
European 
standardisation 
organisations (ESOs) 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 
relevant national 
authorities 

•  Number of harmonised 

European standards (hENs) 
relevant to the Directive 
•  Number of revisions to hENs 

since 2019 

•  Number of formal objections 
to the content of hENs since 
2019 
Qualitative indicators 

•  Degree of alignment of hENs 

with technological 
developments relevant to the 
Directive 

•  Extent to which hENs are 

used as a reference guide for 
ensuring compliance with the 
Directive in the EU 

•  Stakeholders’ perceptions of 

the effectiveness and 
importance of hENs in the 
implementation of the 
Directive 

• The absence of problems in the 
implementation of conformity 
assessment procedures 

• EQ10 - To what extent has 
the conformity assessment 
procedure for lifts and 
safety components for lifts 
been effective and provided 
the highest degree of health 
and safety for consumers 
and users? 

Quantitative indicators 

Desk research 

•  Number of cases of product 
non-compliance in the sector 

Qualitative indicators 

•  Number and type of 

problems reported by notified 
bodies in applying 
conformity assessment 
procedures for lifts and safety 
components 

•  Evidence of difficulties 

related to the acceptance of 

•  Data provided by 

• 

notified bodies and 
other authorities 
ICSMS and Safety 
Gate (previously 
RAPEX) data 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 

• Assessment of the number of 

cases of product non- in the lift 
sector and the reasons for these 

• Qualitative assessment of the 

‘effectiveness’ criterion 

• Contextual multi-stakeholder 

analysis of perceptions 

40 

 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

• EQ11 - How effective are 

• The effectiveness of current 

Quantitative indicators 

Desk research 

certificates by Member State 
authorities 

•  Stakeholders’ perceptions of 

SMEs, notified bodies 
and market 
surveillance authorities 

the effectiveness and 
appropriateness of 
conformity assessment 
procedures 

market surveillance 
authorities in identifying 
non-compliant lifts and 
safety components for lifts? 

market surveillance 
mechanisms in ensuring that 
products placed on the market 
comply with safety standards 

•  Data provided by 

market surveillance 
authorities 
ICSMS and SafetyGate 
data 

• 

•  CASP (coordinated 

activities on the safety 
of products) data 

Field research 

•  Targeted consultations 
with representatives 
from industry and 
SMEs, notified bodies 
and market 
surveillance authorities 

•  Number of cases of product 
non-compliance in the sector 

•  Number of checks and 

inspections carried out by  
market surveillance 
authorities 

•  Percentage of checks that 
have identified non-
conformities or produced 
results inconsistent with the 
conformity assessment 
procedure 

Qualitative indicators 

•  Evidence of differences 

between Member States in 
terms of the level of priority 
given to market surveillance 
in the sector 

•  Stakeholders’ perceptions of 
the effectiveness of the work 
of market surveillance 
authorities 

• EQ12 - To what extent has 

• The proper functioning of the 

Quantitative indicators 

Desk research 

the Lifts Directive 
contributed to a well-
functioning internal market 
for products covered by it? 

internal market for lifts 

• The clarity and 

appropriateness of the 
Directive in ensuring a level 

•  Market size of the sector 
(production, intra-EU and 
extra-EU trade, etc.) and 
trends since the adoption of 

•  Market data (EQ1) 
•  Publications and other 
information sources 
from industry 

41 

 
 
 
 
Judgement criteria 
playing field for companies in 
the EU 

Question 
• EQ13 - To what extent does 
the Directive ensure legal 
certainty, transparency and 
non-discrimination between 
companies? 

• EQ14 - To what extent has 
the Lifts Directive achieved 
its aims regarding the 
protection of the health and 
safety of users and 
maintenance personnel? 

Indicators 

Sources of evidence 

Assessment methods 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers and 
relevant national 
authorities 

the Directive 
Qualitative indicators 

•  Stakeholders’ perceptions of 
the extent to which the 
Directive has facilitated the 
free movement of lifts and 
safety components and 
reduced implementation 
differences across Member 
States 

•  Evidence and stakeholders’ 

perceptions of the creation of 
a level playing field for 
companies in the EU 
•  Evidence and stakeholders’ 

perceptions of any lack of 
relevant information or 
guidance to ensure the 
effective implementation of 
the Directive 

• The Directive’s contribution to 
simplifying and harmonising 
legislation and conformity 
assessment procedures in the 
EU 

Quantitative indicators 

Desk research 

•  Number of hENs relevant to 

the Directive 
Qualitative indicators 

•  Number and type of issues 
reported by stakeholders 
regarding the procedures laid 
down in the Directive and its 
provisions 

•  Evidence and stakeholders’ 
perceptions of the benefits 
provided by the conformity 
assessment procedure 

•  ESOs data (EQ8) 
•  Data on conformity 

assessment (EQ9) 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 
notified bodies and 
relevant national 
authorities 

• The Directive’s contribution to  Quantitative indicators 

Desk research 

42 

 
 
 
 
 
Question 

Judgement criteria 
preventing non-compliant 
products from being placed on 
the market 

Indicators 
•  Number of cases of non-

compliant products reported 
in the sector 

Qualitative indicators 

Sources of evidence 
•  Data on conformity 

assessment (EQ9) and 
market surveillance 
(EQ10) 

•  Stakeholders’ perceptions of 

Field research 

Assessment methods 

the benefits brought by the 
Directive in preventing non-
compliant products from 
being placed on the market 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 
notified bodies and 
market surveillance 
authorities  

• The extent to which the 

Quantitative indicators 

Desk research 

Directive has improved lift 
safety and whether its essential 
requirements exhaustively 
cover existing lift-related risks 

•  Trends in accidents and 

injuries in the sector (latest 
year available) 

•  Number of cases of non-

compliant products reported 
in the sector 

•  Data on market 

surveillance (EQ10) 
•  ELA accident statistics 
•  Other secondary 

sources on accidents 
and health and safety 

•  Number of lifts/safety 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, 
notified bodies and 
market surveillance 
authorities 

components recalled or 
withdrawn from the market 
due to safety issues (latest 
available data) 
Qualitative indicators 

•  Stakeholders’ perceptions of 

the benefits brought by the 
Directive in improving health 
and safety in the sector 
•  Stakeholders’ perceptions of 
the adequacy of the essential 
health and safety 
requirements (EHSR), and 
any issues related to their 

43 

 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

• The presence of any 

Qualitative indicators 

Desk research 

capacity to prevent risks 

unintended (positive or 
negative) consequences of the 
Directive 

• EQ15 - What are the 

barriers to the effective 
application and 
enforcement, particularly 
through surveillance of lifts 
on the market? 

• The presence of  obstacles to 
the full implementation of the 
Directive  

•  Evidence of any unintended 
(positive or negative) effects 
of the implementation of the 
Directive on the market 
•  Stakeholders’ perceptions of 

the presence of unintended 
effects stemming from the 
adoption of the Directive  

•  Publications from 

industry, consumers 
and other stakeholders 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

Quantitative indicators 

Desk research 

•  Market surveillance 

data 
Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

•  Number of cases of non-

compliance reported in the 
EU 
Qualitative indicators 

•  Evidence of barriers to the 
implementation and 
enforcement of the Directive 
in the Member States, in 
particular regarding the 
capacity of market 
surveillance authorities and 
the effect on enforcement 

•  Existence of barriers to the 
effective application and 
enforcement, as reported by 
stakeholders 

•  Existence of provisions to 
discourage negative 
behaviours related to the 
implementation of the 
Directive  

44 

 
 
 
Question 
• EQ16 - What factors have a 
positive or negative impact 
on  the effective application 
of the Directive? 

Judgement criteria 
• The presence of external 
factors facilitating the 
implementation of the 
Directive 

• The presence of external 

factors negatively affecting the 
implementation of the 
Directive 

• EQ17 - What are the 
regulatory (including 
administrative) costs for 
different stakeholders? 

• Regulatory costs generated by 
the Directive for economic 
operators 

• Regulatory costs generated by 

the Directive for market 
surveillance authorities 

• Regulatory costs generated by 

the Directive for notified 
bodies 

• Regulatory costs generated by 

the Directive for other 
categories of stakeholders 

Indicators 

Sources of evidence 

Assessment methods 

Field research 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

Qualitative indicators 

•  Evidence of factors 

positively or negatively 
affecting the implementation 
of the Directive 

•  Existence of mechanisms for 
cooperation, coordination 
and exchange of information 
at national level 

•  Other factors reported by 

stakeholders as positively or 
negatively affecting the 
implementation of the 
Directive 

Efficiency 

Quantitative indicators 

Desk research 

•  Estimated average regulatory 

•  Data produced by 

stakeholders on the 
implementation of the 
Directive and data 
from the previous 
evaluation 

Field research 

•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

costs per stakeholder 
category 

•  Estimate administrative 
burden generated by the 
Directive per stakeholder 
category 

•  Estimated enforcement costs 
for market surveillance 
authorities 
Influence of these costs on 
installation and maintenance 
prices (impact on users) 

• 

Qualitative indicators 

•  Existence of regulatory costs 
reported by each stakeholder 
category 

•  Stakeholders’ perceptions of 
any increases or decreases in 

45 

• Mapping and quantification of the 
administrative requirements for 
economic operators 
(manufacturers, installers and 
importers), where possible by lift 
type and safety component 
category; 

• Mapping and estimation of 
compliance costs (technical 
adaptations, adaptation to 
standards, testing etc.), by lift 
type, safety component category 
and stakeholder group; 

• Mapping and quantification of 
enforcement costs for market 
surveillance authorities; 

• Qualitative assessment of the 

‘efficiency’ criterion 

 
 
Question 

Judgement criteria 

Indicators 
the regulatory costs 
generated by the Directive 
since its adoption, by type 

• Evidence of unnecessary 

Qualitative indicators 

regulatory costs 

•  Evidence reported by 

Sources of evidence 

Assessment methods 

• EQ18 - What are the main 
benefits for stakeholders 
and civil society resulting 
from the Directive? 

• Benefits produced by the 
Directive for different 
categories of stakeholders 

stakeholders that certain 
costs could be reduced or 
procedures simplified 

Quantitative indicators 

Desk research 

•  Estimated benefits quantified 
by stakeholders in terms of 
market efficiency 

•  Estimated benefits quantified 
by stakeholders in terms of 
improved safety 

Qualitative indicators 

•  Existence of additional 

benefits reported by each 
stakeholder category 

•  Stakeholders’ perceptions of 
any changes in costs and 
benefits brought by the 
Directive since its adoption, 
by stakeholder type 

•  Data on market size 

and trends 

•  Data on the safety of 

lifts 
Field research 

•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

• Mapping and, where possible, 

quantification of benefits 
provided by the Directive for 
different categories of 
stakeholders. 

• Monetisation of benefits, where 

possible 

• Qualitative assessment of the 

‘efficiency’ criterion 

• EQ19 - To what extent are 

• The proportionality of costs 

Quantitative indicators 

Desk research 

the regulatory costs 
proportionate to the benefits 
achieved? How affordable 
are the costs for 
stakeholders, given the 
benefits they receive? What 
does this represent in terms 
of administrative and 
reporting burdens? 

incurred under the Directive to 
the benefits achieved 

•  Estimated comparison of 

•  Data on costs and 

costs and benefits 

Qualitative indicators 

benefits (EQ16 and 17) 

Field research 

• Stakeholders’ perception of 
costs as affordable overall, 
with the administrative burden 
considered not excessive 

•  Stakeholders’ perceptions of 
the extent to which benefits 
outweigh the costs  

Qualitative indicators 

•  Stakeholders’ perceptions of 
the  affordability of costs 
•  Stakeholders’ perceptions of 

•  Public consultation 
•  Targeted consultations 
with representatives 
from industry and 
SMEs, consumers, and 
relevant national 
authorities 

• Comparison between the costs 
and benefits generated by the 
Directive (quantitative where 
possible) 

• Qualitative comparison between 
the costs and the effectiveness of 
the Directive 

46 

 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

• Qualitative assessment based on 
desk research and analysis of 
relevant legislation 

• Contextual multi-stakeholder 

analysis of how any 
inconsistencies identified 
influence market behaviour  

Desk research 
• Relevant EU legislation and 

application guides (Machinery 
Regulation, Cyber Resilience 
Act, European Accessibility 
Act, Energy Efficiency 
Directive, etc.) 

• Guide to application of the 
Lifts Directive 2014/33/EU 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 
associations, consumers and 
relevant national authorities 

• EQ20 - External coherence: 
Are there any overlaps or 
complementarities between 
the Lifts Directive and other 
EU Member State 
legislation in the relevant 
areas (in particular the 
Cableways and Machinery 
Directives)? To what extent 
are they coherent? Are there 
additional requirements at 
EU and national level for 
certain products? Are there 
contradictions? 

Sub-questions: 
a.  To what extent has the 
alignment of the Lifts 
Directive with the NLF 
helped to strengthen 
consistency and coherence 
with other applicable EU 
legislation? 

b.  How far has the most 

recent revision of the Lifts 
Directive in 2014 helped 
to eliminate any 
inconsistencies, overlaps 
and gaps in Union 
harmonisation legislation? 
Is the product scope for 
the Lifts Directive 

c. 

• Consistency of the Directive 
with both EU and national 
legislation without overlap or 
contradictions resulting from 
changes to existing legislation 
or the adoption of new 
legislation 

• Complementarity and 

coherence of the Directive 
with the accessibility 
requirements of the European 
Accessibility Act 

• Alignment of the Directive 

with the Cyber Resilience Act 

• Absence of issues of 
complementarity and 
coherence with the Machinery 
Directive and the new 
Machinery Regulation in terms 
of product scope and 
requirements 

• The Directive’s consistency 
and complementarity with 
existing legislation on worker 
safety, avoiding the risk of 
duplicate inspections 
• The extent to which the 

alignment of the Directive with 
the NLF has helped strengthen 
consistency and coherence 
with EU legislation 

the proportionality of the 
administrative burden 

Coherence 

• Number of provisions of the Lifts 
Directive not aligned with other 
relevant EU and national 
legislation adopted since 2019 

• Number of overlaps or 

contradictions between the Lifts 
Directive and other relevant EU 
and national legislation adopted 
since 2019 

Qualitative indicators 
• Evidence of potential risks of 

complementarity and duplication 
between the Directive and other 
legislation (e.g. unclear delineation 
of product scope, dual 
applicability, etc.), as reported 
since 2019 

• Level of alignment of objectives 
and requirements between the 
Directive and other legislation 

• Level of complementarity between 

the scope, objectives and 
requirements of the Directive and 
those of other legislation  

47 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

appropriate? For instance, 
is the delineation clear 
between the Lifts 
Directive and the 
Machinery Directive? Is 
there sufficient clarity on: 
(1) the speed of lifts and 
how this affects which 
Directive is applicable 
and (2) vehicle lifts? 
d.  To what extent does the 
emphasis placed by the 
newly adopted Machinery 
Regulation to 
digitalisation ( e.g. 
product risks from AI, the 
internet of things, robotics 
and autonomous decision-
making through 
automation technologies) 
require alignment of that 
Regulation with the Lifts 
Directive? 

e.  How coherent is the Lifts 
Directive with the new 
digitalisation and 
cybersecurity legislation 
relevant to lifts , such the 
Cyber Resilience Act 
(CRA)? 

f.  How coherent is the Lifts 

Directive with the 
Accessibility Directive 
(2019/882/EU) in 
improving accessibility 
for people with 

48 

 
Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

Question 

disabilities? 

g.  Has the updated Energy 
Efficiency Directive had 
any implications for the 
coherence of the Lifts 
Directive in terms of 
energy efficiency and 
sustainability (including 
repairability, recycling, 
circularity)? 

h.  How coherent is the Lifts 
Directive with well-
established legislation 
such as the Construction 
Products Regulation, the 
Electromagnetic 
Compatibility Directive  
and the Low Voltage 
Directive? 

i.  How coherent is the Lifts 

Directive with 
occupational safety 
legislation on to ensure 
that there are no duplicate 
inspections while lifts are 
in service? 

• EQ21 – Internal coherence 

• The absence of conflicting or 

Are there any internal 
inconsistencies within the 
Lifts Directive? For 
example, are there any 
inconsistent provisions 
within the articles or 
annexes?* 

contradictory provisions, 
requirements or other elements 
in the Directive 

• Clarity and consistency of all 
the Directive’s requirements, 
leaving no scope for differing 
interpretations 

Qualitative indicators 
• Evidence of possible risks of 

complementarity and duplication 
within the legal text of the 
Directive 

• Perceived clarity and consistency 

of the Directive’s requirements and 
provisions , by stakeholder type 

Sub-questions: 

Desk research 
• Legal text of the Directive  
• Guide to application of the 
Lifts Directive 2014/33/EU 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 

• Qualitative assessment based on 
desk research and analysis of the 
legal text of the Directive 
• Contextual multi-stakeholder 

analysis of how any 
inconsistencies identified 
influence market behaviour  

49 

 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 
associations, consumers and 
relevant national authorities 

Assessment methods 

a.  How far do stakeholders 
perceive that there is 
clarity and consistency in 
the requirements for 
economic operators, 
including producers, 
importers, distributors, 
installers and operators? 

b.  To what extent is the 

Directive consistent with 
‘digital by default’ 
(cybersecurity) 
principles? 

c.  To what extent is the Lifts 
Directive coherent with 
the digital rulebook, given 
that it does not yet address 
digitalisation in areas such 
as risk assessment (see 
question about the 
Machinery Regulation 
below) and remote 
inspections to check 
compliance of lifts that 
are in service? 

d.  Are there examples of 

inconsistent use of, or the 
absence of definitions for, 
terminology used in the 
manufacturing and putting 
into service of lifts, for 
example ‘safety 
circuit(s)’? 
• EQ22 - Are the 

requirements for installers 
and manufacturers clear? 

• The clarity of the Directive’s 
scope and requirements for 
manufacturers and installers, 

Qualitative indicators 
• Perceived clarity and consistency 

of the Directive’s requirements and 

Desk research 
• Guide to application of the 
Lifts Directive 2014/33/EU 

• Contextual multi-stakeholder 

analysis of how any 
inconsistencies identified 

50 

 
Question 
Are there any overlapping 
rules? 

Judgement criteria 
with all relevant definitions 
provided 

Indicators 
provisions, by stakeholder type 

Sources of evidence 

Assessment methods 
influence market behaviour 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 
associations of installers and 
manufacturers 

EU Added Value 

51 

 
 
Indicators 

Sources of evidence 

Assessment methods 

Quantitative indicators 
• Market trends in the Lifts sector 

Desk research 
• Eurostat data on market size 

• Qualitative assessment of EU 

added value based on 
consultations 

and trends 

• Other secondary sources (e.g. 

• Quantitative assessment of 

estimated cost savings 

• Contextual multi-stakeholder 

analysis of perceptions 

OECD databases, UN 
Comtrade) 

• Publications and other 
resources produced by 
industry organisations 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 
associations, consumers and 
relevant national authorities 

Judgement criteria 
• The Directive’s contribution to 
creating common rules across 
Europe and thereby 
establishing a well-functioning 
internal market and increasing 
intra-EU trade 

• The Directive’s contribution to 

harmonising and aligning 
former or existing national 
legislation relating to the lift 
sector 

• The Directive’s contribution to 
increasing the competitiveness 
and innovativeness of EU 
economic operators 

Question 

• EQ23. What additional 
value does the Lifts 
Directive bring, compared 
with what could be 
achieved at national level? 

Sub-questions: 
a.  Do the needs and 

challenges addressed by 
the Directive continue to 
require harmonisation 
action at EU level? 
b.  Would national action or 
the absence of EU action 
significantly affect the 
level playing field? 
c.  Has the Lifts Directive 

tackled any significant or 
appreciable transnational 
or cross-border aspects? 
Could these be 
quantified? 

d.  Have there been any clear 
benefits from action at EU 
level? Have there been 
economies of scale and 
service-sharing? Have the 
objectives been achieved 
more efficiently at EU 
level than they would 
have been by Member 
States acting individually 
(larger benefits per unit 
cost)? 

since the adoption of the Directive 
(market size, trade, industry 
competitiveness) 

• Trend in the number of non-

compliant products identified by 
market surveillance authorities 
• Trends in the number of accidents 
and injuries since the adoption of 
the Directive 

• Estimated costs saved by 

complying with a harmonised EU 
regime instead of several national 
regimes 

• Estimated benefit of harmonisation 
where national regulations might 
otherwise diverge for the same 
product 

Qualitative indicators 
• Stakeholders’ perceptions of the 
benefits of common legislation 

• Stakeholders’ perceptions of 

whether similar benefits could be 
achieved through national action 
alone 

• EQ24 - What is the added 
value of the Lifts Directive 

• The extent to which the 
Directive has increased 

Quantitative indicators 
• Market trends in the lift sector 

Desk research 
• Eurostat data on market size 

• Qualitative assessment of EU 

added value based on 

52 

 
 
 
 
 
Judgement criteria 

benefits for users and 
maintenance personnel through 
harmonised safety 
requirements 

Question 
for stakeholders? 

Sub-questions: 
a.  Would national action, or 
the absence of EU action, 
significantly affect the 
level playing field? 
b.  Has the Lifts Directive 

tackled any significant or 
appreciable transnational 
or cross-border aspects ? 
Could these be 
quantified? 

c.  What added value has the 
Directive created for 
SMEs? 

• The Directive’s contribution to 
strengthening the position of 
EU SMEs in the EU and global 
markets 

Indicators 
since the adoption of the Directive 
(market size, trade, industry 
competitiveness) 

• Estimated costs saved by 

complying with a harmonised EU 
regime instead of several national 
regimes 

• Estimated benefit of the 

harmonisation where national 
regulations might otherwise 
diverge for the same product 

Qualitative indicators 
• Stakeholders’ perceptions of the 
benefits of common legislation 

• Stakeholders’ perceptions of 

whether similar benefits could be 
achieved through national action 
alone 

Quantitative indicators 
• Market share of SMEs 

Qualitative indicators 
• SMEs’ perceptions of the benefits 

of common legislation and of 
improvements in their 
competitiveness at EU and global 
level 

• EQ25* – What value has 

• The extent to which the EU 

Quantitative indicators 

53 

Sources of evidence 

Assessment methods 

and trends 

consultations 

• Other secondary sources (e.g. 

• Quantitative assessment of 

estimated cost savings 

• Contextual multi-stakeholder 

analysis of perceptions 

OECD databases, UN 
Comtrade) 

• Publications and other 
resources produced by 
industry organisations 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 
associations, consumers and 
relevant national authorities 

Desk research 
• Eurostat data on market size 

and trends 

• Qualitative assessment of EU 

added value based on 
consultations 

• Other secondary sources (e.g. 

• Contextual multi-stakeholder 

OECD databases, UN 
Comtrade) 

• Publications and other 
resources produced by 
industry organisations 

Field research 
• Public consultation 
• Targeted survey of economic 

operators and industry 
associations 
Desk research 

analysis of perceptions 

• Qualitative assessment of EU 

 
 
 
 
 
 
 
 
 
Question 
the Brussels effect of the 
Directive created? 

Judgement criteria 
provides a regulatory model 
for other countries in the sector 

Indicators 

• Market share of EU companies 

globally 

Sources of evidence 
• Eurostat data on market size 

and trends 

Assessment methods 

added value based on 
consultations 

• Number of countries where 

• ESO data on the global uptake 

• Contextual multi-stakeholder 

CEN/TC 10 standards are accepted 

of CEN/TC 10 standards 

analysis of perceptions 

Qualitative indicators 
• Stakeholders’ perceptions of how 
the Directive has benefited their 
competitiveness in the global 
market 

• Stakeholders’ perceptions of the 
uptake of the same quality and 
safety standards by international 
companies 

• EQ26* - What would be the 
most likely consequences of 
ending EU intervention? 

• The extent to which repeal of 

• Budget allocated to market 

the Directive would negatively 
affect stakeholders, worsening 
their position compared with 
the current situation 

surveillance (including costs of 
enforcement activities). 

• Difference in enforcement costs 

between EU and national 
approaches. 

• Time-series trends analysis of 

internal market trade and exports 

Qualitative indicators 
• Stakeholders’ perceptions of how 
they would be affected by a repeal 
of the Directive 

• Other secondary sources (e.g. 

OECD databases, UN 
Comtrade) 

• Publications and other 
resources produced by 
industry organisations 

Field research 
• Targeted survey of economic 

operators and industry 
associations 
Field research 
• Public consultation 
• Targeted survey of economic 

• Qualitative assessment of EU 

added value based on 
consultations 

operators and industry 
associations 

• Contextual multi-stakeholder 

analysis of perceptions 

54 

 
 
 
 
 
 
ANNEX IV – OVERVIEW OF COSTS AND BENEFITS 

The following tables offer an overview of the costs and benefits compared to the situation that preceded the 2008 legislative package, and of the potential 
burden reduction. Source: Annex IV of the evaluation of the NLF – https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12654-
Industrial-products-evaluation-of-the-new-legislative-framework_en 

Overview of costs and benefits identified in the evaluation of the NLF 

Citizens/Consumers 

Businesses 

Administrations 

[Other] 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Overview of costs and benefits identified in the evaluation 

Enforcement costs 

Resources spent 
by EU bodies to 
ensure NLF 
implementation 

Resources spent 
by national 
authorities to 
ensure NLF 
implementation 

Resources spent 
by economic 
operators during 
conformity 
assessment 
procedures 

Resources spent 
by economic 
operators to 
develop 
standards 

Recurrent 

n/a 

n/a 

n/a 

n/a 

0 

Resources spent by 
the Commission’s 
relevant units in 
relation to NLF 
implementation are 
considered to be 
business-as-usual 
costs. 

EUR 270 000
-360 000  

Incremental cost of EA 

Recurrent 

n/a 

n/a 

n/a 

n/a 

Recurrent 

n/a 

n/a 

Recurrent 

n/a 

n/a 

0 

0 

Since the principles of 
conformity assessment 
have not changed with 
the 2008 introduction of 
the NLF, no additional 
costs have been 
identified. 
The cost of developing 
standards within the 
ESOs was approximately 
EUR 3 000 million in 
2009. The approximate 
cost of creating one 

55 

Not 
quantifiable 

Resources spent by 
notifying authorities 
in relation to NLF 
implementation. 

Not 
quantifiable 

Resources spent by 
accreditation bodies in 
relation to NLF 
implementation (importantly, 
however, this cost is borne 
largely by conformity 
assessment bodies (CABs) 
through the purchase of 
accreditation services). 

n/a 

n/a 

n/a 

n/a 

0 

The approximate 
cost of creating one 
standard was 
estimated at 
approximately 
EUR 1 million. 

n/a 

n/a 

 
 
Citizens/Consumers 

Businesses 

Administrations 

[Other] 

Overview of costs and benefits identified in the evaluation 

Quantitative 

Comment 

Quantitative 

Cost of CE 
marking 

Recurrent 

n/a 

n/a 

0 

Comment 
standard was estimated 
at approximately EUR 1 
million. This cost is 
financed primarily by 
industry (93-95%). Since 
no changes related to 
standards were 
introduced with the 2008 
NLF, no additional costs 
have been identified 
compared to the previous 
scenario. 

Since no changes related 
to CE marking were 
introduced with the 2008 
NLF, no additional costs 
have been identified 
compared to the previous 
scenario. 

Quantitative 

Comment 

Quantitative 

Comment 
Around 3-5% of this 
cost is financed by 
national 
governments and 
around 2% by the 
Commission/EFTA. 
Since no changes 
related to standards 
were introduced 
with the 2008 NLF, 
no additional costs 
have been identified 
compared to the 
previous scenario. 

n/a 

n/a 

n/a 

n/a 

Costs related to 
the accreditation 
framework: 
examination fee 
payable to an 
accreditation 
body 

One-off 
(every time an 
accreditation 
expires) 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Costs related to 
the accreditation 
framework: 
annual fee 
payable to 
accreditation 

Recurrent 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

56 

EUR 4 000-
20 000 per 
accreditation 
(the 
cumulative 
cost borne by 
CABs in 
relation to 
accreditation 
is in the order 
of magnitude 
of hundreds 
of millions of 
euros across 
the EU as a 
whole). 

Different 
practices by 
country (see 
comment). 

In addition to country-
specific differences in fees, 
variations in costs borne by 
CABs also depend on the 
extent of the scope being 
sought, the number of 
locations, the experience and 
involvement of the CAB, the 
maturity of the quality 
management system and its 
processes, and the 
availability of staff. 

Concerning this cost, 
differences between 
accreditation bodies 
emerged. Among those 
bodies who charge a 
maintenance fee, there are 

 
 
 
body 
(continuous 
monitoring costs, 
maintenance fee) 

Costs related to 
the accreditation 
framework: cost 
of developing a 
quality 
management 
system 

Costs related to 
the accreditation 
framework: 
insurance fee 

Reduced costs 
linked to 
becoming 
familiar with the 
legislation 
thanks to the 
introduction of 
common 
definitions 
Cost savings in 
conformity 
assessment 
activities 
Enhanced legal 
certainty 

Citizens/Consumers 

Businesses 

Administrations 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Overview of costs and benefits identified in the evaluation 

Recurrent 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

0 

[Other] 

Comment 
the Italian body (maintenance 
fee calculated as a share of 
turnover) and the Latvian 
body (annual fee of 
EUR 425). In Slovenia, a 
maintenance fee is charged at 
each surveillance visit (either 
every 12 or 15 months). 
Established CABs typically 
already have a quality 
management system with 
established procedures in 
place and already have a 
quality manager dealing with 
it. Given that this cost would 
be incurred in full even in the 
absence of the 2008 NLF, no 
additional costs have been 
identified compared to the 
previous scenario. 

Recurrent 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Not 
quantifiable 

Sector-specific and country-
specific variations. 

Recurrent 

n/a 

n/a 

Recurrent 

n/a 

Recurrent 

n/a 

n/a 

n/a 

Not 
quantifiable 

Not 
quantifiable 

Not 
quantifiable 

Direct benefits 

Savings thanks to 
absence of divergent 
requirements (e.g. 
common suite 
conformity assessment 
modules). 

Not 
quantifiable 

n/a 

n/a 

n/a 

Savings thanks to greater 
coherence between 
directives. 

n/a 

Indirect benefits 

n/a 

n/a 

57 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

 
 
 
Citizens/Consumers 

Businesses 

Administrations 

[Other] 

Overview of costs and benefits identified in the evaluation 

Increased safety, 
health, and 
reduced 
environmental 
damages 

Single market 
benefits 

Quantitative 

Recurrent 

Not 
quantifiable 

Comment 
Benefits deriving 
from the reduction 
in differences in the 
activities carried out 
by the notified 
bodies (thanks to the 
NLF). 

Recurrent 

n/a 

n/a 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

n/a 

n/a 

n/a 

n/a 

n/a 

Order of 
magnitude: 
tens of 
billions of 
euros. 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Greater global 
relevance of EU 
regulations 

Recurrent 

Not 
quantifiable 

Benefit deriving 
from the ability of 
EU legislation to 
elevate its model 
worldwide and 
shape international 
practices (‘Brussels 
effect’). This in turn 
supports the EU's 
global standing in 
global commerce. 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Higher EU 
industrial 
competitiveness 

Recurrent 

n/a 

n/a 

Not 
quantifiable 

Comparative 
competitiveness between 
EU and non-EU 
manufacturers. 

n/a 

n/a 

n/a 

n/a 

58 

 
 
 
 
 
Overview of simplification and burden reduction in the NLF 

Citizens / Consumers 

Businesses 

Administrations 

[Other] 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Simplification and burden reduction (savings already achieved) 

Indirect compliance cost savings 

Reduced costs 
linked to 
becoming 
familiar with the 
legislation 
thanks to the 
introduction of 
common 
definitions 
Cost savings in 
conformity 
assessment 
activities 

Recurrent 

n/a 

n/a 

Not quantifiable 

Recurrent 

n/a 

n/a 

Not quantifiable 

Savings thanks to absence of 
divergent requirements (e.g. 
common suite conformity 
assessment modules). 

Savings thanks to greater 
coherence between 
directives. 

Not quantifiable 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Potential simplification and burden reduction (savings not yet achieved) 
Further potential simplification and savings that could be achieved with a view to making the initiative more effective and efficient without undermining its policy objectives. 

Citizens/Consumers 

Businesses 

Administrations 

[Other] 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Comment 

Possibility of increasing efficiency through the introduction of an e-labelling scheme 

Recurrent 

n/a 

n/a 

EUR 490 
million per 
year 

A general consensus was found among 
interviewees on the possibility of 
increasing efficiency through the 
introduction of e-labelling 

n/a 

n/a 

n/a 

Recurrent 

Recurrent 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

Possibility of accreditation by accreditation body of a different MS 

Not 
quantifiable 

Recurrent 

n/a 

n/a 

Not 
quantifiable 

Strong indications that CABs could 
achieve cost savings and other positive 
impacts through the use of remote 
assessment techniques. 

Not 
quantifiable 

Remote assessment 

Strong indications that NABs 
could achieve cost savings and 
positive environmental and 
efficiency impacts through the 
use of remote assessment 

Not 
quantifiable 

59 

Efficiency could be increased if 
it were possible to be accredited 
by the accreditation body of a 
different Member State (since 
one national accreditation body 
(NAB) might be slower and 
more costly than another) 

Strong indications that EA could 
achieve cost savings and other 
positive impacts through the use 
of remote techniques in the peer 
evaluation process. However, 

 
 
 
 
Potential simplification and burden reduction (savings not yet achieved) 
Further potential simplification and savings that could be achieved with a view to making the initiative more effective and efficient without undermining its policy objectives. 

Citizens/Consumers 

Businesses 

Quantitative 

Comment 

Quantitative 

Comment 

Quantitative 

Potential additional costs related to 
developing/becoming familiar with new 
standards on remote techniques. 

Administrations 

Comment 
techniques. However, given the 
nature of NABs, the cost 
savings should be passed on to 
CABs. 
Potential additional costs 
related to developing/becoming 
familiar with new 
guidance/standards on remote 
techniques. 

Quantitative 

Comment 

[Other] 

there will be additional costs 
(borne by EA and ESOs) 
associated with developing 
guidance and standards related 
to remote assessment 
techniques. 

60 

 
 
 
ANNEX V – STAKEHOLDER CONSULTATIONS - SYNOPSIS REPORT 

Annex V presents an overview of all stakeholder consultations conducted as part of the 
evaluation supporting the study of Directive 2014/33/EU – the Lifts Directive54. 

The objective of the stakeholder consultations was to gather evidence and collect insights 
from  all  relevant  stakeholders  that  would  inform  the  findings  and  conclusions  of  the 
evaluation of the Lifts Directive. 

The stakeholder consultation strategy was designed and delivered in accordance with the 
Better Regulation Guidelines and the research framework, including the evaluation matrix 
presented in Annex III to this staff working document. 

Consultation activities and methodology 

A multi-faceted approach was implemented, comprising the following methods: 

•  Call for Evidence. On 7 November 2024, the Call for Evidence was published on the 
Have Your Say portal. Stakeholders had until 13 February 2025 to provide feedback. 
22 contributions were received. 

•  Open public consultation. The consultation targeting non-professionals was open on 
the Have Your Say portal from 7 November 2024 to 13 February 2025. 47 responses 
were received. 

•  Semi-structured interviews. The external contractor carried out the interviews from 
August 2024 until April 2025. In total, interviews were conducted with 73 stakeholders, 
covering all relevant stakeholder groups. 

•  Online surveys. Two online surveys were conducted, targeting professionals working 

in the sector (survey #1) and building owners and managers (survey #2). 

Survey #1 was launched on 11 November 2024 and ran up to 12 February 2025 because 
so few responses had been received (the closing date of the open public consultation 
was 13 February). The survey was disseminated by the European Commission as well 
as  by  industry  associations  (ELA),  notified  bodies  for  lifts  and  the  Administrative 
Cooperation Group for Lifts (AdCo Lifts). A total of 97 complete and 15 partial (but 
usable)  responses  were  received.  An  additional  63  responses  were  recorded  in  the 
system but deemed unusable as they responded to too few questions. 

Survey 2 was launched on 11 November 2024 and ran up to 12 February 2025 because 
so few responses had been received (the closing date of the open public consultation 
was  13  February).  Support  was  sought  from  the  international  association  of  facility 
managers  (and  related  national  members),  but  only  4  complete  responses  were 
recorded. An additional 21 responses were recorded in the system but deemed unusable 
as they responded to too few questions. 

•  Consultation  of  the  Commission’s  Expert  Group  on  Lifts.  The  evaluation  team 

54 

https://op.europa.eu/en/publication-detail/-/publication/8fcd4f57-b865-11f0-b37f-

01aa75ed71a1/language-en  

 
 
 
presented  some  preliminary  evaluation  findings  to  the  Expert  Group  on  Lifts  on 
25 February  2025.  The  aim  was  to  elicit  feedback  on  the  main  findings  and  find 
consensus on the key issues. 

Results of the consultation activities 

Call for Evidence 

Between 7 November 2024 and 13 February 2025, the European Commission received 22 
contributions  in  response  to  the  Call  for  Evidence,  including  7  position  papers.  These 
contributions  were  submitted  by  various  stakeholders,  including  business  associations, 
NGOs and EU citizens. Key thematic areas of discussion revolved around technological 
advancements, regulatory scope, safety components and the need for clearer guidelines. 

Contributors from notified bodies and industry associations highlighted the need to update 
the Directive to address cybersecurity threats and the implications of AI used in lifts. There 
is a push for robust cyber safety and AI requirements grounded in other relevant regulations 
such as Regulation (EU) 2023/1230. 

Several civil society organisations highlighted inadequacies in terms of accessibility for 
people  with  disabilities,  particularly  deaf,  hard  of  hearing,  and  deafblind  people.  They 
emphasised the need for legislation with binding accessibility requirements supported by 
detailed standards to ensure that all lifts serving the public are designed according to the 
universal design principle and that better consideration is given to the interface with the 
building. The organisations agree that revisions of the Directive and the EN 81-70 standard 
are  necessary  to  close  the  existing  accessibility  gaps  and  better  align  with  the  UN 
Convention on the Rights of Persons with Disabilities (CRPD). 

Several  stakeholders,  including  a  notified  body,  noted  the  lack  of  clear  criteria 
distinguishing ‘new lifts’ from ‘modernisation of existing lifts’. This ambiguity impedes 
proper compliance and could be clarified by integrating existing interpretative guidelines 
directly into the Directive. 

Stakeholders  recommended  expanding  the  list  of  safety  components  to  include  modern 
technological  devices  like  AI  safety  components  and  car  door  locking  mechanisms. 
Definitions within the Directive require adjustments to ensure that they are clear and up to 
date. 

One contributor argued that all safety circuits on printed circuit boards (PCBs), regardless 
of whether they contain semiconductor components, should be EU-type examined, because 
they  are  critical  for  lift  safety.  Two  contributors  pointed  out  that  changes  in  means  of 
suspension, for example belts, are not adequately reflected in the Lifts Directive. 

EU  citizens  and  organisations  expressed  the  need  to  align  the  Lifts  Directive  with 
environmental and economic sustainability frameworks like the Ecodesign for Sustainable 
Products Regulation and the Right to Repair Directive. 

Multiple stakeholders, including a notified body, advocated for integrating the non-binding 
interpretative guidelines of the ‘Guide to Application of the Lifts Directive 2014/33/EU’ 

62 

 
 
directly  into  the  Directive  to  ensure  consistency  and  reduce  confusion  among 
manufacturers and notified bodies. 

A  property  owners’  network  emphasised  the  importance  of  ensuring  interoperability  in 
control systems and the availability of spare parts to extend the life of lifts and to prevent 
obsolescence and market lock-in. 

The  notified  bodies  asked  that  definitions  for  the  terms  ‘lift  installation  company’, 
‘installer’, ‘licensee’ and ‘safety manager’ be added. 

An organisation representing workers emphasised the need for better physical access to 
lifts  and  machine  rooms  as  well  as  appropriate  and  clearly  indicated  protective  spaces, 
especially for lifts without a machine room. 

An  association  representing  public  and  private  residential  companies  warned  that  any 
change to the Directive would result in significant costs for all stakeholders to adapt to the 
new rules. 

Open public consultation (online) 

A total of 47 responses were received from 13 EU Member States and 2 non-EU countries, 
namely  the  United  Kingdom  and  Türkiye,  with  responses  predominantly  from  Spain, 
Lithuania and Greece. The largest respondent group comprised EU citizens, followed by 
company/business representatives comprising micro and small organisations. Although the 
consultation  was  promoted  via  LinkedIn  and  DG  GROW’s  social  media  channels,  the 
response rate remained low, reflecting the niche nature of the topic. 

Most  respondents  reported  using  lifts  daily,  primarily  at  the  workplace,  at  home  or  in 
shopping  areas.  When  queried  about  safety  perceptions,  many  felt  either  very  safe  or 
somewhat safe in lifts. The main concerns raised were lift entrapment, free fall, lack of 
emergency  assistance,  power  outages  and  mislevelling.  Additionally,  31  respondents 
reported issues  with  lifts in  the past  decade, spanning  safety-compromising  defects  and 
inconveniences like jerky movements or unusual noises. Use of emergency communication 
was reported as functional by most respondents who had needed it. 

Lifts in  private residential buildings were perceived as less safe than those in  public or 
commercial buildings. Recent lifts (less than 20 years old) were seen as safer compared to 
those over 30 years old. Respondents did not generally observe significant differences in 
lift safety when visiting other EU countries. 

Accessibility  provisions  varied,  with  private  residential  buildings  reported  as  less 
accessible. Respondents  suggested improvements for access  by people with  disabilities, 
including  features  like  Braille  instructions  and  voice  messages.  Lifts  were  seen  as 
sometimes,  rarely,  or  never  accessible  for  people  with  reduced  mobility  or  impaired 
hearing or vision. 

Out of 15 building owners, 10 reported experiencing lift safety issues over the past 5 years, 
with common problems like unusual noises or mislevelling. Obstacles in obtaining spare 

63 

 
 
 
parts were also noted. Inspection and maintenance frequency varied, and the administrative 
burden  in  managing  lifts  was  mostly  deemed  low  to  medium.  Rare  instances  of  non-
compliance  were  related  to  outdated  equipment  and  improper  safety  signage,  with 
rectification  costs  ranging  from  EUR 250  to  EUR 3 000.  Only  3  respondents  had 
modernised their lift in the last 5 years, with associated costs varying widely. 

Suggestions  for  the  Directive  included  creating  comprehensive  databases  for  lift 
documentation  to  enhance  safety  and  integrating  mandatory  upgrades  to  current  safety 
standards. There was also a call for clear guidelines on cabin temperature and dimensions 
in specific cases like historic buildings. 

Interviews 

A total of 73 stakeholders were interviewed for the evaluation support study. The below 
table breaks this down by stakeholder group: 

Table 1: Number of consulted stakeholders per group 

(including 

representatives 

Stakeholder groups 
EU institutions 
Trade  and  business 
economic operators) 
Conformity assessment bodies 
National  authorities  (including  both  notifying  and  market 
surveillance authorities) 
Representatives of standardisation technical committees 
Representatives of civil society organisations  
Total 

individual 

Target  Completed 
7 
3 

13 

5 

15 

1 
3 
40 

21 

9 

28 

4 
4 
73 

Given the extensive number of interviews conducted, the below text represents a high-level 
summary of the results. 

Effectiveness 

Representatives  of  businesses  do  not  consider  that  there  are  any  particular  issues, 
especially given that the Directive has become a well-known and well-established piece of 
legislation  for  all  stakeholders  in  the  sector.  The  Directive  provides  a  good  point  of 
reference for the sector and helps establish predictability and a level playing field for all 
economic operators in the EU. 

However,  there  are  still  some  discrepancies  across  Member  States,  both  because  the 
Directive  allows  national  authorities  to  regulate  some  areas  (e.g.  prior  approval),  and 
because in  some Member States  there are  additional  national  requirements or rules that 
might modify the overall landscape. For instance, different rules on inspections by notified 
bodies or accessibility requirements can de facto create different market conditions across 
countries. 

64 

 
 
 
 
Harmonised European standards have become an important part of the implementation of 
the Directive. The presence of standards has allowed companies to rely on the presumption 
of  conformity,  thus  reducing  the  costs  for  some  economic  operators  linked  to  the 
conformity assessment process. However, the standardisation process remains quite slow, 
making it hard to keep up with the pace of such developments. 

Representatives of notifying authorities did not identify any shortcomings or issues with 
the  application  of  the  Directive.  They  agreed  overall  on  the  success  of  the  Directive  in 
providing  a  clear,  established  framework  for  the  safety  and  free  movement  of  lifts  and 
safety components in the EU. 

Two authorities mentioned the accreditation of notified bodies, which might lead to issues 
of quality with the work performed by some of them. This could create an uneven playing 
field between notified bodies, and lead to notified bodies using accreditation bodies in a 
different country from the one they operate in. Where there are problems, it is very difficult 
for authorities to trace them back and verify compliance and quality. 

Representatives  of  market  surveillance  authorities  generally  agreed  that  market 
surveillance  for  lifts  and  safety  components  in  the  EU  has  become  rather  reactive. 
Authorities, in particular due to limited capacity and lack of specialised and knowledgeable 
staff, rely heavily on notified bodies to signal any risks or cases of non-compliance before 
the  product  is  made  operational.  Some  countries  do  have  a  lift  register  which  can  be 
beneficial  for  market  surveillance;  however,  the  time  and  effort  required,  as  well  as  its 
limited usability in the past, has made some countries decide to discontinue it. This also 
limits the ability of the authorities to track (new) lifts over their lifetime. 

According to representatives of conformity assessment bodies, the Directive is a good 
piece of legislation, which, in combination with the applicable standards, helps to provide 
legal certainly for economic operators and other stakeholders in the sector. The Directive 
does not present significant limitations or shortcomings, even if there are factors that could 
limit its clarity. Representatives of notified bodies indicated that approaches might vary 
across  countries,  including  as  regards  the  requirements  and  accreditation  process  for 
notified bodies. A few representatives of notified bodies suggested that the absence of a 
more  homogeneous  approach  is  also  due  to  the  fact  that  notifying  authorities  lack 
coordination. 

Representatives  of  standardisation  technical  committees  underlined  that  the  EU  has 
indeed become a standard-setter at international level in this field. They pointed out that 
the standards developed  by the EU have been used as the basis for globally recognised 
specifications,  with  several  non-EU  countries  looking  at  the  EU’s  quality  and  safety 
standards to develop their own. Innovation and developments are typically driven by large 
companies, which have time and resources, while SMEs are more likely to be present in 
niche sectors and focused on more tailored solutions. 

65 

 
 
 
 
Efficiency 

Representatives of businesses agreed that the burden linked to the Directive’s obligations 
is not significant. What they experience, in terms of types of costs, is justified by the type 
of services required and received to prove the safety of the products before they enter the 
market. A few economic operators confirmed that costs have been increasing, but these 
cannot be linked to the Directive; rather, they relate to energy and labour costs, increased 
fees charged by notified bodies and inflation in general. 

Representatives  of  notifying  and  market  surveillance  authorities  confirmed  that  the 
burden linked to the Directive is appropriate and not at all perceived as high. On the one 
hand,  most  of  the  costs  and  efforts  linked  to  the  Directive  would  have  been  sustained 
anyway, given the information they need to collect and procedures they need to follow and 
monitor to ensure the safety of new installations. On the other hand, they are heavily reliant 
on notified bodies to identify possible cases of non-compliance, which means that they can 
limit their involvement to those cases where an issue has already been identified. This helps 
the authorities to cope with their general lack of resources, especially considering that each 
authority is responsible for multiple products, not only lifts. 

Representatives of conformity assessment bodies noted a general increase in the costs of 
accreditation over time. However, this cost cannot be directly attributed to the Directive. 
Similarly, other costs such as labour, training and energy have increased (and have been 
reflected  in  increased  testing  costs  for  economic  operators)  but  are  not  linked  to  the 
Directive and its provisions. 

Coherence 

All categories of stakeholders agreed that the Directive’s objectives and provisions align 
well with EU priorities and the other pieces of legislation. Representatives of businesses 
raised a question regarding the interplay of the Directive with new legislation, such as the 
AI  Act  and  the  new  Machinery  Regulation.  Representatives  of  small  and  medium 
enterprises, furthermore, indicated how the combined effects of these pieces of legislation 
risked creating a burden and leading to confusion. 

Relevance 

All stakeholders agreed that the Directive’s core objectives and activities remain highly 
relevant at both national and EU level. 

Representatives of conformity assessment bodies indicated that the fact that the Directive 
is  quite  old  is  reflected  in  the  list  of  safety  components  (Annex  III),  which  should  be 
updated. The testing of these components, moreover, would not be possible on-site, as this 
would lead to the risk of breaking them and leaving the lift out of order.  

Representatives of businesses, notifying authorities and conformity assessment bodies 
agree about the importance of the Guide to Application of the Lifts Directive in clarifying 
aspects or provisions of the Directive. 

66 

 
 
 
EU added value 

Representatives  of  notifying  and  market  surveillance  authorities  emphasised  the 
significant added value that the Directive brings to Member States, as it lays down some 
minimum requirements for all countries, providing a useful basis for additional national 
legislation (if necessary) and ensuring a common understanding of rules and requirements 
across the EU. 

Representatives of businesses agree that the Directive has provided added value compared 
to what would have been possible without EU intervention. In particular, the presence of 
clear  requirements  for  installers,  together  with  the  possibility  of  different  conformity 
assessment options, creates a market where they can operate with enough certainty. 

Targeted stakeholder surveys – survey of professionals in the sector 

For the survey targeting professionals in the sector (survey #1), responses were received 
from 112 stakeholders. As multiple selections were allowed, the total number of responses 
was 161, as indicated in the table below: 

Table 2: Distribution of respondents to the targeted survey by stakeholder group 

Stakeholder groups 
Economic operators – Installers/Manufacturers 
Public authorities (including Market Surveillance Authorities) 
Conformity assessment bodies 
Economic operators – Maintenance companies (incl. repairers) 
Industry associations, business networks 
Organisations representing lift users/consumers 
Economic operators – Construction/building companies 
Authorised representatives of manufacturers 
Economic operators – Installers/Manufacturers 

# 
41 
36 
28 
25 
16 
7 
1 
1 
5 

% 
25.5% 
22.4% 
17.4% 
16.1% 
9.9% 
4.3% 
0.6% 
0.6% 
3.1% 

Economic  operators  and  conformity  assessment  bodies  were  asked  to  state  where  they 
operate (a maximum of 3 countries). Out of 102 respondents, in 16.7% of cases (n=17) 
respondents  selected  ‘EU  wide’  and  in  another  12.7%  (n=13)  of  cases  they  selected 
‘Global’.  The  most  represented  individual  countries  were  Germany  (9.8%,  n=10),  Italy 
(5.6%, n=6), Switzerland, Malta and Belgium (each with 5 responses, 4.9% of the total). 

A  total  of  34  economic  operators  indicated  the  size  of  their  business:  19  respondents 
(55.6%)  indicated  a  size  of  over  250  employees,  6  respondents  (17.6%)  belonged  to 
companies with 10-49 employees, 6 (17.6%) to companies with 50-249 employees and 3 
(8.9%) to companies with less than 10 employees. 

A total of 31 public authorities indicated the country they represent: 7 responses came from 
Germany, 5 from Lithuania, 2 from each of Belgium, Ireland, Slovenia and Switzerland, 

67 

 
 
 
 
and 1 from  each of Croatia, Czechia, Denmark, Finland, Greece, Iceland, Luxembourg, 
Poland, Portugal, Slovakia and Sweden. 

Effectiveness 

Lift safety in the EU 

Lifts  in  the  EU  are  generally  considered  safe:  to  a  large  extent  by  61%  (68/112)  of 
respondents,  to  some  extent  by  22.3%  (25/112)  of  respondents,  and  safe  only  in  some 
countries  (and  less  safe  in  others)  by  16%  (18/112)  of  respondents.  Only  1  respondent 
indicated  that  they  were  not  safe.  The  majority  of  stakeholders  also  agreed  that 
improvements in lift safety had been made in the past 10 years: significant improvement 
for 40.2% of respondents (45/112) and some improvement for 36.6% (41/112). In 16.1% 
of cases (18/112) respondents identified no changes and only 2 indicated a worsening of 
conditions. 

Regulatory  standards  and  technological  advancements  are  seen  as  the  main  factors 
contributing to improving the safety of lifts, as displayed in the figure below. The adoption 
of  Commission  Recommendation  95/216/EC  was  seen  as  contributing  significantly  to 
improving the safety of existing lifts in the EU countries which have adopted upgrading 
measures. 

Figure 1: Main factors improving lift safety in the past 10 years (n=112) 

According  to  37.5%  (42/112)  of  respondents,  there  are  also  factors  that  contributed  to 
reducing lift safety, to some extent. In the open-ended comments, the factors mentioned 
included the increased complexity of installations, the presence of ‘closed systems’ which 
are not easy to access for maintenance or repairs, the lack of testing options for specific 
safety functions, and the shortage of skilled personnel for inspections and maintenance. 

Functioning of the single market 

Stakeholders were asked to indicate to what extent the single market functions well for lifts 
and  safety  components.  On  a  scale  from  1  (not  at  all)  to  5  (to  a  strong  extent),  47.3% 
(53/112) responded 5 and 38.4% (43/112) responded 4. 

When  asked  if  they  ever  experienced  any  issues  when  importing  parts  and  safety 
components  into  the  EU  from  non-EU  countries,  34.9%  (30/112)  said  yes.  Most  of  the 

68 

 
 
 
 
additional  responses  provided  to  further  explain  the  problem  indicated  the  presence  of 
missing/inadequate technical documents or counterfeit certificates. 

Implementation of the Directive 

Regarding the implementation of the Directive, 56.4% (62/110) of respondents indicated 
no  change  in  the  past  5  years,  while  another  34.5%  (38/110)  indicated  either  some  or 
significant  improvements.  Improvements  were  mainly  linked  to  improvements  in  the 
Guide to Application of the Lifts Directive. 

As  shown  in  the  figure  below,  the  majority  of  respondents  (when  able  to  provide  a 
response) indicated that the Directive contributed positively to improving the situation in 
the single market. 

Figure 2: Contribution of the Directive in improving or worsening the situation in the EU (n=86) 

Stakeholders were also asked to indicate whether there are any major shortcomings linked 
to the implementation of the Directive. As shown in the figure below, the main limitations 
identified  related  to  an  uneven  enforcement  of  market  surveillance  and  the  challenges 
stemming from the lack of a definition of ‘substantial modification’ for a lift. 

69 

 
 
 
Figure 3: Extent to which there are shortcomings in the implementation of the Directive (n=112) 

European standards 

Stakeholders responding to the survey indicated that lift-related European standards are 
technology-neutral to a strong extent (44.2%, 38/86) or some extent (25.6%, 22/86). They 
also  represent  state-of-the-art  specifications  to  a  strong  extent  (39.5%,  34/86)  or  some 
extent (37.2%, 32/86). However, it should also be noted that technology moves faster than 
regulation, and subjects such as AI and cybersecurity are missing from current standards. 

Respondents to the survey agree that the EU can be considered a leading standard-setter at 
global  level,  either  to  some  extent  (36%,  31/86)  or  to  a  strong  extent  (50%,  43/86). 
European standards have influenced international standards according to 64% (55/86) of 
respondents, with another 15% (13/86) indicating that the influence was mutual. 

Stakeholders were asked to indicate to what extent, in their experience, European standards 
were contributing to the development of the lift sector, as shown in the figure below. 

70 

 
 
 
Figure 4: Extent to which EN standards are deemed to contribute to the lift sector in the EU 

The presence of harmonised European standards has been a factor  in helping economic 
operators to export lifts outside the EU according to 53.1% (17/32) of respondents. 25% 
(8/32) replied that they don’t know. 

Market surveillance 

Market surveillance is considered either partially (30.3%, 33/109) or completely effective 
(33.9%, 37/109) by the majority of stakeholders who responded to the survey. For 10.1% 
(11/109)  of  respondents  it  is  rather  ineffective,  while  14.7%  (12/109)  of  respondents 
consider that it varies across Member States. While 35.8% (39/109) of stakeholders replied 
that they don’t know, 37.6% (41/109) of respondents consider that market surveillance has 
improved in the past 5 years. 

Stakeholders  were  asked  to  identify  and  rank  the  main  drivers  of  change  in  market 
surveillance.  They  are  displayed  in  the  figure  below.  Common  provisions  across 
authorities and strengthened coordination were indicated as the most important factors to 
drive any change. 

Figure 5: Drivers of change in market surveillance, ranked 1-5 (n=72) 

71 

 
 
 
 
 
Accessibility of tools and systems 

Stakeholders were asked about how easy it is to access tools, systems and spare parts for 
maintenance purposes and in emergency situations. As shown in the figure below, access 
is generally provided, with a few exceptions especially regarding operating systems, tools 
and spare parts. 

Figure 6: Degree of accessibility of specific items for emergency situations, rescues and maintenance work (n=107) 

Accessibility for people with disabilities 

When  asked  about  the  accessibility  of  lifts  for  people  with  disabilities,  stakeholders 
indicated that they are accessible some or most of the time, as depicted in the figure below. 

Figure 7: Extent to which lifts are safely usable for people with different disabilities (n=100) 

According to 46.3% (31/67) of stakeholders, the current national and EU provisions on the 
accessibility of (public) buildings are comprehensive enough to ensure the safe use of lifts, 
while 23.9% (16/67) think that this aspect should be better regulated at EU level. Standard 
EN 81-7055 was specifically mentioned as providing the necessary specifications to ensure 

55  Cited  standard  EN 81-70:2021+A1:2022:  Safety  rules  for  the  construction  and  installation  of  lifts  – 
Particular applications for passenger and goods passenger lift – Part 70: Accessibility to lifts for persons 
including persons with disability. 

72 

 
 
 
 
 
accessibility of lifts. However, in their replies to open-ended questions, a few stakeholders 
indicated  that  this  standard,  which  is  voluntary,  is  often  not  applied,  thus  limiting  its 
effectiveness. 

Relevance 
Most stakeholders responded that the Directive remains (strongly or somewhat) relevant 
to the needs of stakeholders in the sector, as shown in the figure below. 

Figure 8: Extent to which the Directive remains relevant to current needs (n=110)  

The scope of the Directive is still deemed relevant, in terms of both the definition of lifts 
as  machines  travelling  faster  than  0.15 m/s  (75.7%,  81/107)  and  the  list  of  safety 
components in Annex III (60.4%, 61/106). This also takes into consideration those who 
replied that they don't know. 

When asked about the main aspects that could affect the relevance of the Directive, sector 
professionals indicated in particular the rules on building interfaces, modernisation and re-
manufacturing of lifts, and on new technologies such as cybersecurity and AI, which are 
topics not explicitly addressed by the Directive (see figure below). 

73 

 
 
 
Figure 9: Extent to which these elements limit the Directive’s relevance (n=101) 

All  the  main  aspects  of  the  Directive  (i.e.  essential  health  and  safety  requirements, 
conformity  assessment  modules,  roles  and  obligations  of  stakeholders)  were  deemed 
flexible enough to respond to new technologies and digitalisation-related developments. In 
particular,  essential  requirements  were  deemed  very  flexible  (by  70.3%  (26/35)  of 
respondents),  as  were  conformity  assessment  modules  (73%,  27/37)  and  roles  and 
obligations of stakeholders (67.6%, 25/37). 

Stakeholders  were  asked  to  indicate  the  conformity  assessment  modules  they  use  the 
most within the scope of the Directive. Module B – EU-type examination (24/35), Module 
G – Conformity based on unit verification (21/35) and Module H1 – Conformity based on 
full quality assurance plus design examination (20/35) are those reported to be used the 
most to assess compliance of lifts. Module B – EU-type examination is the one most used 
for conformity assessments of safety components (26/31). 

Overall, 26.6% (28/104) of respondents find that there are aspects missing from the current 
set  of  conformity  assessment  modules.  According  to  the  open-ended  responses,  they 
largely relate to the areas of cybersecurity and artificial intelligence. 

74 

 
 
 
Figure 10: Extent to which there are shortcomings, gaps or superfluous modules linked to the Directive (n=108) 

Regarding the provision of prior approval, stakeholders’ views were quite wide-ranging: 
20.2%  (22/109)  of  respondents  indicated  that  national  discretion  on  the  matter  is  very 
positive, 22% (24/109) indicated that it is quite positive, 18.3% (20/109) showed a neutral 
position,  while  32.6%  (32/109)  of  respondents  indicated  that  this  is  somewhat  or  very 
negative. 

Coherence 
Stakeholders  were  asked  to  identify  some  issues  of  internal  coherence  regarding  the 
Directive. In open-ended questions, some stakeholders underlined that, as it does not cover 
the lifecycle of the lift, rules and regulations for important aspects such as lift maintenance 
and periodic inspections are left at the discretion of Member States, creating fragmented 
national regulations with different requirements. 

In terms of external coherence with other pieces of EU legislation, stakeholders did not 
indicate any major issues, as shown in the figure below. 

Figure 11: Extent to which the Lifts Directive is coherent with other pieces of EU legislation (n=100) 

75 

 
 
 
 
Efficiency 
In line with the general views on the Directive’s effectiveness, all stakeholders responding 
to the survey were largely positive regarding the burden linked to  compliance with and 
enforcement of the Directive. In particular, stakeholders indicated that costs have remained 
the same over the past 10 years (43%, 43/100), while 13% (13/100) indicated that they 
increased  slightly  and  16%  (16/100)  said  they  increased  significantly.  When  asked  to 
further explain their response, the few stakeholders that responded indicated the costs for 
examinations and notified bodies’ fees as the main reasons for the increase. 

In general, 76% (19/25) of stakeholders indicated that their workload to comply with the 
Directive is ‘medium’, 8% (2/25) that it is ‘high’ and 4% (1/25) that it is ‘low’ or ‘none’. 
One of the key reasons for which the burden is seen to be on the lower end of the scale 
(and has been reduced over time) is the use of harmonised standards, which give products 
the presumption of conformity, thus making conformity assessment procedures less costly 
and less time-consuming. Becoming familiar with new harmonised standards does produce 
some  costs  for  economic  operators  and  other  stakeholders:  these  include  the  costs  of 
purchasing and translating the standards, training staff and adapting to the new technical 
specifications. 

In  general,  stakeholders  were  often  not  able  to  provide  estimates  to  quantify  the  costs 
related to compliance with and enforcement of the Directive. 

EU added value 
Stakeholders  responded  positively  regarding  the  EU  added  value  of  the  Directive. 
Including  those  who  responded  that  they  don’t  know,  stakeholders  indicated  that  the 
Directive: 

• 

increased the safety of lifts for users, with 91% (91/100) either agreeing or strongly 
agreeing, and for lift operators and maintenance personnel due to alignment with EU 
safety standards (84%, 84/100); 

•  contributed  to  reducing  barriers  to  trade  on  the  single  market  (83%,  83/100)  and  to 

establishing a level playing field for economic operators (72%, 72/100); 

• 

increased the competitiveness of EU companies in the lift sector on both the EU market 
(71%, 71/100) and the global market (64%, 64/100). 

As regards whether similar results could have been achieved solely with national measures, 
without EU intervention, 57% of respondents (57/100) either disagree or strongly disagree 
with that statement. 

Targeted stakeholder surveys – survey of building owners/managers 

For the survey targeting building  owners and managers (survey #2),  responses were 
received from 4 stakeholders only. Given the very limited representativeness of the input 
received, the survey data were not used in the evaluation. 

76 

 
 
 
Of the 4 respondents who completed the survey, 2 were based in Belgium, 1 in Italy and 
1 in Czechia. In 3 cases, respondents said that they manage more than 1 lift. As regards 
the age of the lifts managed, 2 respondents indicated that the average age was around 20-
30 years (with some lifts installed in 2023 and the oldest ones in the 1960s), 1 that the 
average age was 10-20 years, and 1 that the average age was less than 5 years. 

77 

 
 
ANNEX VI – THE LIFTS DIRECTIVE 

The Lifts Directive ensures the safe and efficient operation of lifts in the EU. The essential 
health and safety requirements set out in Annex I apply to lift installations. This section 
is particularly important as it contains the safety requirements for lift design, manufacture 
and installation. Compliance ensures passenger safety, prevents accidents and minimises 
risks,  through  specific  assessment  procedures  (and  modules)  which  are  set  out  in  the 
Directive’s Annexes. 

Moreover,  the  Directive  details  which  types  of  manufacturers,  installers  and  other 
economic operators are responsible for lift safety. Directive 2014/33/EU is a recast of 
the previous directive covering lifts, Directive 95/16/EC. This recast aligned the previous 
Lifts  Directive  to  the  NLF.  The  NLF  harmonised  market  surveillance,  conformity 
assessment and responsibility for product compliance across all the product sectors that are 
covered  by  the  NLF  (approximately  30  sectors)56.  The  Lifts  Directive  has  not  changed 
substantially in the last 30 years, but the market has, especially since 1995 in the areas of 
digitalisation,  the  circular  economy,  globalisation,  accessibility,  EU  approaches  to 
standardisation, market surveillance and customs. 

The Lifts Directive allows lifts and their safety components to be traded freely within 
the EU single market while ensuring greater safety for lift users and maintenance staff. It 
covers lifting appliances that are (or can be) used to transport people and whose speed is 
not greater than 0.15 m/s. All other lifts and lifting devices are covered by the Machinery 
Directive 2006/42/EC (to be replaced by the Machinery Regulation (EU) 2023/1230 on 
20 January 2027) or Regulation (EU) 2016/424 on cableway installations. Moreover, EU 
legislation  does  not  cover  the  maintenance  and  modernisation  of  lifts.  That  is  the 
responsibility of the national authorities in EU countries. However, the Lifts Directive does 
apply to lifts that were substantially modified. 

Some key provisions of the Directive are: 

•  Article 3  on  free  movement,  and  particularly  point  (3)  thereof,  which  sets  out  the 

possibility for Member States to lay down the requirements as they see fit. 

•  Article 5 on essential health and safety requirements (given that essential requirements 
are of paramount importance of to all harmonised product legislation). Article 5 is the 
main point of reference for the EHSRs set out in Annex I (see below). 

•  The articles on economic operators’ obligations, e.g. Article 7 on the obligations of 
installers,  Article 8  on  the  obligations  of  manufacturers,  Article 9  on  authorised 
representatives,  Article 10  on  the  obligations  of  importers  and  Article 11  on  the 
obligations of distributors. 

56  Adopted  in  2008,  the  New  Legislative  Framework  aims  to  improve  the  internal  market  for  goods  and 
strengthen  the  conditions  for placing  a  wide  range of  products  on  the  EU market.  It  is a  package  of 
measures that aim to improve market surveillance and boost the quality of conformity assessments. It 
also clarifies the use of the CE marking and creates a toolbox of measures for use in product legislation 
– https://single-market-economy.ec.europa.eu/single-market/goods/new-legislative-framework_en. 

 
 
 
•  The  articles  on  conformity  assessment  procedures,  namely  Article 15  on 
conformity assessment procedures for safety components for lifts and  Article 16 on 
conformity assessment procedures for lifts. 

The Directive introduced a series of changes compared to the previous EU legislation on 
lifts,  Directive  95/16/EC.  For  instance,  some  definitions  (provided  in  Article 3)  were 
clarified and aligned with the NLF. Article 4 (on making lifts available on the market) and 
Article 5 (on the essential health and safety requirements) consolidated and explicitly set 
out the rules for placing products on the market and the application of EHSRs. Chapter II 
of  the  Directive  was  a  major  expansion,  as  it  formally  laid  out  specific,  distinct  and 
extensive obligations for every actor in the supply chain to ensure better compliance and 
traceability: 

•  Article 8(6) mandates that manufacturers indicate their name, registered trade name 
or trademark, and postal address on the component or its packaging. This was not 
explicitly required in Directive 95/16/EC. 

•  Article 10 introduced a comprehensive list of obligations for importers (a role that 
was not explicitly covered in the previous Directive), including: ensuring that the 
manufacturer has carried out the correct conformity assessment, that the component 
bears  the  CE  marking,  and  that  the  technical  documentation  has  been  provided. 
They must also take immediate corrective action if a component presents a risk. 

•  Similarly, Article 11 introduced obligations  for distributors, which are  explicitly 
required to verify the presence of the CE marking, the necessary documentation, 
and  the  manufacturer/importer  information  before  making  components  available 
on the market. 

The Directive also kept the original obligations of installers and manufacturers, but these 
were  clarified  in  line  with  the  NLF.  In  particular,  the  Directive  served  to  improve 
traceability/labelling, as the manufacturer/installer must ensure the component is marked 
with their name, registered trade name or trademark, and a single postal address. They also 
have to  keep  a register  of non-conforming safety components  and recalls and keep this 
information for 10 years. 

Similarly, the Directive  is  now in  line  with  the NLF  on the role of  market  surveillance 
authorities,  which  were  granted  increased  powers  (e.g.  to  carry  out  on-site  inspections, 
make test  purchases  and impose penalties) and  the possibility  of working  with  customs 
authorities. 

The table below provides an overview of all the key changes introduced by the Directive. 

79 

 
 
 
 
Table 1: Main changes introduced by Directive 2014/33/EU 

Directive 95/16/EC 

Directive 2014/33/EU  Main differences/key changes 

Art. 1 

Art. 1 

Art. 1(4) 

Art. 2 – Definitions 

Art. 2(1) 

Art. 4 – Placing on the 
market/putting into 
service 

Scope clarified and exclusions expanded (explicit 
exclusion of escalators, stage/theatre lifts, lifting 
appliances < 0.15 m/s). 

New NLF terminology added: ‘making available’, 
‘placing on the market’, ‘economic operator’, ‘recall’, 
‘withdrawal’. 

Split treatment for lifts and safety components; clear 
legal definitions of the two actions. 

Art. 3 

Art. 5 – EHSR 

References moved to updated Annex I; language 
aligned with NLF. 

- 

Art. 8 + Annexes 

Art. 7 

Annex VII 

- 

Art. 8(2)-(5) 

Arts. 7-13 – 
Obligations of 
economic operators 

Entirely new chapter. Introduces duties for installers, 
manufacturers, importers and distributors, and sets 
out traceability rules. 

Arts. 14-16 – 
Conformity 
assessment 

Arts. 18-19 – CE 
marking 

Arts. 24-35 – Notified 
bodies: requirements 
and duties 

Art. 36 – 
Coordination of 
notified bodies 

Arts. 37-44 – Market 
surveillance & 
safeguard procedures 

Modules restructured using NLF terminology (EU-
type examination, quality assurance, unit 
verification). 

Aligns CE marking with Regulation (EC) 765/2008; 
defines affixing and notified body identification 
number. 

Overhauls notification process; introduces concept of 
‘notifying authority’ and reliance on accreditation. 
Expands requirements for the designation, 
functioning, and monitoring of notified bodies, 
ensuring a consistently high level of competence and 
accreditation across the EU. 

New: sets up EU-level coordination group for notified 
bodies. 

New framework aligned with Regulation (EC) 
765/2008, detailing clearer, standardised procedures 
for national authorities to follow when conducting 
market surveillance, including a formal EU safeguard 
procedure for consistently dealing with non-
compliant products across all Member States. 

Art. 9-10 

Arts. 45-49 – Final 
provisions 

Transposition, penalties, and addressees updated; 
repeal of 95/16/EC effective 20 April 2016. 

Annex I of the Directive sets out the essential health and safety requirements applicable 
to lifts and their safety components. These requirements have been devised to protect users 

80 

 
 
 
and  workers  conducting  lift  maintenance,  rescue  operations,  repairs  or  inspections,  for 
example. This Annex I is in line with the principles of the ‘new approach’ to legislation. 

The Lifts Directive does not cover the maintenance and modernisation of lifts, which is the 
responsibility  of  the  national  authorities  in  EU  countries.  The  Directive  does,  however, 
require the installer of the lift to ‘design the lift in such a way that maintenance, inspection 
and rescue operations can be carried out safely’. Moreover, the lift installer must provide 
appropriate  instructions  for  maintenance,  inspection,  repair,  periodic  checks  and  rescue 
operations, although the Directive does not regulate the conditions under which they should 
be carried out. 

Essential requirement 2.2 of Annex I adds a prior approval provision for cases where 
Member States take a different approach to cases where there is not enough space above 
or below the lift (which should, according to essential requirement 2.2, prevent the risk of 
crushing when the car is either at the very top or very bottom of the lift shaft by leaving 
some  free  space  beyond  extreme  positions).  This  prior  approval  provision  may  create 
various potential problems if there is not enough space above the lift in existing buildings, 
an issue which could be explored in the evaluation. 

Safety component manufacturers and lift installers are obliged to verify that the product 
complies with the applicable essential requirements (through conformity assessment) and 
affix the CE marking, both on the safety component and on the lift. 

The Lifts Directive provides a range of options for conformity assessment of lifts and 
safety components of lifts, for the design phase, and for the production phase (for safety 
components)  and  the  installation  phase  (for  lifts).  All  of  these  conformity  assessment 
procedures require the involvement of a notified body for lifts, appointed by each Member 
State to assess whether the products comply with the requirements of the Lifts Directive 
and/or whether the companies’ quality management system is compliant. 

The  table  below  provides  an  overview  of  the  conformity  assessment  modules 
(responsibility of the installers) for lifts and safety components. 

Table 2: Overview of conformity assessment modules in the Directive 

Annex  Module  

Applies to 

Core procedure 

Notified body’s role 

Annex 
IV 

EU-type 
examination 
(Module B) 

Safety 
components 
and lifts (at 
design 
stage) 

Manufacturer/installer 
submits a representative 
design sample or technical 
documentation to a NB for 
design conformity check 
against the EHSR in Annex 
I. 

Examines technical design, 
verifies compliance, issues EU-
type examination certificate 
valid for 5 years (renewable). 

Annex 
V 

Conformity 
to type based 
on product 
quality 
assurance 
(Module D) 

Lifts or 
safety 
components 
already 
type-
examined 

Manufacturer/installer takes 
necessary measures to 
ensure installed lift complies 
with EHSRs through EU-
type examination (B) or 
implementation of a 

Carries out the final inspection 
of the lift about to be placed on 
the market in order to check the 
conformity of the lift. 

81 

 
 
 
Annex  Module  

Applies to 

Core procedure 

Notified body’s role 

Safety 
components 

Safety 
components 

Annex 
VI 

Annex 
VII 

Conformity 
to type based 
on product 
quality 
assurance 
(Module E) 

Conformity 
based on full 
quality 
assurance 
(Module H) 

Annex 
VIII 

Unit 
verification 
(Module G) 

Lifts  

Safety 
components 

Lifts 

Lifts 

Lifts 

Annex 
IX 

Annex 
X 

Annex 
XI 

Annex 
XII 

Conformity 
to type with 
random 
checking 
(Module C2) 

Conformity 
to type based 
on product 
quality 
assurance for 
lifts (Module 
E) 

Conformity 
based on full 
QA plus 
design 
examination 
(Module H1) 

Conformity 
to type based 
on product 
quality 
assurance 
(Module D) 

certified quality system 
(H1). 

Manufacturer uses an 
approved quality system for 
final inspection and testing 
of the safety components for 
lifts. 

Manufacturer uses an 
approved quality system for 
the design, manufacture, 
final inspection and testing 
of safety components. 

Each individual lift is 
examined and tested by a 
NB to verify conformity 
with Annex I (one-off 
certification). 

Used after EU-type 
examination (Module B). 
The manufacturer ensures 
that the components 
conform to the approved 
type. 

Installer uses an approved 
product quality system for 
final lift inspection and 
testing. 

Combines Module H (full 
QA) with a design 
examination stage (by NB) 
for technically innovative 
lifts not fully covered by 
harmonised standards. 

Installer operates an 
approved production quality 
system for manufacturing 
and installing the lifts. 

Periodically carries out audits 
to ensure that the manufacturer 
maintains and applies the 
quality system.  

Assesses the manufacturer’s 
quality system to ensure that 
the safety components for lifts 
are designed, manufactured, 
inspected and tested in 
compliance with EHSRs. 

Performs design check, 
construction inspection and 
functional testing on-site and 
examines the technical 
documentation. 

Conducts random checks on the 
manufactured products. 

Assesses the installer’s product 
quality system to ensure that 
the lifts are in conformity with 
the approved type as described 
in the EU-type examination 
certificate or with a lift 
designed and manufactured 
under a full quality system. 

Assesses the installer’s quality 
system and carries out a design 
examination where harmonised 
standards are not fully applied. 

Assesses and audits the 
production quality system to 
ensure that the lifts installed are 
in conformity with the 
approved type (Module B) or 
with a lift designed and 
manufactured under an 
approved quality system 
(Module H1). 

82 

 
 
 
 
 
Harmonised European standards also play a key role, by providing safety component 
manufacturers  and  lift  installers  with  solutions  to  ensure  compliance  and  by  conferring 
presumption  of  conformity  with  the  EU  legislation.  A  number  of  regularly  updated 
European standards (developed by the CEN/TC 10) detail the safety rules for various types 
of lift, and different aspects of lift construction and mechanisms. 

Furthermore, market surveillance is an important part of the NLF. It sets out measures to 
check  that  products  meet  the  requirements  of  the  applicable  legislation  and  that  non-
compliant  products  are  brought  into  compliance  or  withdrawn  from  the  market.  The 
Directive requires Member States to organise and carry out market surveillance activities 
through  market  surveillance  authorities.  One  challenge  that  needs  to  be  taken  into 
consideration is that the European market surveillance system relies primarily on ex post 
compliance checks when a product is placed on the market and put into service. 

83 

 
 
 
ANNEX VII – ANNEXES TO THE MARKET ANALYSIS 

Products falling within the scope of the Directive include lifts – those intended for the transport 
of persons, persons and goods, and goods alone if the carrier is accessible – and their safety 
components  (as  listed  in  Annex  III  of  the  Directive).  The  Directive  does  not  cover  the 
maintenance and modernisation of lifts, although it does apply to lifts that were substantially 
modified. The market analysis looked at the following indicators: 

•  number of firms and employees, 

•  units and value of lifts and safety components sold (production), 

•  number of lifts installed, 

•  overall value and volume of intra/extra-EU imports/exports of lifts and safety components, 

•  competitiveness of trade compared to other exporters. 

A number of sources have been analysed to look for the above-mentioned indicators. Most of 
them follow on from the work that was undertaken in the previous 2019 evaluation study of 
the Lifts Directive. However, some indicators had to be discontinued as the research team was 
unable to recover some data sources, or the sources themselves were not available for the most 
recent period; for example, the indicator providing information on the size of enterprises falling 
within the scope of the Directive could not be used this time around and, for the analysis of the 
number  of  patents  falling  within  scope  of  the  Directive,  the  information  source  was  not 
available to the current research team. 

Furthermore, it should be noted at this point that some limitations exist, such as the lack or 
incompleteness  of  market  data.  This  issue  was  dealt  with  in  our  analysis  by  applying  a 
methodology that aims to gather estimates and to disaggregate data, while also adding value 
through desk research and stakeholder consultation. Other limitations were also encountered 
in gathering market data: 

•  The NACE codes used for the analysis include products that are outside the scope of the 
Directive (i.e. some lifts and skip hoists that are subject to the Machinery Directive), thus 
making it harder to obtain a precise estimate of the size and value of the lift market. 

•  The  available  data  do  not  allow  a  distinction  to  be  made  between  safety  component 
manufacturers  and  lift  installers,  here  again  hindering  an  accurate  assessment  of  the  lift 
market. 

•  For the same reason, the available data do not show the number of new lift installers and 
safety  component  manufacturers  entering  the  market  since  2015.  Furthermore,  data  at 
national level are highly fragmented. 

•  Some indicators are also limited in time. This is the case for the number of firms, as data 

are only available until 2020 (source: Eurostat SBS). 

•  Finally, as part of the EU harmonisation legislation, the Directive does not cover after-sales 
services (i.e. maintenance and modernisation of lifts). However, these constitute an integral 
and relevant part of the lift sector, particularly in the EU. Due to data aggregation, it was 

84 

 
 
 
not possible to distinguish between firms active in production and installation and those 
performing  modernisation  and  maintenance  only,  and  therefore  not  impacted  by  the 
Directive but by national legislation. 

These limitations made it somewhat more difficult to assess the impacts of the Directive on the 
internal  market,  though  some  trends  could  still  be  identified.  A  specific  methodology  was 
developed for the market analysis in order to take account of these limitations. 

The  table  below  summarises  the  methodology  developed  to  conduct  this  analysis,  showing 
which  indicators  have  been  identified,  from  which  sources  and  for  which  products. 
Unfortunately, in many cases the available data do not fully match with the products covered 
by the Directive. Where possible, indicators relating only to the products within the scope of 
the Directive were estimated by combining official and non-official sources. 

85 

 
 
 
 
Table 1: Methodology for market analysis indicators 

Indicator 

Units and 

Source 

Coverage 

Issues 

Action 

Estimate 

ELA 2023 white 

Products: lifts and 

Fully matching with the 

The under-representation of SMEs is not deemed to hinder 

None 

value of lifts 

paper and other 

safety components 

scope of the Directive, 

the estimate of production sold, as they play a minor role in 

and 

ELA industrial 

Territory: EU-27, CH, 

though likely to under-

lift production. In some cases, these data were used to 

components 

statistics 

NO, TR 

represent SMEs. 

triangulate data provided by official sources. 

sold 

(production) 

Timeframe: 

2015-2022 

Eurostat 

Prodcom57 

Products: lifts: NACE 

(A) Data at Member 

(A) Data have been used only at aggregate level (EU). 

Value of lifts sold = no 

Rev. 2 code 28221630 

State level are very 

(B) The inclusion rather than the exclusion of skip hoists 

calculation necessary 

and 28221650; 

fragmented. 

covered by the Directive is not straightforward. Nonetheless, 

Value of lift components sold 

Safety components: 

(B) NACE codes for 

skip hoist production value – whether covered by the 

= value of lift components 

NACE Rev. 2 

lifts include skip 

Directive or not – over total EU production of lifts and skip 

including escalator 

code 28221950 

hoists58. 

hoists is estimated to not exceed 10%, meaning that those 

components*0.92  

Territory: EU-27 

(C) NACE codes for 

outside the scope of the Directive are even fewer. As a result, 

Timeframe: 2011-

lifts include lifts that 

the indicator has been used as it is. 

2023 

might fall under the 

(C) The percentage of lifts that may fall under the Machinery 

Intra- and 

Eurostat 

Products: lifts: SITC 

Machinery Directive 

Directive has been estimated as residual, considering that 

Import/export of lifts = no 

extra-EU-28 

International 

Rev. 3 code 74481; 

(e.g. due to different 

most products in its scope are ‘captured’ by NACE Rev. 2 

calculation necessary 

trade (import 

Trade60 and UN 

Safety components: 

speeds)59. 

code 2822. As a result, the indicator has been used as it is. 

Import/export of lift 

57 Eurostat Prodcom provides the value and volumes of production sold: http://ec.europa.eu/eurostat/cache/metadata/EN/prom_esms.htm. 

58 A skip hoist is a bucket or car operating up and down a defined path, receiving, elevating and discharging bulk materials. 

59 The Directive does not apply to lifting appliances whose speed is not greater than 0.15 m/s. (Art. 1(3)). 

60 Prodcom does not provide details on trade partner countries, whereas the Eurostat International Trade database does. 

86 

 
 
 
 
Indicator 

Source 

Coverage 

Issues 

Action 

Estimate 

and export) in 

Comtrade 

SITC Rev. 3 code 

(D) The NACE code for 

(D) We estimate that only 92% of the NACE code for safety 

components = import/export of 

value 

Database 

74493 

safety components also 

components fall within the scope of the Directive, the 

lift components including 

Territory: EU-28 and 

includes escalators that 

remaining 8% being related to escalators.  

escalator components*0.92 

EEA 

are not covered by the 

Timeframe: 2011-

Directive. 

Competitive 

UN Comtrade 

ness 

Database; 

2023 

None 

None 

Estimated based on UN Comtrade Database. 

Export percentages 

Number of 

Eurostat SBS 

Products: lifting and 

Lifting equipment also 

. 

None 

enterprises 

handling equipment: 

includes lifting 

It is not possible for the research team to estimate the 

NACE Rev. 2 code 

machineries that do not 

percentage of manufacturing companies included in the 

2822 

fall within the scope of 

NACE code that do not produce any products included in the 

Territory: EU-27 + IS, 

the Directive. 

scope of the Lifts Directive. Therefore, this data will be 

NO, CH 

Timeframe: 2011-

2020 

considered to be purely indicative. 

Number of 

ELA 2023 white 

Products: lifts and 

These data also include 

Data provided by ELA specifically relate to the lift sector. 

None 

employees 

paper and other 

safety components 

employees and 

These data include employees involved in both 

ELA industrial 

Territory: EU-27, CH, 

enterprises active only 

production/installation and the provision of after-sales 

statistics 

NO, TR 

in the after-sales market 

services (the latter not being covered by the Directive). We 

Timeframe: 

2015-2022 

(i.e. not covered by the 

have opted to use ELA statistics rather than other sources for 

Directive). 

this indicator as they are relatively reliable and relate only to 

the lift sector. 

87 

 
 
 
 
 
 
 
 
The following table presents the product composition of NACE code 2822 based on Eurostat classification. 

Table 2: Eurostat classification of NACE code 2822, lifting and handling equipment 

Code 
28221130 
28221170 
28221200 
28221330 
28221350 
28221370 
28221420 
28221433 
28221435 
28221440 
28221450 
28221460 
28221470 

28221513 
28221515 
28221530 
28221550 
28221570 

28221630 
28221650 
28221670 
28221740 
28221750 
28221770 
28221793 

28221795 

28221820 
28221840 
28221850 

Product 
Pulley tackle and hoists powered by an electric motor (excluding of the kind used for raising vehicles) 
Pulley tackle and hoists, non-powered by electric motor (other than skip hoists or hoists of a kind used for raising vehicles) 
Winches and capstans (excluding those for raising vehicles) 
Built-in jacking systems of a type used in garages for raising vehicles 
Hydraulic jacks and hoists for raising vehicles (excluding those for use in garages) 
Jacks and hoists of a kind used for raising vehicles (excluding built-in jacking systems of a kind used in garages, hydraulic jacks and hoists) 
Overhead travelling cranes on fixed support 
Mobile lifting frames on tyres and straddle carriers 
Transporter cranes, gantry cranes and bridge cranes 
Tower cranes and portal or pedestal jib cranes 
Self-propelled lifting equipment, of a kind mounted to run on rails in servicing building sites, quarries and the like 
Lifting equipment designed for mounting on road vehicles 
Lifting equipment (excluding overhead travelling cranes, tower, transporter, gantry, portal, bridge or pedestal jib cranes, mobile lifting frames or 
straddle carriers, self-propelled machinery) 
Self-propelled works trucks fitted with lifting or handling equipment, powered by an electric motor, with a lifting height ≥ 1 m 
Self-propelled works trucks fitted with lifting or handling equipment, powered by an electric motor, with a lifting height < 1 m 
Self-propelled works trucks fitted with lifting or handling equipment, non-powered by an electric motor 
Works trucks fitted with lifting or handling equipment (excluding self-propelled trucks) 
Works trucks, self-propelled, not fitted with lifting or handling equipment, of the type used in factories, warehouses, dock areas or airports for short 
distance transport of goods; tractors of the type used on railway station platforms 
Electrically operated lifts and skip hoists 
Lifts and skip hoists (excluding electrically operated) 
Escalators and moving walkways 
Pneumatic elevators and conveyors 
Bucket type continuous-action elevators and conveyors for goods or materials 
Belt type continuous-action elevators and conveyors for goods or materials 
Roller conveyors for goods or materials (excluding pneumatic elevators and conveyors, those specially designed for use underground, bucket type, 
belt type) 
Continuous-action elevators or conveyors for goods or materials (excluding pneumatic elevators or conveyors, those designed for use underground, 
bucket type, belt type, roller conveyors) 
Teleferics, chair-lifts, ski-draglines and traction mechanisms for funiculars 
Lifting, handling, loading or unloading machinery, n.e.s. 
Loading machinery specially designed for agricultural use 

88 

 
 
 
Code 
28221930 
28221950 
28221970 

28222000 

Product 
Parts of machinery of HS 8425, 8427 and 8428 (excluding lifts, skip hoists or escalators) 
Parts of lifts, skip hoists or escalators 
Parts of self-propelled works trucks, not fitted with lifting or handling equipment, of the type used in factories, warehouses, dock areas or airports 
for short distance transport of goods, incl. tractors for railways station platforms, n.e.s. 
Buckets, shovels, grabs and grips for cranes, excavators and the like 

89 

 
 
 
ANNEX VIII – ANNEX TO THE BRUSSELS EFFECT 

Definition 

The ‘Brussels effect’ refers to the ability of the European Union to determine, shape or 
otherwise  influence  regulatory  standards  and/or  behaviour  beyond  the  confines  of  its 
jurisdiction61. This ability is generally thought to be realised through non-negotiated and 
non-coercive means. The Brussels effect can be considered as a proxy of the EU’s ability 
to shape global governance and trade through its regulatory power and serves as a model 
for  other  regions  seeking  to  influence  international  standards  and  norms.  The  Brussels 
effect has been said to have five underlying elements, all of which apply to the case of lifts, 
namely  market  size,  regulatory  capacity,  stringent  standards,  inelastic  targets,  and  non-
divisibility62. 

In analysing the non-EU Member States that have adopted standards that are identical or 
broadly aligned with EU standards, it is worth thinking in terms of ‘concentric circles’ as 
regards the degree of formal cooperation with the EU regulatory process and/or adoption 
of EU standards: first, non-EU Member States within CEN/TC 10; second, countries with 
a formal cooperation agreement with the EU; third, other countries that have unilaterally 
adopted  national  standards  that  are  closely  aligned  with  EU  standards;  fourth,  other 
countries where many suppliers have chosen to operate according to EU standards; fifth, 
other countries not aligned with EU standards, notably the US. 

The available evidence is sufficient to demonstrate that the Brussels effect manifests itself 
in the lift sector. In particular, there is strong evidence that many non-EU countries have 
aligned their standards with the EU either through direct cooperation or unilateral adoption 
or indirectly via alignment with ISO standards. Moreover, the stakeholders consulted for 
this  survey  consistently  reported  the  importance  of  the  Brussels  effect  in  terms  of  its 
influence on non-EU jurisdictions and on global manufacturers. There is evidence to show 
that  the  EU  has  high  levels  of  trade  in  lifts  and  a  significant  trade  surplus:  USD 0.466 
billion in  ‘Parts of lifts, skip  hoists or escalators’63 and USD 1.281 billion in  ‘Lifts and 
hoists’64 (see ‘Impact on global trade flows’ below). This points to the importance of the 
Brussels effect for the EU’s global trade, although causality cannot be directly proven by 

61 Anu Bradford, The Brussels Effect: How the European Union Rules the World (OUP 2020). 

62 Ibid. 

63 

https://wits.worldbank.org/trade/comtrade/en/country/ALL/year/2023/tradeflow/Exports/partner/WLD
/product/843131. 

64 Observatory of Economic Complexity: https://oec.world/en/profile/hs/lifts-and-skip-hoists. 

90 

 
 
 
the data. Moreover, the trade data does not neatly map onto the products covered by the 
Lifts Directive but may encompass other products. 

Non-Member States within CEN/TC 10 

CEN  comprises  34  member  countries,  each  represented  by  their  respective  national 
standardisation  bodies.  These  members  work  together  to  develop  and  adopt  European 
standards  (EN),  including  those  formulated  by  CEN’s  technical  committee  on  lifts 
(CEN/TC 10), which focuses on safety rules for the construction and installation of lifts, 
escalators and passenger conveyors. 

As well as the 27 EU Member States, the member countries of CEN include Iceland, North 
Macedonia, Norway, Serbia, Switzerland, Türkiye and the UK. These last two countries 
are examples of CEN members that have adopted the standards developed by CEN/TC 10, 
which facilitates compliance with the Lifts Directive. 

United Kingdom 

The 2014 Lifts Directive was transposed into UK law under the Lifts Regulations 2016, 
which have remained in force ever since, albeit with some minor amendments65. The EU 
Withdrawal Act 2018 preserved the Lifts Regulation 2016 and enabled them to be amended 
so as to continue to function effectively following the UK’s departure from the EU. In line 
with this, the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 
2019 removed references to EU institutions and made specific provision for the market in 
Great  Britain.  However,  some  of  the  provisions  in  UK  legislation  apply  differently  in 
Northern Ireland under the terms of the Windsor Framework. 

Türkiye 

Türkiye has aligned its national legislation with the requirements of the Lifts Directive. 
The Turkish standards institution, the TSE, has transposed various European Norm (EN) 
standards  into  national  standards,  such  as  TS EN 81-1  and  TS EN 81-2,  which  were 
adopted in the early 2000s and govern the construction and installation of lifts. 

To ensure compliance with this national legislation,  Türkiye has established procedures 
for  the  designation  of  notified  bodies  for  the  construction  and  installation  of  lifts.  The 
Turkish Ministry of Industry and Trade oversees this process, ensuring that  CABs meet 
the necessary criteria before being designated as NBs. The Ministry also conducts market 
surveillance to ensure compliance with the legislation, including inspections at locations 
where lifts are installed. 

Türkiye has also implemented a regulation on electrical equipment designed for use within 
certain  voltage  limits,  based  on  the  EU’s  Low  Voltage  Directive  2014/35/EU.  This 
regulation lays down safety principles and conformity assessment procedures for electrical 

65 

https://www.gov.uk/government/publications/lifts-regulations-2016/lifts-regulations-2016-great-

britain#legislative-background. 

91 

 
 
equipment,  including  components  used  in  lifts,  further  harmonising  Turkish  legislation 
with EU directives. 

Cooperation with CEN 

Some countries have aligned their standards with those of the Lifts Directive on the basis 
of a partnership with CEN. 

Australia 

Australia’s  national  standards  body,  Standards  Australia,  has  a  long  history  of  working 
with  CEN  and  other  international  standards  organisations,  such  as  the  International 
Organization for Standardization (ISO), for example, through international standardisation 
forums and bilateral technical committees. While Standards Australia is not a full member 
of CEN, it works closely with CEN through harmonisation efforts and mutual recognition 
of international standards where applicable. 

The Australian Standard AS 1735 series governs the design, construction and installation 
of lifts, escalators and moving walkways. Several parts of AS 1735 are direct adoptions or 
adaptations of European standards: 

•  AS 1735.19:2019.  This  standard  specifies  requirements  for  alarm  systems  in 
passenger  and  goods  passenger  lifts  and  is  identical  to  the  European  standard 
EN 81-28:2018+AC:2019. 

•  AS 1735.12:2020. Focusing on accessibility features for persons with disabilities, 
this  standard  adopts  EN 81-70:2018  with  amendments  to  address  Australian 
conditions. 

•  AS 1735.8.1-2020.  This  standard  pertains  to  safety  rules  for  electric  lifts  with 

inclined paths and is a modified adoption of EN 81-22:2014. 

Given this close alignment, some EU certifications are accepted in Australia, albeit on a 
case-by-case basis. 

China 

CEN and China have been working together for a long time to encourage a move towards 
the  harmonisation  of  product  standards.  This  has  included  the  Seconded  European 
Standardization Expert for China (SESEC) project, which has aimed to raise awareness of 
the European Standardisation System in China66. Collaboration has encompassed a broad 
range of product fields, including lifts. 

In  2005,  CEN/TC 10  and  the  Standardization  Administration  of  China  (SAC/TC 196) 
signed  a  cooperation  agreement  to  align  their  efforts  in  developing  lift  standards.  This 
cooperation  transformed  European  standards  EN 81-20  and  EN 81-50  into  international 
standards, resulting in ISO 8100-1 and ISO 8100-2. China’s lift standards have historically 
been heavily influenced by European standards, particularly the EN 81 series. The Chinese 
standard GB 7588, for example, is almost identical to EN 81. 

66 https://sesec.eu/ . 

92 

 
 
Efforts to harmonise standards have been ongoing. In 2019, ELA and the China Elevator 
Association (CEA) signed a memorandum of understanding to promote cooperation and 
mutual  understanding  of  standards.  This  cooperation  aims  to  align  interpretations  of 
standards like ISO 8100-1 and ISO 8100-2 in order to facilitate a more unified approach 
to lift safety and design. 

Unilateral adoption of (close to) EU standards 

Some countries have adopted regulatory standards for lifts that are heavily influenced by 
EU  standards  as  this  allows  them  to  ensure  that  they  are  in  line  with  international  best 
practice. 

India 

India’s standard IS 14665 was introduced in 2000. Although formal cooperation between 
India and CEN/TC 10 has been limited, the Bureau of Indian Standards has tended to align 
its standards with those of EN 81. 

Eurasian Economic Union (EAEU) 

The EAEU’s ‘Technical Regulation on the Safety of Lifts’ (TR CU 011/2011) came into 
force in April 2013 and harmonises safety requirements for lifts across the EAEU countries 
(Armenia,  Belarus,  Kazakhstan,  Kyrgyzstan  and  Russia).  That  technical  regulation  is 
influenced by international standards, including those of the EU’s Lifts Directive, although 
not completely aligned. It specifies safety requirements for design, installation and use and 
requires EAC Certification. 

Mongolia 

In 2015, Mongolia adopted its national lift standard (MNS ISO/TR 11071-1:2015) setting 
out  safety  rules for the construction and installation of lifts. The standard is  not legally 
binding  but  is  instead  a  technical  report  providing  a  comparative  analysis  of  safety 
standards used in various countries, including the EU. It serves as guidance for policy and 
alignment of standards. 

There  is  potential  for  further  alignment  with  EU  standards,  given  that  in  2016  the 
Mongolian  Agency  for  Standardization  and  Metrology  (MASM)  became  the  first 
companion standardisation body (CSB) of CEN. CSB status enabled Mongolian experts to 
work  with  their  European  counterparts  with  the  aim  of  learning  from  each  other, 
exchanging  best  practices  and  working  jointly  on  strategic  areas67.  While  the  CSB 
agreement  does  not  specifically  target  lift  standards,  it  encompasses  related  sectors, 
including construction and safety. 

Widespread adoption by producers 

Many producers of lifts around the world have chosen to develop products in compliance 
with the Lifts Directive and the EN 81 series. For example, Japan has its own national code 

67 https://www.eeas.europa.eu/node/14777_en. 

93 

 
 
but firms like Mitsubishi and Hitachi use EN 81T for export. Similarly, manufacturers in 
Brazil, Hong Kong, Singapore and South Korea often choose to align with EU standards. 
In the Gulf States (e.g. UAE, Qatar), EN 81 standards are often required in construction 
tenders. 

United States 

The American Society of Mechanical Engineers (ASME) sets the primary standards for 
lifts in the US, specifically the ASME A17.1 Safety Code for Elevators and Escalators. US 
standards are not directly based on EU standards but are designed to offer alignment with 
international  standards  (e.g.  ISO 8100-1)  and  thus  show  a  degree  of  overlap  with  EU 
standards. 

The  first  standard,  A17.1/CSA B44  –  Safety  Code  for  Elevators  and  Escalators,  is 
prescriptive  in  that  it  specifies  detailed  requirements  (e.g.  dimensions,  forces,  sensors, 
clearances)  for  the  design,  construction,  installation,  operation,  inspection,  testing, 
maintenance,  alteration  and  repair  of  lifts,  escalators  and  related  conveyances.  The 
standard  is  relatively  inflexible  and  thus  mostly  suitable  for  standard  installations. 
A17.1/CSA B44  is  focused  on  installation  and  maintenance  rather  than  approval  of 
individual  components.  It  relies  on  on-site  inspection  and  testing  rather  than  design 
conformity documentation. 

In contrast, the second standard, A17.7/CSA B44.7 – Performance-Based Safety Code for 
Elevators  and  Escalators,  is  performance-based.  It  is  intended  to  offer  flexibility  in 
problem-solving,  particularly  for  new  technologies  and  practices  or  non-traditional 
systems. 

Overall, US regulation is more performance-based and less prescriptive than in the EU and 
requirements can vary significantly between states and municipalities, particularly in terms 
of accessibility and energy efficiency. Attention is mostly given to on-site inspection and 
testing in contrast to the EU’s focus on design conformity documentation and approval of 
individual components. Regulation and enforcement are also more decentralised than in 
the EU. 

Influence on the International Organization for Standardization 

The ISO’s adoption of EU standards shows just how important EU standards have become. 
Following  close  collaboration  between  CEN/TC 10  and  the  ISO  technical  committee 
ISO/TC 178, the EU standards  EN 81-20 and EN 81-50 were adopted as ISO standards 
ISO 8100-1:2019 and ISO 8100-2:2019. These ISO standards are expected to be replaced 
by ISO/DIS 8100-1 and ISO/DIS 8100-2 in the near future68. CEN reports that it intends to 

68 https://www.iso.org/standard/70824.html. 

94 

 
 
work  in  parallel  with  ISO  on  the  revision  of  standards,  so  that  EU  standards  and  ISO 
standards remain aligned69. 

Impact on global trade flows 

The precise impact of the Brussels effect on trade flows with the rest of the world cannot 
be estimated with any certainty. There is, however, some evidence to support the argument 
that  the  Brussels  effect  provides  a  boost  to  EU exports  to  the  rest  of  the  world.  (Some 
caution must be applied in the analysis of trade data, as product categories do not always 
correlate precisely with those products covered by the Lifts Directive.) This boost arises 
not only through the adoption of EU standards by regulators in other countries but also 
through the choices made by manufacturers exporting to the EU and through the supply 
chains of EU-based manufacturers. 

Trade data shows that the EU was the second-largest exporter of ‘Parts of lifts, skip hoists 
or escalators’ in 2023. China’s exports amounted to USD 1.219 billion, while the EU’s 
exports came to USD 0.893 billion (not including intra-EU trade)70. Moreover, after China 
and the EU, the next two countries with the highest exports were both member countries 
of  CEN  and  apply  the  standards  set  out  in  the  Lifts  Directive,  i.e.  the  UK  (USD 0.203 
billion) and Türkiye (USD 0.167 billion). With imports of EUR 0.427 billion, the EU had 
an  overall  trade  surplus  of  USD 0.466  billion.  In  contrast,  US  exports  stood  at  only 
USD 0.16 billion compared with imports of USD 0.561 billion, resulting in an overall trade 
deficit of USD 0.402 billion. 

Table 1: Exports of parts of lifts, skip hoists or escalators (2023) 

Country 

China 

Export trade value, 2023 
(USD billion) 

1.219 

EU (excluding intra-EU trade)  0.893 

EU (including intra-EU trade) 

3.316 

UK 

Türkiye 

US 

0.203 

0.167 

0.160 

Source: World Integrated Trade Solution 

Other data suggests a significant EU trade surplus in ‘Lifts and skip hoists’. Total exports 
of these products by the 27 EU Member States in 2023 were USD 3.316 billion (including 

69  https://www.cencenelec.eu/news-and-events/news/2021/eninthespotlight/2021-02-09-standards-lifting-
the-single-market-up/#:~:text=The%20first%20phase%20of%20the,ISO%208100%2D2%3A2019. 

70 

https://wits.worldbank.org/trade/comtrade/en/country/ALL/year/2023/tradeflow/Exports/partner/WLD
/product/843131. 

95 

 
 
intra-EU trade), while total imports were USD 2.034 billion71. Thus, even accounting for 
intra-EU trade, the surplus with the rest of the world amounted to  USD 1.281 billion in 
that year. Moreover, this trade surplus has arisen in a sector experiencing steady growth: 
6.32% in 2023 compared with 2022 and 1.72% annually over the last five years. 

These findings from the trade data are supported by the responses to the survey conducted 
for this evaluation. The vast majority of stakeholders responding to the survey reported 
that: 

•  EU  standards  had  contributed  to  advancing  the  state-of-the-art  (scientific  and 

technological progress) globally (68/86, 79%); 
the EU is a world leading standard-setter in lifts (74/86, 86%); 

• 

•  EU standards influenced international standards (68/86, 79%). 

Of 32 economic operators or industry associations, the majority (17/32, 53%) reported that 
harmonised  European  lift  standards  help  them  to  sell  lifts  outside  the  EU  and  only 
7/32(22%) said that the standards did not (the rest, 8/32, did not know). Two manufacturers 
were  able to  estimate the value of such sales: one estimated them at  11-25% of annual 
turnover, while the other estimated 1-10%. In their qualitative responses to open questions 
in  the  survey,  economic  operators,  industry  associations  and  other  stakeholders 
consistently reported that EU standards were important influences on standards in other 
ways, thus creating a favourable global trading environment for them. 

The data also suggests that the US, Canada and Mexico are not only net importers of ‘Lifts 
and skip hoists’ but also have low levels of imports and exports of these products. The 
three countries together experienced a trade deficit in these goods of USD 210 million in 
2023. Total trade was far less than the EU both in terms of exports (USD 0.459 billion, 
compared  with  USD 3.316  billion  for  the  EU-27)  and  imports  (USD 0.670  billion, 
compared  with  USD 2.033  billion  for the EU-27), which suggests that much of the US 
market is served by domestic manufacturers. 

• 

71 Observatory of Economic Complexity: https://oec.world/en/profile/hs/lifts-and-skip-hoists. 

96 

 
 
 
 
ANNEX IX – MODERNISATION AND MAINTENANCE PRACTICES OF EU MEMBER STATES 

The  tables  below  were  completed  using  information  provided  by  national  authorities 
and/or national industry associations. No information was received for Austria, Estonia, 
Luxembourg and Malta. Information on modernisation for Austria and Luxembourg was 
partially retrieved from a survey conducted by the European Lifts Association in 2020 on 
the implementation of EN 81-20/50. 

Table 1: National practices regarding modernisation 

Country  

Austria 
Belgium 

Bulgaria 
Croatia 
Cyprus 
Czechia 
Denmark 
Finland 

France 

Germany 

Greece 
Hungary 

Ireland 
Italy  
Latvia 
Lithuania 
Luxembourg 
Netherlands 
Poland 
Portugal 
Romania 
Slovakia 
Slovenia 
Spain 
Sweden 
Norway 
Switzerland 

Existence of national 
legislation on 
modernisation of lifts 
Yes 
Yes 

Yes 
Yes 
Yes 
Yes 
Yes 
Yes 

No – rules on the safety 
of existing lifts mandate 
that certain lift 
components be brought 
into conformity 
No – existing legislation 
mandates that a risk 
assessment be carried out 
regularly 
Yes 
No – national guide 
covers technical 
requirements for lift 
modernisation 
No specific regulation 
Yes 
Yes 
Yes 
No (as of 2020) 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
Yes 
No – rules are set at 
regional level 

Explicit reference to 
European standards 

Application of penalties 
for non-compliance 

No72 (as of 2020) 
No – reference to 1995 
EC Recommendation 
Yes 
Yes 
No 
No 
No 
No – reference to the 
Directive 
Yes 

No 

Yes 
Yes 

No 
Yes 
No – indirectly 
Yes 
No 
No 
No 
No 
No 
No 
No 
No – indirectly 
No – indirectly 
No 
No 

n/a 
Yes 

Yes 
Yes 
Yes 
Yes 
Yes 
Yes 

Yes 

Yes 

Yes 
No 

No 
Yes 
Yes 
Yes 
n/a 
Yes 
Yes 
Yes 
No 
Yes 
Yes 
Yes 
Yes 
Yes 
No 

72 Mandatory reference to national standards was included in 2020. However, the country was in the process 
of  revising  the  national  legislation  to  include  the  new  EN 81-80  Standard  –  Safety  rules  for  the 
construction and installation of lifts – Existing lifts – Part 80: Rules for the improvement of safety of 
existing passenger and goods passenger lifts (NOT cited). 

97 

 
 
Table 2: National inspection and maintenance practices 

Minimum 
frequency for 
inspections 

Minimum 
frequency for 
maintenance 

Use of a register 
of lifts 

Country  

Belgium 

Existence of 
national 
legislation on 
maintenance of 
lifts 
Yes 

Bulgaria 

Yes 

Croatia 

Cyprus 

Yes 

Yes 

Czechia 

Yes 

Denmark 

Yes 

Finland 

Yes 

France 

Yes 

Germany 

Greece 

Hungary 

Yes 

Yes 

Yes 

As set out in lift’s 
technical 
documentation. If 
not available, every 
6 months. 

No, but in the 
process of setting 
up a digital 
repository. 

Once a month. 

Yes 

Every 6 months if 
maintenance 
carried out by a 
certified 
maintenance 
company; 
otherwise every 3 
months. 
Once a year (or 
within one year of 
last inspection). 
Once a year. 

At least once every 
2 years. 

Once a month. 

Once a month for 
lifts in public 
buildings. 
Once every 3 
months for lifts in 
private buildings. 
As set out in lift’s 
technical 
documentation and 
national legislation 
(frequency depends 
on the specific 
part/component). 

Expert inspections 
once every 2 
months for lifts in 
buildings with free 
public access. 
Once every 3 
months for lifts in 
buildings with 
limited public 
access. 
Once every 2 to 12 
months depending 
on the lift. 
Once every 2 years.  As set out in lift’s 

n/a 

technical 
documentation.  
Once every 6 
weeks or once a 
year, depending on 
the component. 

Once a year for 
high-rise buildings; 
otherwise, once 
every 5 years. 
Once every 2 years.  No minimum 

Once a year. 

Once a year for 
lifts less than 20 
years old; 
otherwise, once 
every 6 months.  

frequency. 
Once every 15 
days. 
As set out in lift’s 
technical 
documentation; 
otherwise once 
every 35 or 70 days 
depending on the 
age of the lift. 

98 

No, but it is 
planned. 
Yes, but not up to 
date. 

No 

No 

No 

No 

Yes 

Under 
development. 
Yes 

 
 
Minimum 
frequency for 
inspections 

Minimum 
frequency for 
maintenance 

Use of a register 
of lifts 

No minimum 
frequency. 

Two reports of 
thorough 
examination per 
year. 
Once every 2 years.  Once every six 

n/a 

No 

Yes 

Yes  
No 

Yes 

Yes 

Yes 

No 

months. 
As set out in lift’s 
technical 
documentation. 
Once a month. 
No minimum 
frequency. 
As set out in lift’s 
technical 
documentation. 
Once a month. 

Once every 14 days 
for regular check. 
Once every 6 or 12 
months for general 
maintenance. 
As set out in lift’s 
technical 
documentation. 

Country  

Ireland 

Italy  

Latvia 

Lithuania 
Netherlands 

Poland 

Existence of 
national 
legislation on 
maintenance of 
lifts 
Yes73 

Yes 

Yes 

Yes 
Yes 

Yes 

Portugal 

Yes 

Romania 

Yes 

Slovakia 

Yes 

Slovenia 

Yes 

Spain 

Yes 

Sweden 

Norway 

Yes 

Yes 

Switzerland 

Yes 

Once a year. 

Once a year. 
At least once every 
18 months. 
Once a year. 

Once every 2, 4 or 
6 years depending 
on type and use of 
the building. 
Once a year. 

Once every 3 
months for a 
professional 
inspection. 
Once every 3 years 
for a professional 
test. 
Once every 6 years 
for official test by 
NBs. 
Once a year. 

Once every 2, 4 or 
6 years depending 
on type and use of 
the building. 
Once a year. 

As set out in lift’s 
technical 
documentation. 
Once a month. 

No 

Yes, at regional 
level74. 

No minimum 
frequency. 

No 

Yes 

Once every 2 years.  No minimum 

As decided at 
regional level. 

frequency. 
As set out in lift’s 
technical 
documentation. 

Yes, at regional 
level. 

73 There are no statutory maintenance requirements at national level. However, inspections are required by 

the Health and Safety Authority of Ireland. 

74 National industry associations gather data from member companies. 

99