- “And this is very helpful for economic operators. This alleviate costs and provides for legal certainty. The problem is that, uh, this system is not always effective. And, uh, in fact, as you as you may probably know, we are now embarking in a process of revision of the standardisation regulation. The open public consultation was just published yesterday and the call for evidence has already been published. But in the meantime, we wanted to make sure that there is a fallback option in case harmonised standards are not there. So if we can go to the next slide. Uh, so this fallback option has already been introduced in several pieces of legislation. I'm thinking of medical device regulation, machinery regulation. So now the idea is that this should be uh, also for coherence, uh, should be introduced throughout, uh, the legislation under the new legislative framework. And the, the idea is that if the standards are not available, the commission can adopt common specifications. Certification. This will ensure a consistent approach across product legislation and most importantly, will ensure for the manufacturers and economic operators that if they don't have as a benchmark harmonized standards, they can use a common benchmark which is provided by the common specifications. As it is the case for harmonized standards, the common specification will allow the manufacturers to prove a presumption or conformity with the legal requirements, and in this way this will reduce cost and complexity for the manufacturers. If we can go to the next slide, uh, I would like to strengthen because we have heard concerns, uh, often about that.”
EU Single Market harmonisation · EU competences on consumer protection and product standards
- “And therefore, uh, we have, uh, we have replaced it by information which is listed in the and in one of the annex of this, uh, regulation, to be more precise. Uh, then the next slide, the idea is that over time, digital product passport will become mandatory for all products on the market, but we have not introduced that yet. This is something we are considering in the context of the upcoming revision of the new legislative framework. Uh, but what we have, uh, included now in our proposal is that, uh, whenever a product is affected by different pieces of legislation, one of which may already have included on a mandatory basis the digital product passport, then, uh, the information related to the other pieces of legislation will be added in the same digital product passport or the same QR code. So that will alleviate also burden for manufacturers. They can use the same digital tools and also will improve coherence among the different legal acts and obligations. So this is all when it comes to the digital aspects of this proposal. But then the proposal also has another important pillar, which is the one of the common specifications as an alternative to harmonised standards. And then we can move to the next slides. Well, I don't have to to mention here the importance of standards. We had already several changes on this in this in this committee. Uh, the standards are, uh, underpinning, uh, our internal market legislation providing presumption of conformity for economic operators.”
Ecodesign & durability · EU Single Market harmonisation · Product passport
- “This is only a fallback option. So our preferred option is always that the harmonized standards are there. So it is to have a fully functioning system whereby you have the essential requirement in the legislation, and then the technical specification set out through a stakeholder driven approach through harmonised standards. But in the case where we have, for example, from the commission side, issued a standardisation request and then the standardise, and they have not been able to provide the standards we need to have as regulators, we need we need to have the means to provide alternative solution. So we would set out the common specification, but not on our own. We would obviously draw on the expertise which is available. And and namely we will use the expert groups which have been set up Uh, up already in the context of the different sectoral legislation. And by having this introduced, uh, horizontally, we have a common approach because so far there are many divergences in the different legal acts where we have introduced this possibility. By introducing it through this proposal, we ensure that there is a common approach throughout the all the legal acts which are covered by the proposal. And in the next slide, you have the full list of all the amended legislative acts. So to which the then our proposal you can move to the next slide. Our proposal on digitalisation and common specifications would apply. So I will stop at that with my presentation and happy to reply Replied to your questions, if any. Thank you.”
EU Single Market harmonisation · EU competences on consumer protection and product standards
- “Thank you very much and many thanks for the positive disposition that you have showed that this is really encouraging us. Now, I will reply to the questions one by one. Why are changes in the drafting of the common specifications? Well. The common specification has been introduced progressively in different legal acts, and the fact that they have been subject obviously, to different interinstitutional processes has resulted in incoherence and in different language. So with this proposal, our attempt is to streamline and have a coherent approach throughout the legal text. We have put forward a language on the basis of the experience which we have gained so far, including with the legal acts where the common specification option was introduced. And this is why, for example, we had introduced also a so-called urgency option because, uh, as I said, in general, we think of it as a fallback option. We provide a mandate to the standardizes. If they don't fulfil the mandate, then we can introduce common specification. But there are cases we have seen recently because of all the issues with the access to documents surrounding the standards that, for example, standards were available, ISO or IEC standards were available, but they were not given to us because of legitimate reasons. But that introduced an element of disruption to the system. So we have tried to cover with our proposal the different uh, cases and, and give the then the co-legislator the possibility to intervene also in those cases. This is why our proposal differs from the language which was in previous legal texts.”
EU Single Market harmonisation · EU competences on consumer protection and product standards
- “And this is again in order not to, uh, not to impose costs on them. Um, when it comes to the link between the common specification and the harmonized standards, I think we all value the standardization system. And, uh, the way the standards support, uh, our internal market legislation, we don't want that to change. We just need to make sure that the, uh, the system to provide harmonized standards is efficient. And this is why we will be, looking into ways to improve it. But here we are saying it's only a fallback option. So if the harmonised standards are not there. So there's no uh, we are not undermining the, the harmonised standard, the standardisation system. We are just saying we have noticed. I mean, it's just the fact that there are cases where harmonised standards are not there. And this creates, uh, this creates problems on the market. So in those cases, we need to have the means to intervene. Uh, when it comes to, uh, the digital instructions and information to consumers, indeed, uh, the consumers needs to find the instructions and safety information related to that specific product, that this is the intention, if there is any need to clarify the text in that respect, we are open to look into ways to clarify that. But that's the clear intention. Uh, why haven't we waited for the revision of the standardisation regulation? Because it will take a lot of time.”
Ecodesign & durability · EU Single Market harmonisation · EU competences on consumer protection and product standards
- “And, uh. And we have urgent issues on the market. Uh, we have already this option validated through other, uh, legal acts. It has been implemented already in some sectors. It worked. And and faced to the different issues that we see currently with the non-availability of standards for many different reasons, we thought that that element of the revision of the standardisation regulation, uh, should have been anticipated. Uh, will common specification have an effect on competitiveness? Well, I will say a positive effect because they will provide for legal certainty and the companies can use them to prove compliance with the legal requirements. But when it comes to developing them, I understand that there is some concern because the harmonization process is bottom up and, uh, you know, stakeholder driven approach, common specification will be, as I mentioned in my presentation, will be developed by the Commission, but with the assistance of the expert groups. And in these expert groups, all stakeholders are represented. So that will ensure that the common specification will be sound and will also serve the competitiveness objectives. And then when it comes to the, uh, consideration about languages, I it's a very relevant issue to be looked at. It's very sensitive with respect to consumers, so that will probably deserve some further, uh, cost benefit analysis. And it can be one of the elements that could be addressed in the context of the revision of the new legislative framework. Thank you very much.”
EU Single Market harmonisation · EU competences on consumer protection and product standards · Competitiveness matrix
- “And finally, let's try to ensure consistency with other legal acts if removing certain requirements. For example, the obligation of manufacturers to include include a postal address would hamper the enforcement of other pieces of legislation such as market surveillance. Um, so let's, uh, be be be careful with that. Concerning common specifications. I will reiterate it again, may not have become clear enough from our proposal, but clearly for us this is a fallback option. We continue believing that standardization, as you said, is the norm and that we would prefer a bottom up Approach where the stakeholders they can define the technical specification. This being said, we already have the common specifications option included in several pieces of legislation. And we think as regulators, we need to have this last resort option when we don't have the standards. So we welcome the drafting suggestion and further alignment that you are trying to to to achieve with other pieces of legislation. Uh, where I would still insist that we have added the possibility of acting, of taking common specification in urgent, unforeseen cases. This would still be important for us. We have seen recently we didn't receive for more than a year, uh, standards from Cenelec when they were developed by ISO, IEC. Now, luckily we are in a much better position today.”
EU Single Market harmonisation · EU competences on consumer protection and product standards
- “Uh, this being said, we are discussing I mean, we are open to discuss the formulation and then, uh, what is important, I think, is that we have a coherent approach. So from now on, this will be the formulation which will the ones which we will agree together will be the formulation which will be introduced in all the different legal acts. Uh, when it comes to the link between the Declaration of Conformity and the digital product passport. So, as I said, we are not introducing now the digital product passport. It was felt to be too soon. Uh, and that will have to be, uh, assessed. That option will have to be assessed in the context of the revision of the new legislative framework. But what we are saying is if there is already a DPP for that product, because, for example, it is a toy and already the toy regulation is introduced, the DPP then for other aspects, let's imagine that that toy is also connected. It's a radio equipment, uh, falling under the scope of the radio equipment uh, directive as well. Then for that aspect, the dock that the declaration of conformity will be introduced through the machine readable code. The same machine readable code, so that will avoid duplication. But when the product is not covered at all for any of the aspects by the DPP, we live for the time being the the choice to the manufacturers.”
Ecodesign & durability · Circular economy · Product passport
- “If we can go to the next slide, please. So the scope of this proposal is quite broad. It changes the number of regulations and directives. Most of the legal acts, which are in scope of the so-called new legislative framework, which is the horizontal framework for the free movement of goods. Next slide please. So when it comes to digitalisation and then we can go directly to the next slide. Um, the proposal aims to reduce paper the obligation to provide paper documentation as much as possible. So the EU Declaration of Conformity, which is a key document which the manufacturers have to draw up, that it would be possible for the manufacturers to only draw it up in electronic form. And whenever this declaration of conformity. It is mandatory that it has to accompany the product. Then the declaration of conformity, instead of being provided in paper format, can be made accessible through an internet address or a machine readable code. This will make life much easier for for the manufacturers and also with the bring environmental benefits, as there's no need for paper documentation. Uh, if you, uh, we move to the next slide. So the idea is that all the communication between the economic operators, the national authorities, and also the end users, with, uh, some exceptions with respect to the end users, all the communication is digitalized and which means also that the manufacturers have to provide the digital contact, which will facilitate this communication, and that will make sure that all the information on a product is easily reachable and that it's the it applies both to the national authorities and the end users.”
Ecodesign & durability · EU Single Market harmonisation · Digitalization of public governance & administration
- “Good morning. Um. Thank you. Um, so I prepared a set of slides. Uh, they should be. I cannot. Okay. Perfect. Uh, so the overall aim of this proposal is to, uh, make life easier for our companies entering the single market. So the idea is to and you can go to the next slide please. The idea is to reduce burden for economic operators, reduce costs. Um, and also make sure that they have the necessary benchmark when they want to put products on the market, uh, in order to, to prove compliance of their products. Obviously, all of this is done taking into consideration also the needs of consumers. So, uh, we hope that with our proposal, we have indeed, uh, we are striking the right balance between simplifying life for operators and and still ensuring consumer safety and information. Um, the rationale for our proposal, as I said, is simplification and boosting competitiveness. This is in line with what we have announced, uh, in, uh, earlier in our communication. Long term competitiveness of the EU, uh, where we announced a big effort to rationalise and simplify reporting requirements and administrative burdens. So this is only one of the proposals in the context of these big efforts that we have undertaken. And then it is also in line with the efforts to support competitiveness in the EU, which we have outlined in our Communication on Competitiveness compass for the EU, which, uh, clearly, explicitly refers to both the two aspects of this proposal. So, uh, making information digital and uh, finding alternatives, uh, to harmonize standards when they do not exist.”
EU Single Market harmonisation · Competitiveness matrix
- “We can move to the next slide. Um, so, uh, the instruction that accompanied the product will have to be or may be provided in electronic form. Uh, but and this is what I was mentioning earlier, we have tried to strike the right balance between alleviating burden for manufacturers, but also providing necessary assurances to the consumers when it comes to the safety information, which are essential for the for the consumers. They should be provided on paper or they should be marked on the product and the digital instruction would be would need to be accessible online during the expected lifetime of the product, or for at least ten years. And uh, with some exceptions, which could be set out in the sectorial legislation if, uh, the instructions are provided in an electronic form D and users. So namely, the consumers have the right to request a paper version of the instruction and the safety information at the time they purchase the goods. So a big move towards digitalization, but with the caveat safety information she provided on paper. And the consumers can also ask instruction for use in paper format at the time of purchasing the product. Uh, the next slide, please. Uh, so we, uh, we have also introduced certain, uh, distinction if the product, uh, in case the product are not meant for consumers or are meant only for professional use. There is no obligation to provide, uh, safety information in a paper format. And then there is one piece of legislation, the personal protective equipment, where the notion of safety information is not, uh, defined.”
Ecodesign & durability · Reparability of products · EU competences on consumer protection and product standards