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Omnibus Regulation Aligning product legislation with the digital age

Business and industry, Single market

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Public consultation

ID: 14699

Lobbying Activity

58 responses

European carmakers urge full digitalization of battery information

Association des Constructeurs Européens d'Automobiles, 1 Aug 2025

The group calls for removing numerous articles requiring printed labels, stickers, and packaging markings. They propose strengthening the Battery Passport to serve as the central digital information hub.
A digital shift would eliminate outdated physical obligations that are inefficient and environmentally burdensome.

German Industry Warns Against EU's Common Specifications Proposal

Bundesverband der Deutschen Industrie e.V., 2 Sept 2025

BDI demands that Common Specifications only be used as a temporary fallback in exceptional cases when harmonised standards are unavailable or delayed. They insist CS must automatically expire once equivalent harmonised standards are published. The process must begin with formal requests to recognised standardisation organisations.
This would preserve their influence in the consensus-based standardisation system and maintain global market access.
Regulators lose flexibility to quickly establish technical requirements without industry consensus processes.

EuroCommerce warns against shifting digital transition costs to retailers

EuroCommerce, 1 Sept 2025

EuroCommerce demands clear definitions for mandatory safety information to prevent market fragmentation. They insist manufacturers provide paper instructions and support point-of-sale printing. Redundant physical labelling for batteries should be removed to reduce packaging.
This prevents retailers from absorbing administrative costs and logistical burdens during the digital shift.
Manufacturers lose by being forced to fund on-demand printing for retailers.

DIGITALEUROPE urges digital documentation while defending industry technical standards

DIGITALEUROPE, 3 Sept 2025

The organization demands the withdrawal of common specifications to protect the industry-led standardisation system. They also push for the full digitalisation of product documentation and labels.
Moving to digital-only documentation would significantly reduce overhead and operational costs.
The European Commission would lose proposed powers to set technical rules unilaterally.

Consultation response

Apple Inc., 3 Sept 2025

Please find attached Apple's feedback to the Omnibus IV proposal.

Swedish Enterprise backs digital product info but opposes common specifications

Confederation of Swedish Enterprise, 29 Aug 2025

The group supports digitalising product declarations and instructions to simplify business processes. They suggest replacing physical addresses with digital contacts and removing "Common Specifications" proposals.
Replacing physical addresses with digital info reduces labeling costs and saves packaging space.
Non-digital consumers may lose access to manufacturer details if physical addresses are removed.

EDF urges digital-only instruction manuals for professional products

ELECTRICITE DE FRANCE, 22 Aug 2025

EDF proposes extending the removal of paper-format manuals to all professional products. They want to align ecodesign rules with the general digital-first objective.
Removing paper requirements would simplify operations and lower the company's administrative expenses.
Workers might lose immediate, offline access to safety information required for their health.

Orgalim Urges EU to Allow Digital-Only Product Information

Orgalim – Europe's Technology Industries, 13 Jun 2025

Orgalim requests an omnibus regulation to permit providing product manuals via digital links or QR codes. They argue manufacturers should choose the format based on the product and end-user needs.
Manufacturers would drastically reduce their expenses by eliminating the need for bulky paper documentation.
Customers lacking internet access may find it harder to view essential safety and assembly instructions.

WKÖ Urges More Bureaucracy Relief for Small Mid-Cap Firms

Wirtschaftskammer Österreich, 22 Jul 2025

WKÖ supports administrative simplification by extending derogations to companies with fewer than 750 employees. They request extending feedback deadlines to authorities from 15 to 30 days.
Expanded data protection exemptions would significantly lower administrative costs for thousands of Austrian businesses.
Environmental groups lose detailed data on hazardous substances if reporting requirements are significantly simplified.

Business chambers call EU simplification package insufficient for SMEs

EUROCHAMBRES – Association of European Chambers of Commerce and Industry, 21 Aug 2025

EUROCHAMBRES requests genuine simplification that delivers immediate relief to Europe's 26 million SMEs, not just 38,000 mid-caps. They urge the Commission to draft legislation with smaller businesses in mind from the outset, adhering to the 'Think Small First' principle, and to provide clearer GDPR guidance while reducing reporting obligations.
This would reduce compliance costs and administrative burdens for their 26 million SME members.

European paper industry demands paper manuals remain in products

Confederation of European Paper Industries, 1 Sept 2025

The organization opposes digital-only instructions for consumer products. They argue that requiring shoppers to request paper copies creates unnecessary barriers and safety risks for those lacking digital skills.
Retaining printed manuals protects the core business interests of European paper mills.
Manufacturers lose the cost-reduction and simplification benefits provided by removing paper instructions.

VDMA urges strict controls on fallback technical product specifications

Verband Deutscher Maschinen- und Anlagenbau e.V., 3 Sept 2025

The VDMA insists that Common Specifications remain a fallback option used only when industry standards are missing. They demand expert drafting committees and public consultations to ensure transparency throughout the regulatory process.
Machine builders would avoid expensive third-party audits by maintaining a presumption of conformity.
Third-party testing organizations lose business if companies can bypass mandatory certification using specifications.

ITI Urges EU to Expand Digital Product Labelling Rules

ITI - The Information Technology Industry Council, 3 Sept 2025

ITI requests that digital documentation become the default option for all products to replace paper instructions. They also want the Commission to prioritize industry-led standards over government-imposed technical specifications.
Tech companies would lower manufacturing expenses and environmental footprints by eliminating mandatory paper manuals.
European standards bodies lose authority as the Commission gains power to set technical rules.

German crafts urge longer digital transitions for small businesses

Zentralverband des Deutschen Handwerks e.V., 3 Sept 2025

The group wants common specifications used only as a last resort. They also call for longer transition periods and funding for small businesses.
Smaller firms would avoid high upfront costs and excessive administrative burdens.
Distributors and authorities would face inefficiencies from maintaining dual systems.

Home appliance industry calls for fully digital manuals

APPLiA (Home Appliance Europe), 3 Sept 2025

The home appliance industry requests the option to provide all user manuals and energy labels in digital formats. They argue that requiring paper safety instructions creates unnecessary workload and legal uncertainty. Furthermore, they demand that new technical specifications only be introduced if traditional standardisation processes fail.
Moving to digital documentation would eliminate millions of euros in printing and handling costs for manufacturers.
Standardisation bodies would lose influence if the Commission gains power to bypass their technical processes.

Packaging industry urges EU to digitalise product compliance rules

The European Organisation for Packaging and the Environment, 1 Sept 2025

EUROPEN supports using digital tools like the Digital Product Passport to replace paper-based information. They request harmonised digital standards across all EU legislation to align compliance deadlines and streamline reporting.
Digitalisation would help companies avoid repetitive packaging changes and lower administrative costs.
Member States lose the ability to enforce unique national language and reporting formats.

Consultation response

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 27 Aug 2025

Independent Retail Europe welcomes the European Commissions commitment to simplify rules and reduce the administrative burdens placed on EU businesses. We welcome the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the…

Ecommerce Europe urges impact assessment for product documentation digitalisation

Ecommerce Europe, 3 Sept 2025

The group requests impact assessments to evaluate costs for small businesses. They also want clear definitions for digital contact requirements. Finally, they advocate for minimum standards for national enforcement authorities.
This would reduce compliance costs for small businesses and eliminate redundant communication requirements.
Consumers may lose guaranteed access to telephone support for product complaints and inquiries.

German tech industry urges digital-first approach for product information

ZVEI e.V. - Verband der Elektro- und Digitalindustrie, 21 Aug 2025

ZVEI supports digital instructions but rejects mandatory paper copies for consumer products. They argue digital contact details should replace physical addresses to modernize communication. Additionally, they insist technical standards must be prioritized over government specifications.
Electronic-only documentation would reduce administrative burdens and streamline compliance for manufacturers.
Consumers without digital access face long delays when requesting mandatory physical safety manuals.

3M urges digital instructions for all personal protective equipment

3M, 3 Sept 2025

3M requests allowing digital manuals for all protective equipment regardless of the user. They argue the distinction between professional and consumer use is impractical and hinders digitalisation. They also state that common specifications should only be used in very exceptional cases.
This would decrease expenses related to printing and help avoid complex user categorization.
Consumers without internet access lose the legal guarantee of receiving physical safety instructions.

IKEA warns EU against bypassing industry-led product standards

Inter Ikea Systems BV, 2 Sept 2025

IKEA urges the Commission to prioritize strengthening existing industry-led systems rather than creating parallel government specifications. They argue that new rules must involve industry experts to ensure standards are technically robust. Any government-issued specifications should remain strictly temporary measures.
Aligning with international standards helps IKEA avoid the expense of redesigning and recertifying products.
Regulators lose the power to quickly address safety gaps when industry-led standard processes stall.

Consultation response

European Committee for Standardization, 2 Sept 2025

CEN and CENELEC support the European Commission's efforts to harmonize criteria for issuing common specifications. This is in principle positive, but it is crucial that the process is done in a way that ensures the involvement of a broad range of stakeholders, from societal stakeholders to Member…

Japan Business Council urges digital-first EU product rules

Japan Business Council in Europe, 3 Sept 2025

JBCE urges the EU to require digital formats as the default for formal requirements. They recommend prioritising international standards over EU-specific ones to avoid trade barriers.
Moving to digital documentation reduces compliance costs and logistical burdens like packaging clutter.
EU citizens face higher prices if the regulations introduce unnecessary financial and administrative burdens.

ANEC demands both paper and digital product manuals

The European Consumer Voice in Standardisation, 2 Sept 2025

ANEC insists that manufacturers provide instructions in both paper and digital formats. They argue printed manuals are vital for consumers lacking digital literacy or internet access. They also propose moving CE markings to digital files to reduce confusion.
This prevents the transfer of information access costs from businesses to consumers.
Manufacturers lose the potential cost savings and efficiency of providing exclusively digital information.

Danish Consumer Council demands paper instructions for digital products

Forbrugerrådet Tænk (the Danish Consumer Council), 3 Sept 2025

The organization insists that safety instructions must be provided in both paper and digital formats. They also suggest moving CE marking to digital files to prevent consumer confusion.
Maintaining physical documentation ensures that consumers without internet access or digital skills remain protected.
Manufacturers would incur higher production costs by providing both physical and digital documentation.

LightingEurope demands withdrawal of EU common specifications proposal

LightingEurope, 2 Sept 2025

The organization calls for the total withdrawal of the common specifications proposal to protect industry competitiveness. While they welcome digitalization, they want a better definition of safety-critical information that must remain on paper.
The industry would avoid new administrative burdens and unworkable technical mandates.
International standards bodies lose influence as Europe moves toward parallel systems.

Dansk Standard Demands Stakeholder Inclusion in Technical Specifications

Dansk Standard, 18 Jul 2025

Common specifications should be a last resort used only when the standardisation system fails. The organization calls for industry involvement and clear rules for withdrawing specifications when standards appear.
The organization would maintain its influence over technical rules and ensure market relevance.
Member States lose influence because the proposal shifts power to the Commission.

Spanish vehicle manufacturers urge EU to digitise battery labeling

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE AUTOMÓVILES Y CAMIONES, 4 Aug 2025

ANFAC requests eliminating redundant physical documentation that adds cost and complexity. They propose strengthening the Battery Passport as a central digital information hub accessed via QR codes.
Digitalisation would lower manufacturing costs by removing obsolete and environmentally burdensome physical labeling requirements.

Consultation response

ASOCIACIÓN ESPAÑOLA DE FABRICANTES DE PASTA, PAPEL Y CARTÓN, 2 Sept 2025

We welcome the Commission's approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, ASPAPEL is concerned about setting a 'digital only' approach in…

Consultation response

Small Business Standards, 29 Aug 2025

Please find attached SBS's comments on the Omnibus Regulation Aligning product legislation with the digital age.

Consultation response

Eclipse Foundation AISBL, 3 Sept 2025

We appreciate the opportunity to provide feedback on the omnibus proposals for a directive and a regulation to align product legislation with the digital age. Free and open source software (FOSS) is, by many measurements, the largest category of software today. Europes IT systems and European…

Consultation response

Läkemedelsindustriföreningen, 1 Sept 2025

Lif the research-based pharmaceuticals industry in Sweden is grateful for the opportunity to give our remarks on the proposed regulation and directive with the goal of aligning product legislation with the digital age. The life sciences sectorcovering pharmaceuticals, medical devices, in vitro…

Consultation response

European Carton Makers Association, 8 Aug 2025

The European Carton Makers Association (ECMA) welcomes the Commissions approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, we are extremely…

Consultation response

European Portable Battery Association, 23 Jul 2025

In response to the Commission proposal for a Regulation regarding Digitalisation and the Alignment of Common Specifications, we consider it crucial that the EU product legislation is aligned with the digital age. We support the proposed changes for the conformity assessment procedures of batteries…

Consultation response

European Materials Handling Federation, 3 Sept 2025

FEM, the European Materials Handling Federation, welcomes the European Commissions proposal for an Omnibus Regulation Aligning product legislation with the digital age. The initiative is a significant step forward the modernisation of EU product legislation and simplification of compliance…

European Safety Federation Urges Digital-First Rules for Safety Equipment

European Safety Federation, 3 Sept 2025

The federation requests removing the distinction between professional and consumer users to allow digital-only instructions. They also seek clearer definitions for machine-readable codes and consistent terminology across EU laws.
Manufacturers would avoid the costs and logistical complexity of providing mandatory paper documents for consumer products.
The single market faces fragmentation if national authorities apply inconsistent rules for consumer products.

Consultation response

VDE - Verband der Elektrotechnik Elektronik Informationstechnik e.V., 2 Sept 2025

The German Commission for Electrical, Electronic and Information Technologies (DKE) a business unit from the wider VDE Group, welcomes the European Commissions aim to modernize product legislation through the Omnibus IV simplification package, and to ensure that the European Single Market remains…

Consultation response

UL GmbH, 25 Aug 2025

UL Solutions respectfully submits these comments in response to the proposed regulation regarding digitalization and standard specifications. This proposal suggests introducing common specifications for accreditation standards within Regulation (EU) No. 765/2008. We believe this is unnecessary, as…

Consultation response

ASOCIACION ESPAÑOLA DEL GAS, 18 Jul 2025

Comentarios de Sedigas en respuesta a la consulta pública sobre la legislación europea Ómnibus adjunta

Consultation response

Kommission Arbeitsschutz und Normung, 26 Aug 2025

Die Kommission Arbeitsschutz und Normung (KAN) begrüßt die Gelegenheit zu den Vorschlägen der Kommission für eine Verordnung im Hinblick auf Digitalisierung und gemeinsame Spezifikationen des IV. Omnibus-Pakets Stellung zu nehmen und bittet um Beachtung der beigefügten Stellungnahme.

Consultation response

Intergraf European Federation for Print and Digital Communication, 22 Aug 2025

Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential…

Consultation response

AQUA - Association Européenne des Fabricants de Compteurs d’Eau et d’Energie Thermique, 20 Aug 2025

Dear European Commission Metrology Team, On behalf of Aqua Metering, the European trade organization representing water meter and thermal energy manufacturers, we would like to thank the Commission for the opportunity to comment on the proposed Omnibus Regulation aligning product legislation with…

Consultation response

Associazione Italiana fra gli Industriali della Carta, Cartoni e Paste per Carta, 2 Sept 2025

Please find attached Assocarta, Associazione Italiana fra gli Industriali della Carta, Cartoni e Paste per Carta, comments on the Omibus Regulation aligning prdoduct legislation with the digital age.

Consultation response

Mobile & Wireless Forum (Mobile Manufacturers Forum), 31 Aug 2025

The MWF thanks the European Commission (EC) for the opportunity to provide input on the Omnibus Regulation Aligning Product Legislation with the Digital Age and attached its submission below.

Consultation response

Comité Européen de Constructeurs d'Instruments de Pesage, 21 Aug 2025

CECIP fully supports the European Commissions objective to simplify regulatory frameworks and accelerate the digital and green transition. The principle of Digital by Default is a cornerstone of this evolution, marking a vital legislative shift where digital formats become the standard, and printed…

Consultation response

HKI Industrieverband Haus-, Heiz- und Küchentechnik e.V., 14 Jul 2025

Please find attached our position paper concerning the digital provision of product-related information under Regulation (EU) No 305/2011 (Construction Products Regulation). While we fully support the Commissions initiative to promote digital formats through the Omnibus IV package, we believe that…

Consultation response

Industrieverband Schneid- und Haushaltwaren, 25 Jun 2025

On behalf of the Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) and in cooperation wit the Federation of the European Cookware and Cutlery Industries (FEC), we are pleased to submit our joint position paper on the Digital Product Passport (DPP) / digital product information in the context…

Consultation response

Sika AG, 3 Sept 2025

Sika appreciates the opportunity to comment on the Omnibus proposals COM(2025)503 and COM(2025)504. We strongly support the objective of modernising and simplifying EU product legislation. We welcome the introduction of the concept of digital contact, accompanied by a concise definition. Other…

Consultation response

EUROM1 Optical Industries - ASSOCIATION DES INDUSTRIES DE L'OPTIQUE OPHTALMIQUE EUROPEENNES, 3 Sept 2025

EUROM 1 welcomes the European Commissions Omnibus Regulation as a valuable step towards digitalisation, user-friendliness and sustainability. While supporting the overall direction of the proposal, EUROM 1 raises concerns regarding the requirement for mandatory paper instructions for consumer…

Consultation response

DigitalTrade4.EU, 3 Sept 2025

Our feedback addresses the European Commissions proposal COM(2025) 504 and its annexes, focusing on the integration of the European Trade Indexes Registry (EUTIR) into the New Legislative Framework (NLF). We propose EUTIR as a foundational digital infrastructure that ensures legal validity,…

Consultation response

The Japan Electrical Manufacturers' Association, 3 Sept 2025

We, Japanese 4 electric and electronic industry associations-JEMA, JEITA, CIAJ and JBMIA (hereinafter JP4EE) welcome the opportunity to provide our comments and proposals on the draft Commission Regulations under the Omnibus IV Simplification Package. We broadly support the European Commissions…

Consultation response

figawa, 3 Sept 2025

figawa would like to thank the EU-Commission for the opportunity to submit our comments to respond to the survey Omnibus Regulation Aligning product legislation with the digital age. We support the EU's goals of achieving a resilient, green, and digital economy and the measures for digitalization…

Consultation response

SFS Suomen Standardit ry, 2 Sept 2025

Please find attached SFS Finnish Standards comments on the Omnibus Regulation aligning product legislation with the digital age. Our comments regard specifically the Commissions initiative related to common specifications.

Consultation response

European Committee of Electrical Installation Equipment Manufacturers, 29 Aug 2025

Please find attached CECAPI's position to the European Commission's call for feedback in view of the Omnibus Regulation Aligning product legislation with the digital age.

Consultation response

AFECOR - European Control Manufacturers Association, 8 Aug 2025

Afecor, the European Control Manufacturers Association, broadly supports the Omnibus proposal aimed at amending several directives and regulations concerning digitalization and common specifications. We believe that fully leveraging digital product information can significantly contribute to…

Consultation response

, 7 Aug 2025

Representing the entire value chain of paper in Belgium (forest owners, pulp, paper, and cardboard producers and processors, printers, as well as newspaper, magazine, and direct mail publishers), Papier.be welcomes the Commissions approach to simplify EU legislation with the objective of reducing…

Consultation response

Bundesverband Druck und Medien e. V., 23 Jul 2025

The BVDM, the leading association representing the German printing and media industry, supports the goals of reducing bureaucracy and promoting digitalization. However, we strongly oppose the proposed elimination of printed user instructions and safety information for consumer products. Printed…

Consultation response

EUROGIP, 15 Jul 2025

Please find attached our comments related to digital instruction for use in PPE regulation (2016/425/EU). Some of those comments could apply on the other regulations concern by Omnibus initiative. We understand that the main objective is to authorize digital instructions and information,…