APPLiA response to the Call for Evidence on the Digital Omnibus

With the launch of the consultation on the upcoming Digital Omnibus, APPLiA seizes the opportunity to draw attention to critical elements that will shape the future of Europe’s digital regulatory landscape. This contribution builds on the association’s consistent engagement across three previous consultations, mentioned in the Call for Evidence, ensuring continuity in its positions and reinforcing our recommendations

In this new recommendation, you will find APPLiA’s analysis of the upcoming Digital Omnibus and its impact on the sector, with a focus on four key areas:

1. Artificial Intelligence Act – the need for a clearer definition of “AI systems,” avoiding unjustified high-risk classifications, and ensuring consistency with existing product safety rules.

2. Data Act – concerns over weak safeguards for trade secrets, disproportionate retroactive obligations on legacy products, and uncertainties around the definition of data holders.

3. Cybersecurity Act – the importance of maintaining a voluntary and flexible certification system, driven by industry standards and transparent stakeholder involvement.

4. Interplays across digital legislation – the risks created when AI, data, and cybersecurity rules overlap with sectoral frameworks, leading to duplication and compliance conflicts.

Through these recommendations, APPLiA reaffirms its commitment to fostering a regulatory environment that is simpler, more consistent, and innovation-friendly, one that enables Europe’s home appliance industry to deliver sustainable solutions, strengthen competitiveness, and contribute to the EU’s digital and green ambitions.