APPLiA's feedback on "Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Directive"

We acknowledge the Commission’s intention to promote digital user manuals as a means to reduce paper consumption, lower costs, and minimise CO₂ emissions. While digital instructions and safety information are already common practice, current legislation still obliges the home appliance sector to provide printed instructions and safety information with each unit. We therefore welcome any move that grants manufacturers the choice between digital and paper formats.

However, the current proposal does not yet constitute a genuine simplification for our sector (home appliances are consumer products). It continues to mandate that safety information be provided in paper form with each product unit. This requirement would necessitate separating safety information from general usage instructions, a process that is not only burdensome but also creates legal ambiguity.

Allowing a fully digital manual, including safety instructions, could yield significant cost savings, estimated between €40 up to €170 million. In addition, from an environmental perspective, avoiding the printing of millions of unnecessary pages would be a critical step forward. 

Fully digital manuals come with several advantages. They ensure barrier-free access, support the integration of videos and hyperlinks to additional resources, and offer the convenience of being impossible to lose. We fully support giving consumers the option to request a physical copy of the documentation if explicitly desired. We also agree to limit this option to the first six months following the purchase of a product.

To fully unlock the potential for simplification, we believe that safety information can be delivered electronically, potentially in even more user-friendly formats, such as animations. But keeping in mind the safety of the consumer as the utmost objective, this should be done in a second phase.

Last but not least, notes the omission of two relevant pieces of legislation from the list of omnibus laws: the General Product Safety Regulation and the Energy Label Regulation. The latter, in particular, holds substantial potential for cost and environmental savings.

Under the current EU E-label Regulation 2017/1369, a printed, full-colour energy label must be provided with each appliance placed on the market, even though only a small fraction of appliances are physically displayed in stores, where the label is actually needed. The average cost of producing and handling a single energy label is 0.20€. If we estimate that only 1 in 500 printed labels are actually used as intended, this results in an effective cost of €100 per used label (€0.20 × 500). Approximately 100 million labelled home appliances, cooling, and heating units are introduced to the EU market each year. This results in significant waste of printed colored paper that leads to costs of at least 20 million euros, only for our sector.

Given that energy labels are already available digitally via the EU EPREL database, on manufacturers’ websites, and in all online appliance listings, we see strong potential for allowing energy labels to be provided in digital format only. This should be explored as a viable simplification opportunity with significant impact.

In summary

• The proposal represents a step in the right direction, enabling both cost savings and a reduction in CO₂ emissions.
• However, it does not yet offer true simplification from an operational perspective. Companies would still be required to separate safety information from usage instructions, creating additional workload and legal uncertainty.
• The digitalisation of safety instructions should be clearly foreseen as a next step, allowing for more effective and user-friendly communication.
• The scope of the omnibus should also be expanded to include the General Product Safety Regulation (GPSR).
• We strongly recommend unlocking the full potential of the digital energy label by amending Regulation 2017/1369 without delay.

Common Specification 

The European Union's conformity system for household appliances has for decades relied on the robust system of the current New Legislative Framework (NLF), with legislation defining legal obligations, and harmonised standards providing the technical means to demonstrate compliance 

The recent Omnibus IV legislative package would fundamentally alter this approach by introducing Common Specifications across 22 product-related regulations and directives. The suggested approach would empower the European Commission to directly adopt all the technical specifications and detailed technical methods, and thereby completely bypass the standardisation bodies and processes. This represents a significant departure from the New Approach that has underpinned the growth and success of the EU single market for decades.

The Commission’s proposal states that Common Specifications should only be used if standardisation efforts fail. We agree with having such a fallback mechanism; however, stronger safeguards are needed to ensure that common specifications are used as a last resort. Common specifications should only be introduced if standardisation has demonstrably failed within a defined timeframe, such as two years.

Also, the Commission should be required to always first request and attempt to establish the standards through CEN and CENELEC. This concept is already realised in Regulation (EU) 2023/1230 (‘Machinery Regulation’), which has recently introduced Common Specifications.

We underline that the Machinery Regulation has been adopted through the ordinary legislative procedure and thus provides a solid and legitimate basis upon which to build. Below, we therefore propose the following text copied from the‘ Machinery Regulation and amended as a constructive solution aligned with the Commission's objectives. 

We firmly believe that, for reasons of democratic integrity, this Omnibus Regulation must ensure that Common Specifications are subject to the same rigorous principles as traditional standard development, namely, reliability, expertise, openness, transparency, and consensus. These principles are essential to uphold the credibility and effectiveness of EU technical regulation, which underpins a well-functioning internal market, safeguards consumer safety, and supports environmental protection.

In summary 

• The introduction of common specifications represents a departure from the successful approach that was created with the New Legislative Framework (NLF).
• Stronger safeguards are needed to ensure that common specifications are used under well-defined, exceptional cases as a last resort, as stated by the Commission.
• Such safeguards are already well formulated in Regulation (EU) 2023/1230 (‘Machinery Regulation’) and would, with some further adjustments, meet the objectives of “last resort” spelt out by the Commission.