Bringing Product Legislation to the Digital Age: APPLiA's Input to the INI Report

APPLiA has submitted its input to the European Parliament’s Own-Initiative Report on A New Legislative Framework for Products Fit for the Digital and Sustainable Transition.

The New Legislative Framework (NLF) has played a fundamental role in supporting product safety, sustainability, and the smooth functioning of the Single Market. However, to remain fit for purpose, the NLF must evolve in line with the digital age and the EU’s sustainability objectives.

With decades of experience contributing to EU product legislation, home appliance manufacturers recognise the importance of updating the framework to meet new realities, while preserving its core strengths.

In our recommendations to the European Parliament, we highlight the need to:

Recognise online marketplaces as economic operators.  

Over 4 billion packages are delivered to the EU with many of them being non-compliant. For example more than 400 products coming outside of the EU were listed under the "electrical appliances " category in the EU’s Safety Gate system, with over 200 posing significant risks such as burns or electric shock. This puts European manufacturers at a disadvantage, distorting the level playing field and posing risks to consumer safety. Many traders on those platforms do not have a legal entity within the EU, making enforcement more difficult. Including online marketplaces in the definition of economic operators in the NLF, online marketplaces would resume greater responsibility and ensure more effective compliance.

Set maximum deadlines for standardisation requests and objections.

The delayed publication of harmonised standards in the OJEU remains a major issue. The delays are undermining industry competitiveness, weakening the level playing field, and limiting the ability of authorities to enforce compliance. The result is higher levels of non-compliant products circulating across Europe, putting EU companies at a disadvantage. Without harmonised standards the manufacturers rely on other international standards or expensive certification. Standards also enable effective self-assessment by allowing a presumption of conformity, removing the need for costly and time consuming third-party verification.

Ensure effective and appropriate use of the Digital Product Passport.

The implementation of the DPP must be efficient, minimising burdens on businesses while effectively supporting the circular economy. The DPP should remain a tool rather than an end in itself, avoiding unnecessary information overload that could hinder its usability and effectiveness. It is important to consider that establishing the DPP requires significant investments while effective digital tools are already established.

Permit electronic formats for safety and user documentation.

Safety-related documentation such as user manuals and declarations of conformity should be allowed to be displayed to users only in electronic formats. Home appliance manufacturers are spending up to 170 million euros on paper manuals while 1 in 5 users look for the information on their website. Allowing to display information digitally and removing the paper requirement would significantly reduce costs as well as the environmental footprint. Keeping in mind that the information is already available online and would require additional resources.

Harmonise the definitions of "remanufacturing," "refurbished," "maintenance" with the ESPR.

The last legislative mandate introduced several laws promoting sustainable consumption and the circular economy, bringing forward new concepts and definitions. The definitions of "remanufacturing," "refurbished," and "maintenance" should be harmonised in alignment with the Ecodesign for Sustainable Products Regulation to avoid regulatory fragmentation and ensure a uniform application of sustainability requirements across the entire supply chain.