Photo Source: EC - Audiovisual Service
The EU Commission released today its 6-pillar strategy to address existing barriers of the Single Market hampering its correct functioning and preventing businesses and citizens from benefiting from its full potential.
Paolo Falcioni, APPLiA Director General, commented: “The latest geopolitical developments put the spotlight on the need to reinforce Europe’s internal strength. Every day, our member companies ship thousands of appliances across the EU and manage over half of the continent's e-waste, demonstrating our profound reliance on a truly robust and effective Single Market to safeguard our long-term reputation and global competitiveness. The Strategy's focus on tackling two decades of fragmentation and its emphasis on regulatory convergence and harmonisation fully align with APPLiA’s core priorities. However, while the Strategy puts the Digital Product Passport (DPP) at the forefront of digital transformation, it's vital the EU first fully leverage existing tools for information sharing in a data-driven Single Market, preventing unnecessary duplication and added complexity for EU businesses."
The Commission's vision for a stronger and more united Single Market hinges on the removal of the 'Terrible Ten' barriers, including the proposal for harmonised packaging, labeling, and waste rules and an overall focus on harmonisation. These are vital steps towards reducing fragmentation and its associated costs. Differing regulations and standards across EU countries force manufacturers to develop diverse product versions, impeding the free movement of goods. This fragmentation is evident in the EU home appliance sector, where differing national sustainability rules over the past decade have inflated production costs and consumer prices, undermining the Single Market's effectiveness. Without harmonisation, this trend will continue to impede business growth and European economic integration.
APPLiA firmly supports the strategy's emphasis on improved alignment between national and EU regulations and the planned Single Market Barriers Prevention Act. Divergent implementation creates unnecessary complexity, legal uncertainty, and increased costs, hindering the free movement of goods and slowing the transition to a circular economy.
The Strategy rightly reports that the current standardisation process is often too slow and unresponsive to market needs. This is particularly problematic in our sector, where innovation in energy efficiency, smart technologies, durability, and reparability is rapid. Delays in standardisation create legal uncertainty and hinder the adoption of new technologies.
The strategy's emphasis on easier access to harmonised standards and the aim for the EU to be a global standard-setter are therefore vital. We look forward to the revision of the New Legislative Framework (NLF) and Standardisation Regulation, planned for Q2 2026, and emphasise the need for a truly concurrent process between the development of legislation and the necessary harmonised standards. Clear deadlines, efficient objection procedures, and greater involvement of industry experts in the standardisation process are key to ensure standards are technically sound, market-relevant, and available when legislation becomes applicable, allowing industry to plan and invest with confidence.
The Strategy's push for a data-driven Single Market can significantly boost efficiency across the appliance sector. While we recognise the value of tools like the Digital Product Passport (DPP) for information-sharing, existing platforms such as the EPREL database should be fully leveraged and optimised first. It is crucial to avoid creating parallel structures that further increase complexity and costs.
Before rolling out the DPP through sectoral legislation and revisions of the New Legislative Framework (NLF), the Commission must conduct a thorough impact assessment. This assessment should evaluate the DPP's real added value, cost-effectiveness, and complementarity with existing tools, specifically on a product-by-product basis.
Similarly, shifting to digital labeling and digital user manuals, if thoughtfully implemented, can empower consumers and reduce environmental impact, potentially saving EU businesses over €100 million. Here, it is important to emphasise that all relevant documentation—such as product information, safety instructions, and user manuals—is already available and easily accessible online. Therefore, no additional resources would be required, and efforts should focus on avoiding duplication and unnecessary complexity.
Ensuring that product rules are up-to-date and that products comply with those rules is paramount for consumer safety, fair competition, and the integrity of the Single Market. We support the Commission's efforts to modernise product legislation. However, we stress the need for effective market surveillance, particularly in the online space. The surge in non-compliant products sold online poses a significant threat. Enforcement must be robust and consistent across Member States. To this end, the rapid establishment of an EU Market Surveillance Authority would significantly strengthen our collective ability to safeguard consumers and uphold fair competition.
Effective EU-level coordination and governance are necessary, and monitoring imports from third countries is critical to ensure a level playing field where all products, regardless of origin, meet the same high EU standards for safety, energy efficiency, environmental performance, and durability. This requires a robust framework of impactful, proportionate, and consistently applied penalties for non-compliance, defined at the EU level and enforced by Member States.
To ensure effective enforcement and close the loop in the current legislation, online marketplaces should resume greater responsibility for products sold on their websites and be recognised as economic operators.
Given the significant volume of appliances reaching end-of-life, efficient and harmonised EPR and waste rules are crucial to ensure that producers can effectively and efficiently organise and finance the collection, sorting, treatment, and recycling of their products across a Single Market for Waste. Furthermore, harmonised waste rules and standards will lead to better use of raw materials and reduce Europe's dependencies.
APPLiA welcomes the anticipated proposal in the draft Omnibus in Q4 2025 to reduce reporting obligations. We also look forward to the Circular Economy Act in Q4 of 2026, which should bring further harmonisation and simplification of EPR requirements. It is essential to strike a balance between environmental responsibility, the need to prevent free-riding, and minimising disproportionate administrative and financial burdens on producers, while ensuring the development of well-functioning, transparent, and competitive markets for secondary raw materials.
Read Our 12 Recommendations to Enhance the Single Market
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