25 Jun 2014

DIGITALEUROPE initial comments on - A vision for the internal market for industrial products

DIGITALEUROPE initial comments on - A vision for the internal market for industrial products

General observations

DIGITALEUROPE welcomes the Commission’s ambition to strengthen the internal market through the review of the Union legislation on industrial products. The markets continuously change and accordingly the internal market legislative framework has to adapt to these changes or has to be made more adaptable to evolutions where necessary.

The Commission communication acknowledges the “overriding need to minimise administrative burdens, especially for SMEs” and aims for simplification of rules. Our experience from changes announced as ‘cutting red tape’ is however that the regulatory burdens have often increased for our sector. This is partly due to the application of horizontal principles for all sectors, without due consideration of its proportionality for any given sector.

An example is the New Legislative Framework (NLF) from 2008, which in itself added new administrative requirements without removing existing ones. The recent agreement within the ’Alignment package’ and the revised Radio Equipment Directive applied a stringent interpretation of the NLF, while admittedly removing one obligation that had been introduced through NLF (the case of single DoC).

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