Less paper, more standards: The case for digitalisation and for repairing, not replacing, Europe’s standardisation system

Executive summary 

The fourth omnibus proposal touches on two important areas for European industry: the digitalisation of product documentation – which can reduce burdens for companies and take forward Europe’s digital transformation – and the generalisation of common specifications across EU product laws. Whilst we see clear potential in the former, the latter would sideline Europe’s proven standardisation system. 

The horizontal introduction of common specifications should be withdrawn. Europe’s challenge is not a lack of standards but the persistent failure of the citation process. Industry continues to produce robust, internationally aligned harmonised standards, many of which remain uncited for years due to procedural bottlenecks and legal over-interpretation. 

Expanding the use of common specifications would only entrench these problems. It would hand the Commission wide discretion to decide when to bypass harmonised standards, risk making common specifications the default tool rather than the exception and undermine Europe’s public–private standardisation model. Unlike harmonised standards, common specifications cannot guarantee openness, inclusiveness or international coherence, nor can they be maintained at the pace of technological progress. The right solution is to repair the citation system, not replace it. 

By contrast, moving away from paper-based requirements has clear benefits for companies, consumers and the environment. By reducing printing, translation and distribution costs, digital documentation frees up resources that can instead be invested in innovation, while also cutting waste and supporting the EU’s sustainability objectives. The proposal already takes some useful steps, but it can go further: 

• Aligning with existing legislation: The amended directives must be consistent with the Market Surveillance Regulation (MSR), and recently adopted acts such as the AI Act and Cyber Resilience Act (CRA) should also be updated to remove conflicting paper requirements.

• Modernising contact details: Support the introduction of a digital point of contact, harmonise terminology and remove the outdated requirement for a postal address on products. Where a Digital Product Passport (DPP) applies,4 contact details should be provided there. 

• Providing flexibility in documentation: The DPP should be the default channel, but not the only one. Companies must be free to provide information via other digital means, such as websites or QR codes. 

• Streamlining QR code rules: Avoid multiple, overlapping QR code obligations and work towards an interoperable international standard. 

• Phasing out paper: Permit digital documentation without restriction. Where paper is genuinely needed, a short one-page safety sheet is sufficient. 

• Enabling e-labelling: Allow CE marking and other regulatory information to be displayed digitally on products with integrated screens, as already done in other major markets.