Consumer Products Safety: More consistency needed across the board

Published: 3 June 2013

Policies & Issues: Internal Market - Compliance, Standards & Enforcement

Orgalime welcomes the European Commission’s ambition to improve the General Product Safety Directive (2001/95/EC – 'GPSD') with its proposal for a Regulation on Consumer Product Safety (CPSR).  However, we believe that ensuring consumer product safety would be simpler and more consistent with European harmonisation legislation pursuing consumer safety if: 

1. The CPSR scope is clearly restricted to non-harmonised consumer products only

2. ‘Consumer products’ and 'products for exclusive use by professionals' are distinguished

3. The principle of non-retroactivity of the law is confirmed

4. Aspects for assessing the safety of products are improved, and in particular by providing:

  • A definition of 'safe product'
  • Prioritisation of aspects for assessing product safety
  • Clarification of 'vulnerable consumers' and consumer expectations concerning safety.

5. The indication of origin is removed

6. Administrative requirements for manufacturers of non-harmonised products are significantly
lightened, and especially by removing or limiting:

  • The requirement of 'technical documentation', which is bureaucratic overkill for most non-harmonised consumer products
  • Identification elements, which should apply only for some few categories of products after assessment of their cost-effectiveness for improved traceability
  • Article 15 on a product traceability system is deleted

7. The European Commission’s decisions are addressed to manufacturers (not only standardisers), for whom standards should remain a voluntary tool

8. Penalties are removed because they are redundant as they are included in the draft Market Surveillance Product Regulation (MSPR), or at least these should be aligned with it.

Related Position Papers

Internal Market: Suggestions for a revision of the Blue Guide on the implementation of EU product rules 2016 [27 January 2020]

Internal Market: Shaping a New Deal for the Single Market: Harmonised standards in support of a competitive European industry [27 January 2020]

Internal Market: For a restored mutual trust in a market-relevant European Standardisation System [24 September 2019]

Towards effective, efficient EU market surveillance: all for a level-playing field without additional burdens for legitimate manufacturers [6 December 2018]

For simpler compliance with and smarter enforcement of EU harmonisation legislation: Orgalime comments on the amendments of the European Parliament to the Commission proposal on Compliance and Enforcement [6 July 2018]

For simpler compliance with and smarter enforcement of EU harmonisation legislation: comments on the Commission proposal for a Regulation laying down rules and procedures for compliance with and enforcement of Union harmonisation legislation on products [5 April 2018]

Orgalime calls for improved enforcement of harmonisation legislation for safe and compliant products [21 February 2018]

Simpler and more effective market surveillance of products is urgently needed [21 September 2017]

Orgalime guidance on the manufacturer’s obligations for the combination of a machine with radio equipment [12 June 2017]