New Legislative Framework (NLF) - Interpretative Fiches

Published: 18 March 2011

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

Further to its 11 October 2010 position paper, Orgalime is pleased to provide a set of concrete recommendations for the smooth application of product legislation that applies the rules of the New Legislative Framework (NLF) for the placing of products on the Community market. We hope that the Commission and member states will find inspiration into them with a view to revise the valuable EC Blue Guide to the 'implementation of Directives based on New Approach and Global Approach'.

These interpretative fiches are addressing the following issues:

Obligations of economic operators:
Fiche n°03: Translation requirements, in particular of the Declaration of Conformity (DoC)
Fiche n°04: Traceability requirements: Conditions for affixing the name and address of the manufacturer and/or the importer on the product itself
Fiche n°17: How far the obligation of the importer should go?

Fiche n°05: Scope: clarification of the definition of accreditation for the purpose of notification

Conformity assessment (CA):
Fiche n°08: Proportionality in the application of CA procedures, esp. for small and medium sized companies
Fiche n°09: Requirements for accredited in-house CA bodies with a view to ensure fair competition between in-house accredited bodies and other bodies vis-à-vis notification
Fiche n°10: Clarification of the definitions with regard to the application of CA modules

Market surveillance:
Fiche n°11: Content of the Technical Documentation to be provided on request to authorities
Fiche n°15: There should be no enforcement incentive to third-party certification.

Related Position Papers

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]

Call to preserve the EU ‘New Approach’ as one of the Single Market’s best regulatory techniques [8 March 2017]

For an efficient market surveillance of online trade: suggestions for the better handling of fulfilment centres in the enforcement of EU harmonisation legislation [13 February 2017]

Letter to European Commissioners on the Mutual Recognition Agreement between the EU and Switzerland [1 February 2017]