Orgalime’s questions on the implementation of Directives aligned with the New Legislative Framework

Published: 15 September 2014

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

Orgalime welcomes the European Commission’s plan to organise seminars on the implementation of Low Voltage Directive (LVD 2014/35/EU), Electromagnetic Compatibility Directive (EMC 2014/30/EU) and Radio Equipment Directive (RED 2014/53/EU). We consider that such seminars could contribute to a more consistent implementation of the Directives by market surveillance authorities and economic operators across the EU and hope that additional seminars for all the other Directives aligned with Decision 768/2008 will follow.
However, manufacturers have also raised an important number of horizontal questions. Therefore, we invite the Commission to organise a seminar which would tackle horizontal questions. We strongly believe that these questions should not be dealt with during the Directive-specific seminars, as this could result in diverging interpretations among the Directives.
Moreover, we expect the Commission to revise parts of the Blue Guide to include the seminars’ results and eliminate any remaining room for misinterpretation of the aligned provisions.
Therefore, please find included in the annex a list of points where the text of the Blue Guide could confuse or misinform the reader.

Related Position Papers

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]

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]