EGMF Position Paper on Omnibus IV

EGMF has published its response to the European Parliament’s compromise amendments on Omnibus IV. While the initiative aims to simplify EU product legislation, several provisions risk creating new burdens and inconsistencies.

1. “Direct access” to digital Declarations of Conformity (DoC)
   The current wording could force manufacturers to regenerate QR codes and reprint documentation every time a DoC is updated, creating unnecessary administrative and environmental costs. EGMF calls for a practical interpretation that allows a landing page where authorities can retrieve the correct DoC using simple product information.
2. Extended deadlines for requesting paper instructions
   The European Parliament proposal introduces obligations based on the term “consumer,” which is not defined in several relevant regulations, making the requirement unenforceable. EGMF urges policymakers to avoid obligations that depend on user categories manufacturers cannot verify.
3. Short transition period for the Machinery Regulation
   Unlike other NLF legislation impacted by the Omnibus IV, the Machinery Regulation is the only one with left with no transitional period. EGMF requests a harmonised 24 month transition period, aligned with other legislation.
4. Digital only DoC requirement
   While EGMF strongly supports digitalisation, a mandatory digital only DoC would remove necessary flexibility for SMEs, small production runs, and custom made machinery. EGMF advocates maintaining the option to provide the DoC in either digital or paper format.