European Commission’s evaluation of the New Legislative Framework on industrial product labelling

The EU executive recently run a public consultation on the evaluation of the new legislative framework.

We have identified several points for improvement in response to the Commission’s call for evaluation. Briefly, we consider the current rules on industrial product labelling to be fit for purpose. Yet we expect the update to:

1. Explicitly define specific references to existing EU-27 and UK standardisation systems, something that is lacking from the current rules.

2. Provide clear guidance to companies on the extent and exact instances where non-AI products are or can be modified by AI.

3. Standardise the display of additional product information through QR links directing users’ instantly to products’ specific CE mark. This would significantly modernise the framework.

4. Establish a common EU/UK database linked to both jurisdictions and their required trademarks. This would facilitate compliance of companies active in EU-27 and UK markets with the regulation and reduce regulatory costs.

5. Avoid incorporating drastic regulatory changes to prevent hardship and uncertainty for companies.

6. Adopt safety, health, energy efficiency and environmental requirements for light and shading management and controls. The legislation should specifically incorporate the waste directive on electrical waste and electronic equipment.

7. For those companies operating in the EU-27 and UK, exclude from the legislation requirements to add unnecessary evident and obvious labelling information. For example, the addition of a EU address, authorised representative, and/or the setting of a legal entity in the EU for a company based in the UK.