Amending certain Directives as regards digitalisation and common specifications (Omnibus IV)

We appreciate the opportunity to provide feedback on the omnibus proposals for a directive and a regulation to align product legislation with the digital age. Free and open source software (FOSS) is, by many measurements, the largest category of software today. Europes IT systems and European innovation are powered largely by FOSS. Eclipse Foundation is the largest FOSS foundation based in Europe.

Apple response - Omnibus IV proposal Table of Contents 1. 2. 3. Introduction On the benefits of digitization for Europe A more ambitious EU plan - Extending Omnibus IV s scope A. Regulatory Information B. Labels C. Consumer information 4. Ensuring regulatory consistency - Avoid new complex physical requirements 5. Conclusion 1.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Raising standards for consumers POSITION PAPER ANEC reply to the European Commission proposals on Omnibus Directive and Regulation Aligning product legislation with the digital age Contact: [name removed] [email removed] [name removed] – [email removed] The European Consumer Voice in Standardisation aisbl ANEC is supported financially by the European Union & EFTA Ref: ANEC-WP1-2025-G-051 02/09/2025 Rue d’Arlon 80 –…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Definition and Concerns "Common specifications" are defined in the proposed directive on digitization and alignment of common specifications as an alternative to harmonized standards. But their development is seen as a threat to the current European Standardization System (ESS).

Common specifications The ZDH is convinced that in any case common specifications should only be consid-ered as a last resort measure. The primacy of stakeholder driven harmonised stand-ards must be preserved as the main way to facilitate compliance and provide presump-tion of conformity.

ITI intends to respond to the recent amendments proposed by the European Commission as part of the "Omnibus IV" package, which aims to introduce changes across a series of regulations and directives. In particular, the proposal seeks to advance two horizontal objectives: (i) promoting the digitalization of product-related compliance obligations, and (ii) introducing the possibility to rely on common specifications…

Observations on COM (2025) 503 URL ‘Have you say’: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14698Omnibus-Directive-Aligning-product-legislation-with-the-digital-age_en Observations from the French liaison committee on Pressure Equipment Directive 2014/68/UE and on Simple Pressure Vessel Directive 2014/29/UE. I.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

European Commission Feedback from The Danish Agency for Digital Government on the draft Omnibus Directive Overall The Danish Agency for Digital Government supports the proposed regulation by the European Commission on digitalization of paper requirements and common specifications. However we would like to draw your attention to the differences in the two provisions below.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

EFIC welcomes the possibility to comment on the draft implementing Regulation as regards digitalisation and common specifications, that has been put forward in the framework of the Omnibus IV package. We are a creative, versatile and dynamic sector, composed mainly by SMEs and microenterprises. Our industry is part of a complex value chain, with a broad range of designs, products and materials.

A single, predictable conformity path is essential for EU competitiveness and effective market surveillance. METSTA welcomes the opportunity to contribute to the Omnibus package. METSTA (Mechanical Engineering and Metals Industry Standardization) is a strategic standardization partner for Finnish technology and export industries.

SPECTARIS e. V. Berlin | September 3rd 2025 POSITION Ref. Ares(2025)7177579 - 03/09/2025 SPECTARIS Position Consultation feedback On Proposal for the Omnibus Directive Aligning product legislation with the digital age - COM(2025)503 Considerations for the Optical Sector and Personal Protective Equipment About SPECTARIS SPECTARIS is the German industrial association for optics, photonics, analytical, and medical…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We support the removal of user manuals for professional protective clothing. The user manual is not kept by the employee during their work activities, so they won't consult it while working. Professional PPE (Personal Protective Equipment) is provided by the employer, who remains responsible for training employees and for the correct use of the PPE.

Please find attached JBCEs position paper on the proposals for a Directive on the digitalisation and alignment of common specifications under the Omnibus IV package. JBCE welcomes the Commissions initiative and highlights the need to more boldly embrace digitalization approaches, remove physical requirements, ensure horizontal alignment across the NLF, and prioritise international standards over EU-specific common…

Ecommerce Europe is grateful for the opportunity to provide feedback on the proposals for a Regulation and a Directive on Aligning product legislation with the digital age. While our association is overall supportive of tapping digital solutions to simplify reporting obligations, the proposals raise some procedural and practical questions.

FINAL DRAFT – 29 AUGUST 2025 Less paper, more standards: The case for digitalisation and for repairing, not replacing, Europe’s standardisation system Executive summary The fourth omnibus proposal touches on two important areas for European industry: the digitalisation of product documentation – which can reduce burdens for companies and take forward Europe’s digital transformation – and the generalisation of common…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Policy paper on Omnibus IV (Paper vs. Digital documentation & Common Specifications) 1/10 Paper vs. Digital documentation We acknowledge the Commission’s intention to promote digital user manuals as a means to reduce paper consumption, lower costs, and minimise CO₂ emissions.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ELA2025-038 2025-06-26 Formatted: Font: Arial Proposed amendment of the Lifts Directive 2014/33/EU The European Commission has introduced an omnibus proposal for a directive COM(2025)503 updating sectoral laws. ELA wishes to share industry comments on the proposed amendment of the Lifts Directive.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The IKEA product range includes over 9,500 products sold in 63 markets, and we actively participate in over 100 standardisation committees. Drawing on decades of experience, we welcome the European Commissions ambition in Omnibus IV to modernise EU product legislation and reduce compliance burdens.

VDMA welcomes the opportunity to comment on the Omnibus proposals COM(2025)503 and COM(2025)504 and would like to address the element for Common Specifications only. In light of the increasing European Commissions intention to use Common Specifications (CS) as a regulatory fallback mechanism to harmonised European Standards (hEN) within the European Single Market, and their embedding in both new and revised legal…

EPTA appreciates the opportunity to give feedback. We support: A homogenous approach across product legislation Digitalisation of product information requirements to fit the digital age Digital only communication with authorities and notified bodies We propose to: Add missing product legislation to unleash full benefits of digitalisation and simplification Delete specific requirement for the OND to avoid…

DI appreciates the opportunity to comment on targeted amendments permitting the use of common specifications and paperless documentation within existing NLF legislation, namely COM(2025) 503 final and COM(2025) 504 final. Summary: DI supports the Commissions proposal to enable digital fulfilment of information obligations.

Cecurity.com calls on the Commission to preserve the integrity and credibility of the European standardisation system, building on: legal certainty, stakeholder trust, technical robustness, and international compatibility.

Filed in French · English published by the European Commission

Thank you for giving us the opportunity to react to this proposal. eFutura is a professional association that brings together and accompanies digital players around the document and the Data. We are involved in standardisation work and influence the evolution of French (AFNOR), European (ETSI and CEN) and international (ISO) standards in our fields of electronic archiving, Cyber Security, Electronic Facture…

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CERTIFICALL’s reply to the consultation on the proposal for a Omnibus Directive to align product legislation with the digital sector September 2025 Introduction CERTIFICALL thanked the European Commission for the opportunity offered to contribute to the public consultation on the proposal for a Omnibus Directive.

Filed in French · English published by the European Commission

Brussels, 02 September 2025 LightingEurope Position on the Omnibus IV proposal for a Directive and a Regulation as regards the digitalisation and alignment of common specifications Introduction The following input presents LightingEurope’s position to the recent European Commission’s (EC) proposal for a Directive and a Regulation as regards the digitalization and alignment of common specifications.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Italian Electrotechnical Committee (CEI), Italys national standardization body for the electrotechnical, electronic, and telecommunications sectors, welcomes the consultation on the proposed Omnibus Directive, aimed at updating product legislation to meet digital challenges.

The German Commission for Electrical, Electronic and Information Technologies (DKE) a business unit from the wider VDE Group, welcomes the European Commissions aim to modernize product legislation through the Omnibus IV simplification package, and to ensure that the European Single Market remains fit for the digital age.

Please find the attachment for our full comment. We, electric equipment manufacturers coalition of medical devices, and analysis, measurement, test, control and monitoring instruments which are classified into category 8 and 9 of EU RoHS Directive in Japan, which are listed below, would like to express the gratitude of having the opportunity of stating our opinion.

CEN and CENELEC support the European Commission's efforts to harmonize criteria for issuing common specifications. This is in principle positive, but it is crucial that the process is done in a way that ensures the involvement of a broad range of stakeholders, from societal stakeholders to Member States and industry (the actors who will later enforce and follow the specifications to gain access to the internal…

Raising standards for consumers POSITION PAPER ANEC reply to the European Commission proposals on Omnibus Directive and Regulation Aligning product legislation with the digital age Contact: [name removed] [email removed] [name removed] – [email removed] The European Consumer Voice in Standardisation aisbl ANEC is supported financially by the European Union & EFTA Ref: ANEC-WP1-2025-G-051 02/09/2025 Rue d’Arlon 80 –…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The Federation of Digital Confidence Third Parties (FNTC), which brings together more than 160 stakeholders in the digitalisation of digital services providers, regulated professions, experts, users and start-ups, thanks the European Commission for the opportunity offered to contribute to the public consultation on the proposal for a Omnibus Directive.

Filed in French · English published by the European Commission

The European Telecommunications Standards Institute (ETSI) is pleased to provide its feedback on the European Commissions Proposal for an Omnibus Directive aligning product legislation with the digital age, aimed at modernising and simplifying existing product safety and compliance directives, such as Directive 2014/53/EU on Radio Equipment (RED), and Directive 2014/30/EU on electromagnetic compatibility (EMC).

EuroCommerce warmly welcomes the Commissions initiative on digitalization of paper requirements as an important step toward reducing compliance burdens and modernising EU product legislation for the digital age. Transitioning away from paper-based obligations can unlock cost savings, reduce waste, lower resource use, automatise compliance and reporting, and drastically improve information flow across supply chains.

Lif the research-based pharmaceuticals industry in Sweden is grateful for the opportunity to give our remarks on the proposed regulation and directive with the goal of aligning product legislation with the digital age. The life sciences sectorcovering pharmaceuticals, medical devices, in vitro diagnostics, medical software, and biotechnologyis a strategic industry for Sweden.

As a global provider of industrial automation solutions, Balluff GmbH fully supports the European Commissions initiative to enable the digital provision of accompanying product information. This marks an important step toward digitalization, sustainability, and legal clarity.

Austrian Standards International supports the European Commission's efforts to harmonise criteria for issuing common specifications. This is in principle positive, but it is crucial that the process is done in a way that ensures the involvement of a broad range of stakeholders, from societal stakeholders to Member States and industry (the actors who will later enforce and follow the specifications to gain access to…

Submission On Call for Evidence: “Omnibus Directive Aligning Product Legislation With The Digital Age” Table of Contents 1. About The MWF 2 2. Introduction 2 3. General Comments 2 4. Comments on Selected Specific Provisions 3 I. II. 5. ‘Article 11 - Amendments to Directive 2014/53/EU’ in ‘COM(2025) 503 final’ 3 ‘ANNEX XI’ in ‘COM(2025) 503 final – ANNEXES 1 to 13’ 11 a.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Response to the Public Consultation on Omnibus Directive and Regulation Aligning product legislation with the digital age. CECAPI, the European association representing manufacturers of electrical installation equipment, welcomes the opportunity to contribute to the public consultation on Omnibus Directive and Regulation Aligning product legislation with the digital age.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The La Poste group, a major player in postal, logistical and digital services in France and Europe, is closely following developments in the European regulatory framework. The proposal for a Directive on digitalisation and common specifications raises major challenges for all industry and service operators, particularly in terms of participating in the definition of technological requirements and preserving European…

Filed in French · English published by the European Commission

THE EUROPEAN ASSOCIATION REPRESENTING SMEs IN STANDARDISATION COMMENTS SBS comments on the adoption of the Omnibus Regulation and Directive Aligning product legislation with the digital age (Omnibus IV package) August 2025 SBS welcomes the opportunity to provide feedback on the European Commission proposals for a Regulation and a Directive aligning product legislation with the digital age (Omnibus IV package).

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our group, the Japanese electric and electronic industrial associations (JP4EE), has been covering the regulations on substances in articles for many years. Therefore, our comments relate specifically to the proposed amendment to the RoHS Directive 2011/65/EU among many proposals in COM (2025) 503. We welcome that the European Commission is considering simplification of existing measures.

EUROMOT welcomes the consultation on the EC proposal for an Omnibus Directive Aligning product legislation with the digital age and also pleased to have the opportunity to submit our contribution regarding Article 2 of the proposal amending Directive 2011/65/EU (RoHS). We fully support the transition towards digital documentation and procedures.

2025-08-27 1/3 Response to the Public Consulta on on Omnibus Direc ve and Regula on Aligning product legisla on with the digital age. AFME, the Spanish associa on represen ng manufacturers of electrical installa on equipment, welcomes the opportunity to contribute to the public consulta on on Omnibus Direc ve and Regula on aligning product legisla on with the digital age.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Independent Retail Europe welcomes the European Commissions commitment to simplify rules and reduce the administrative burdens placed on EU businesses. We welcome the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the introduction of targeted regulatory exemptions for SMCs (even though, overall, we consider the impact of these measures on…

As a global leader in industrial automation, Pepperl+Fuchs warmly welcomes and strongly supports the Commissions initiative. We regard this as a forward-looking milestone in driving digitalization and embedding legal certainty, while at the same time advancing Europes sustainability goals.

Bitkom read the Commissions «Proposal for a [Directive/Regulation] [] as regards the digitalisation and alignment of common specifications» with great interest and would like to provide input. Shortly summarized, we believe: -> Common Specification should be designed as a clearly limited fallback option in alignment of Art. 20 of the Machinery Regulation and developed with industry involvement.

Please find attached AFNOR's response to the European Commission's consultation on the Omnibus Directive aligning product legislation with the digital age. It includes feedback from all categories of stakeholders, as gathered by the French Coordinating and Steering Committee of Standardization, notably consumers, as well as input from stakeholders in specific fields such as electrotechnologies and others.

Stellungnahme IV. Omnibuspaket: Vorschläge für eine Verordnung und eine Richtlinie im Hinblick auf Digitalisierung und gemeinsame Spezifikationen August 2025 Die Kommission Arbeitsschutz und Normung (KAN) begrüßt die Gelegenheit zu den Vorschlägen der Europäischen Kommission für eine Verordnung und eine Richtlinie im Hinblick auf Digitalisierung und gemeinsame Spezifikationen des IV.

Filed in German · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

The BVDM, the leading association representing the German printing and media industry, supports the goals of reducing bureaucracy and promoting digitalization. However, we strongly oppose the proposed elimination of printed user instructions and safety information for consumer products. Printed information is essential to ensuring safe usage, equal access, and environmental sustainability.

Intergraf warns against setting a digital only approach in EU product legislation. The practice applied to professional equipment under the Machinery Regulation should not be extended to consumer goods. At present, EU consumers receive printed instructions with their products, containing essential information on use, assembly, and repair. They are vital for product safety and consumer protection.

UL Solutions respectfully submits these comments in response to the proposal for a directive regarding digitalization and common specifications. UL Solutions recognizes the proposals value, and particularly its support for economic operators (EOs) and consumers.

EUROMOT and IMEC POSITION EUROMOT aisbl PRESIDENT A European Interest Representative · TVA BE 0599.830.578 · RPM Brussels EU Transparency Register Id. No. 6284937371-73 Dr Holger Lochmann A Non-Governmental Organisation in consultative status with the UN Economic Commission for Europe (UNECE) and the UN International Maritime Organisation (IMO) GENERAL MANAGER Dr Peter Scherm Page 2 of 6 2025-08-13 EUROMOT/IMEC –…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Please find attached the position paper of European Boating Industry (EBI) on the Fourth Omnibus Simplification Package in relation to the Recreational Craft Directive 2013/53/EU. EBI represents the recreational boating industry in Europe. It encompasses all related sectors, such as boatbuilding, equipment manufacturing, marinas and service providers.

Harmonised European standards (hENs) has fundamentally proven its value through the involvement of all relevant stakeholders. Yet, there may be some instances where hENs do not deliver on time and where common specifications may be appropriate to fill the gap.

We would like to ask that the final amending Directive be in line with the following proposals. 1.Common specifications should be removed altogether from Article 2 of the Proposed Directive (COM (2025) 503) (Proposed Amendment to Directive 2011/65/EU). Reason: Electrical and electronic equipment and machinery equipment are often subject to multiple product legislation.

Brussels 08/2025 Position Ref. Ares(2025)6776884 - 21/08/2025 Eurochambres position on IV Omnibus Simplification package Eurochambres supports the European Commission's simplification efforts and the goal of reducing administrative burdens on EU businesses. At the same time, the fourth Omnibus Simplification package presented on 21 May has a limited impact on the broader business community.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ZVEI German Electro and Digital Industry Association welcomes the opportunity to provide input to the European Commissions legislative process of an Omnibus Directive Aligning product legislation with the digital age. Please find attached our position paper with comments and suggestions from the German Electro and Digital Industry.

On behalf of VDDW e. V., the Association of the German Water and Heat Meter Industry, we would like to thank the Commission for the opportunity to comment on the proposed Omnibus Regulation aligning product legislation with the digital age.

Eurovent supports the Commission Omnibus proposals aimed at promoting digital-by-default practices. On the other hand, we are deeply concerned by the introduction of common specifications. We welcome the principle digital by default proposed by the Commission.

Consumer Right to a Paper Version Article 7, Pages 3031 While we support the principle of ensuring accessibility of product information to all consumers, the requirement to provide a paper version free of charge raises significant concerns from a practical and financial standpoint.

COMMENTS ON THE PROPOSAL FOR AN OMNIBUS DIRECTIVE ALIGNING PRODUCT LEGISLATION WITH THE DIGITAL AGE The National Federation of Electrotechnical and Electronic Companies (ANIE), within the Confindustria system, represents over 1,100 high and medium-high technology companies operating in the Electrotechnical and Electronic sectors, as well as industrial General Contractors.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As a manufacturer, we see the clear declaration of the applicable EU directives and regulations as an essential part of our product compliance. Our ultimate goal is to provide safe and marketable devices. It is crucial for us to ensure that regulatory requirements are practicable and can be implemented without unnecessary duplication.

Filed in German · English published by the European Commission

Position Paper 4 Omnibus Package Small Mid-Cap Enterprises and Digitalisation th July 2025 GENERAL COMMENTS From the point of view of the Austrian Federal Economic Chamber (WKÖ), a tangible simplification and reduction of the administrative burden of EU legislation for all companies must be achieved quickly in order to strengthen Europe's competitiveness.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ERF is the Spanish association of waste recyclers, and we have been involved in standardisation since 2010. Please find out the following: In the light of the proposal for European Omnibus legislation, the following elements should be considered: The European regulatory model based on the New Legislative Framework (NLF), complemented by Market Surveillance, has proven to be an ideal way to foster innovation and the…

Filed in Spanish · English published by the European Commission

Comentarios de Sedigas en respuesta a la consulta pública sobre la legislación europea Ómnibus Ante la propuesta de legislación europea Ómnibus se deben contemplar los siguientes elementos: ▪ El modelo regulatorio europeo basado en el Nuevo Marco Legislativo (NLF), complementado con la Vigilancia de Mercado, ha demostrado ser una fórmula idónea para fomentar la innovación y la puesta de productos seguros en el…

Filed in Spanish · English published by the European Commission

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

In the context of the consultation on the proposal for a directive on the digitalisation and harmonisation of common specifications, the Spanish Association of Paints and Tintas de Imprimir (ASEFAPI) wishes to convey the following key considerations, based on our experience with the European standardisation system and its contribution to industrial development, product safety and the integration of the internal…

Filed in Spanish · English published by the European Commission

The Swedish National Electrical Safety Board welcomes any proposal aiming to reduce the administrative burden of industry, particularly SME:s and micro-companies, while ensuring high product safety and compliance with EU legislation. The Swedish National Electrical Safety Board however has some concerns regarding certain aspects of the proposed omnibus directive, these concerns are decribed in the attached file.

The Spanish Association for Standardisation UNE considers that the following elements should be considered in the context of the proposed European Omnibus legislation: The European regulatory model based on the New Legislative Framework (NLF), complemented by Market Surveillance, has proven to be an ideal way to foster innovation and the placing of safe products in the Internal Market.

Filed in Spanish · English published by the European Commission

Consumers currently receive printed user manuals with their purchases, providing essential information on assembling, installing, using, maintaining, repairing, and recycling products. These manuals safeguard consumer safety and economic interests. Proper installation and maintenance ensure product longevity and optimal performance.

In the light of the proposal for European Omnibus legislation, the following elements should be considered: The European regulatory model based on the New Legislative Framework (NLF), complemented by Market Surveillance, has proven to be an ideal way to foster innovation and the placing of safe products in the Internal Market.

Filed in Spanish · English published by the European Commission

CEETTAR represents the professional end-user of around 45% of all agricultural machinery produced in the EU and around 90% of forestry machinery in the EU. In addition to this, we are also a major user of construction machinery for agricultural purposes, earthmoving and rural activities.

On behalf of the Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) and in cooperation with the Federation of the European Cookware and Cutlery Industries (FEC), we are pleased to submit our joint position paper on the Digital Product Passport (DPP) / digital product information in the context of the ongoing consultation on the Omnibus Regulation initiatives. Please find our position paper attached.

Dear Concerning the directive 2014/68/EU. Page 49 point (c) states that technical information shall be accessible online during the expected lifetime of the pressure equipment and at least 10 years. However chapter 2 article 6 point 3 states that the manufacturers shall keep the technical information for 10 years.

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering, electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of over 2,755 billion, manufacturing one-third of all European exports and providing 11.6 million direct jobs.