Amending certain Regulations 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)

Sika appreciates the opportunity to comment on the Omnibus proposals COM(2025)503 and COM(2025)504. We strongly support the objective of modernising and simplifying EU product legislation. We welcome the introduction of the concept of digital contact, accompanied by a concise definition.

FEM, the European Materials Handling Federation, welcomes the European Commissions proposal for an Omnibus Regulation Aligning product legislation with the digital age. The initiative is a significant step forward the modernisation of EU product legislation and simplification of compliance procedures.

As a global provider encompassing several manufacturers and other economic operators of personal protective equipment (PPE) EssilorLuxottica welcomes the European Commissions (EC) initiative to modernize regulatory frameworks through digitalization.

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.

As a member of the European Safety Federation we support their position but would like to highlight a number of key points. 1. Consistency of terms between this act and both General Product Safety Regulation (EU)2023/988 (GPSR) and the PPE Regulation (EU)2016/425 (PPER) . For example: (1) digital contact vs.

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) 504 Observations on the Draft - OMNIBUS IV URL ‘Have you say’: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14699Omnibus-Regulation-Aligning-product-legislation-with-the-digital-age_en Conflict of objectives between Directive 2024/1781 and COM(2025)503 Drafts COM(2025)503 aims the complete removal of paper-format instruction manuals, at least when the product…

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

EUROM 1 welcomes the European Commissions Omnibus Regulation as a valuable step towards digitalisation, user-friendliness and sustainability. While supporting the overall direction of the proposal, EUROM 1 raises concerns regarding the requirement for mandatory paper instructions for consumer products and products that could reasonably be used by consumers.

Feedback ESF on proposal for Omnibus Regulation Aligning product legislation with the digital age Date : 03/09/2025 The European Safety Federation (ESF) and its members welcome the proposal of the 21st of May 2025 for a Regulation amending amongst others Regulation (EU)2016/425 as regards digitalisation and common specifications.

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

The proposed Omnibus IV Regulation aims to modernise EU product legislation by digitising compliance documentation and removing paper-based requirements, including printed instructions for use (IFUs). While the objective of reducing administrative burdens can be understood, the blanket shift to digital-only formats poses serious economic, social, and consumer protection risks, especially for Europes printing…

Omnibus Regulation Aligning product legislation with the digital age. ANFAO, Italian Association of Optical Goods Manufacturers, supports the current draft of the Omnibus regulation as an important evolution of the legislation in the direction of sustainability, digital evolution and clear safe information to the users.

Sede legale: Piazza Castello 28 – 20121 Milano Tel. [phone removed] – Fax [phone removed] Delegazione: Viale Pasteur 10 - 00144 Roma Tel [phone removed] – Fax [phone removed] [email removed] www.federazionecartagrafica.it Codice Fiscale 97500320151 Omnibus IV - digitalisation and common specifications in product legislation Federazione Carta e Grafica, the Italian Federation of the Industry Associations for Paper…

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

Our feedback addresses the European Commissions proposal COM(2025) 504 and its annexes, focusing on the integration of the European Trade Indexes Registry (EUTIR) into the New Legislative Framework (NLF). We propose EUTIR as a foundational digital infrastructure that ensures legal validity, traceability, security, and interoperability of electronic trade documents across the EU.

HB Protective Wear is an experienced PPE specialist, manufacturing high quality protective garments that protect people from a wide range of hazards at the workplace. HB Protective Wear GmbH welcomes the initiative to simplify legislative reporting requirements through the proposed Omnibus regulation. The proposal addresses key challenges faced by manufacturers when placing products on the EU market.

We support the current draft of the Omnibus Regulation as a meaningful evolution of EU legislation, advancing sustainability, digital transformation, and the delivery of clear and safe information to users. These goals are essential to modernizing regulatory frameworks and aligning with broader initiatives such as the Green Deal and the circular economy.

Please find attached JBCEs position paper on the proposals for a Regulation 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…

3M welcomes the European Commission Omnibus proposal on Digitalisation and alignment of common specifications published on 21st May 2025. As a manufacturer of Personal Protective Equipment (PPE), our contribution is related to the amendment to the PPE Regulation (EU 2016/425).

We, Japanese 4 electric and electronic industry associations-JEMA, JEITA, CIAJ and JBMIA (hereinafter JP4EE) welcome the opportunity to provide our comments and proposals on the draft Commission Regulations under the Omnibus IV Simplification Package.

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.

figawa would like to thank the EU-Commission for the opportunity to submit our comments to respond to the survey Omnibus Regulation Aligning product legislation with the digital age. We support the EU's goals of achieving a resilient, green, and digital economy and the measures for digitalization proposed in the Omnibus Regulation Aligning product legislation with the digital age proposal.

1) Regarding the safety information in digital format, especially for PPE (Regulation (EU) 2016/425): In our field it is still possible to offer digital declarations of conformity (DoCs). Our experience with this is that a lot of these DoCs are not available while module C2 examination. Often the links to the documents are broken.

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)

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…

While we welcome the objective of modernizing and simplifying regulatory procedures, the proposal to digitize instructions for use, as presented in this document, raises concerns regarding Category III personal protective equipment (PPE), which protects users from serious or fatal hazards and therefore requires special attention.

Ansell, global leader in safety solutions and an integrated manufacturer of personal protection equipment for healthcare and industrial workplaces, welcomes the opportunity to comment on the Omnibus proposal, and would like to make following comments to this current proposal linked to the Personal Protective section.

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.

EPTA appreciates the opportunity to give feedback to the Omnibus IV proposals. We support: (1) A homogenous approach across product legislation (2) Digitalisation of product information requirements to fit the digital age (3) Digital only communication with authorities and notified bodies.

Milano, 2 Settembre 2025 -----------------------------------------------------------------------------------------------------------------------------------------------------Omnibus IV - digitalisation and common specifications in product legislation Assocarta represents the Italian pulp and paper industry and gathers, through its 67 members, the 86% of the Italian production of the sector which accounts almost for…

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

The examination of the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) No 765/2008, (EU) 2016/424, (EU) 2016/425, (EU) 016/426, (EU) 2023/1230, (EU) 2023/1542 and (EU) 2024/1781 as regards digitalisation and common specifications calls for two comments: 1-the first relates to the fact that, in the explanatory memorandum to the proposal, it is stated (§ 5, page 8)…

Filed in French · English published by the European Commission

2.9.2025 Ref. Ares(2025)7121550 1 (2)- 02/09/2025 SFS Finnish Standards’ comments on the Omnibus Regulation aligning product legislation with the digital age SFS Finnish Standards appreciates the opportunity to comment on the Omnibus Regulation aligning product legislation with the digital age. Our comments regard specifically the Commission’s initiative related to common specifications.

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

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)

We welcome the Commission's approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, ASPAPEL is concerned about setting a 'digital only' approach in product legislation.

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to align product legislation with the digital age. We believe that the Legal Entity Identifier (LEI) and its digital counterpart, the verifiable Legal Entity Identifier (vLEI) can play a key role in reducing administrative burdens, enhancing interoperability, and strengthening digital trust for manufacturers and other…

The Federation of German Industries (BDI) welcomes a uniform and horizontal regulation of the use of Common Specifications (CS) but expresses serious concerns about the European Commissions proposal. While the initiative aims to counteract delays in the availability of harmonised European standards (hENs), BDI warns that the systematic use of CS risks undermining the integrity, efficiency, and global relevance of…

SESKO supports the European Commission's efforts to harmonise criteria for issuing common specifications. It is crucial that the future process is done in a way that ensures the involvement of a broad range of stakeholders. It is also important that there is a clear framework for the Commission's competences and for the possible withdrawal of common specifications.

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. 1. Digitalisation 1.1.

2025-09-02 Svenska informations- och telekommunikationsstandardiseringens (ITS) synpunkter på förslag till förordning - COM(2025)504 Vem är ITS och varför yttrar vi oss? ITS (Svenska informations- och telekommunikationsstandardiseringen) är ett av svenska regeringen erkända standardiseringsorgan och Sveriges NSB i ETSI. ITS yttrar sig bara i frågan om införandet av gemensamma specifikationer (GS).

Filed in Swedish · English published by the European Commission

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

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 Printing Industry in Finland calls on the Commission to maintain paper instructions for consumer products in EU legislation. Removing them would endanger consumer rights, safety, accessibility, and sustainability. Paper instructions provide immediate, reliable, and universal access to essential product information (use, assembly, repair, safety).

We welcome the Commission's approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, Cepi is concerned about setting a 'digital only' approach in product legislation.

As a national standards body and German member of the European standardization organization CEN, DIN is pleased to have the opportunity to comment on the draft for the Omnibus Directive aligning product legislation with the digital age (Omnibus IV), which, among other things, plans the broad introduction of common specifications (CS) across large parts of European product regulation.

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.

EUROPEN already provided initial feedback on this topic through the survey on the Simplification Omnibus Aligning EU Product Legislation with the Digital Age, launched on 11 April, which we are sharing as an attachment. Building on that initial input, we would like to take this opportunity to further complement our contribution through the present submission.

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.

Submission On Call for Evidence: “Omnibus Regulation 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 5.

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 Confederation of Swedish Enterprise appreciates the Commission's proposals to simplify processes for companies and aligning product legislation with the digital age. We support digitalising the EU Declaration of Conformity, enabling digital instructions, and making electronic communication with authorities the norm.

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)

Firstly, we would like to express our gratitude for your invitation to stakeholders' comments on the draft Omnibus Regulation Aligning product legislation with the digital age. Our group, the Japanese electric and electronic industrial associations (JP4EE), has been covering the regulations on substances in articles for many years.

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…

We CIEL Lebanon that has introduced the Bar Coding Symbology and the Digital Signature Platform with all its derivatives before the turn of the Century in our Region, are fully convinced and equally motivated to support the European Commissions initiative to align product legislation with the Digital Age is, as a matter of fact, an important step towards reducing administrative burdens, enhance interoperability, and…

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.

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)

UL Solutions respectfully submits these comments in response to the proposed regulation regarding digitalization and standard specifications. This proposal suggests introducing common specifications for accreditation standards within Regulation (EU) No. 765/2008. We believe this is unnecessary, as the existing harmonized standards for conformity assessment bodies are already fully adequate and effective.

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.

We suggest to extend the principle of complete removal of paper-format instruction manuals to professional products in-scope of Regulation 2024/1781 (Ecodesign regulation). Indeed, while COM(2025)503 aims at achieving the complete removal of paper-format instruction manuals, the Regulation 2024/1781 (Ecodesign regulation), proposed to be modified by COM(2025)504, keeps on requiring that essential elements be…

We welcome the opportunity to participate in the public comment call for the Omnibus IV Proposed Regulation (COM (2025) 504) for Digitalisation and alignment of common specifications. JMC strongly supports the policy of Omnibus package IV simplifying product legislation and reducing bureaucracy in the European Single Market.

CECIP fully supports the European Commissions objective to simplify regulatory frameworks and accelerate the digital and green transition. The principle of Digital by Default is a cornerstone of this evolution, marking a vital legislative shift where digital formats become the standard, and printed or analog alternatives serve as supplementary options.

Brussels 08/2025 Position Ref. Ares(2025)6776923 - 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 Regulation aligning product legislation with the digital age. Please find attached our position paper with with comments and suggestions from the German Electro and Digital Industry.

KVGO contribution to the European Commissions public consultation on Omnibus IV The Royal Dutch Association of Printing and Allied Industries (KVGO) is deeply concerned about the Commissions proposal to restrict printed consumer product manuals to an opt-in basis. We believe this proposal risks undermining consumer rights, product safety, and sustainability.

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.

Dear European Commission Metrology Team, On behalf of Aqua Metering, the European trade organization representing water meter and thermal energy manufacturers, we would like to thank the Commission for the opportunity to comment on the proposed Omnibus Regulation aligning product legislation with the digital age.

ECOS has reviewed the European Commissions proposal for a regulation of the European Parliament and of the amending Regulations (EU) No 765/2008, (EU) 2016/424, (EU) 2016/425, (EU) 2016/426, (EU) 2023/1230, (EU) 2023/1542 and (EU) 2024/1781 as regards to digitalisation and common specifications released on 21 May 2025 and this feedback outlines ECOS position with regards to the specific provisions related to the…

The European Carton Makers Association (ECMA) welcomes the Commissions approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs. However, with the proposed Omnibus IV on aligning product legislation in the digital age, we are extremely concerned if a digital only approach was considered with product information for medicines and medical devices Currently…

Afecor, the European Control Manufacturers Association, broadly supports the Omnibus proposal aimed at amending several directives and regulations concerning digitalization and common specifications. We believe that fully leveraging digital product information can significantly contribute to achieving the EUs goals in sustainability, digitalisation, and competitiveness.

Representing the entire value chain of paper in Belgium (forest owners, pulp, paper, and cardboard producers and processors, printers, as well as newspaper, magazine, and direct mail publishers), Papier.be welcomes the Commissions approach to simplify EU legislation with the objective of reducing administrative burdens, particularly for SMEs.

The Spanish Automobile and Truck Manufacturers Association (ANFAC) expresses its support for the Commissions initiative on digitalisation and fully shares the Commissions ambition to simplify administrative processes for businesses, reduce unnecessary administrative complexity, and promote the adoption of digital solutions, including tools like digital product passports.

The European Automobile Manufacturers Association (ACEA) welcomes the Commissions proposal on digitalisation and is fully aligned with the Commissions goal of reducing paperwork for businesses, cutting unnecessary administrative burdens, and encouraging the use of digital tools, such as digital product passports.

QUINTIN CERTIFCATIONS (NB 2927 France) Although the digitization of instructions offers many advantages, we do not believe it is appropriate to apply it to all products. Indeed, for certain equipment, such as Personal Protective Equipment (PPE), which is subject to EU Regulation 2016/425, which protects users against serious and/or mortal risks, its essential that this equipment be used correctly by users to ensure…

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.

In response to the Commission proposal for a Regulation regarding Digitalisation and the Alignment of Common Specifications, we consider it crucial that the EU product legislation is aligned with the digital age. We support the proposed changes for the conformity assessment procedures of batteries which would slightly reduce the administrative burden of the industry.

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)

With regard to the part of the Omnibus IV package aimed at supporting digitilisation, we welcome the proposals to facilitate the transfer of information between stakeholders and to harmonise this transfer by electronic means rather than by paper. However, immediate paper access to safety instructions, notices, etc. must be maintained.

Dato: Ref.: 18-07-2025 SDK Dansk Standards høringssvar vedrørende Omnibus IV om fælles specifikationer Resumé Dansk Standard (DS) støtter Kommissionens indsats for at harmonisere skabeloner og kriterier for udstedelse af fælles specifikationer.

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)

Making interaction with AI free must be the key theme of the digital future. This means that the user must be able to make a free choice on a daily basis if and how to interact with AI, which must appear with the email and phone number of the responsible person to contact in case of problems.

Filed in Italian · English published by the European Commission

In the context of the consultation on the proposal for a regulation 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

CECIMO, representing the European manufacturing technology industry, supports the European Commissions Omnibus IV initiative to enhance digitalisation and streamline compliance procedures across the Single Market.

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

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

The DigitalTrade4.EU consortium provides feedback to the European Commission on strengthening the EUs leadership in green and digital trade. The consortium supports the Commissions Omnibus proposals aimed at reducing administrative burdens, promoting digital-by-default practices, and introducing common specifications for harmonized standards.

Please find attached our comments related to digital instruction for use in PPE regulation (2016/425/EU). Some of those comments could apply on the other regulations concern by Omnibus initiative. We understand that the main objective is to authorize digital instructions and information, downloadable from an internet adress, and not only in physical format.

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

Please find attached our position paper concerning the digital provision of product-related information under Regulation (EU) No 305/2011 (Construction Products Regulation). While we fully support the Commissions initiative to promote digital formats through the Omnibus IV package, we believe that similar progress is urgently needed for products still covered by the old CPR including, for example, individual room…

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

In view of the upcoming revision of the European Standardisation Regulation 1025/2012, the following elements should be considered: It is essential for the European Commission to speed up the deadlines for citing standards in the Official Journal of the European Union: — European industry, in collaboration with other interest groups, is investing heavily in the development of standards to ensure that they support…

Filed in Spanish · English published by the European Commission

Following recent discussions on the digitalization of legal documentation for PPE, we would like to share Elis perspective as a key player in the rental and maintenance of textile and PPE solutions. We believe that transitioning to a digital format offers significant advantages for both compliance and operational efficiency: Improved ecological impact: Reducing paper usage aligns with our sustainability goals and…

On behalf of the Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) and in cooperation wit 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.

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.