General Product Safety Regulation

Targeted proposals to make GPSR a success Over the last 20 years, BIC has experienced the impediments to the enforcement of lighter safety standards under the GPSD, with the vast majority of lighter models non-conforming to the two international safety standards, despite: - an emergency decision by the Commission in 2006, - the referencing of the two lighter safety standards in the Official Journal, - a 9 year-long…

The French Business Movement (MEDEF) welcomes the publication of this draft Regulation, which partly addresses the major issues raised by MEDEF in its contribution to the new Consumer Agenda of September 2020. We are particularly interested in two main objectives pursued by this revision: — the alignment of product safety and compliance rules in the EU and the alignment of the responsibilities of each economic…

Filed in French · English published by the European Commission

vzbv strongly supports the draft for a General Product Safety Regulation. We agree on the objectives and welcome: • The underlined value of the safety net function and precautionary principle • Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States • Stronger traceability in the supply chain and a greater responsibility for safety of online…

This document is focusing only on key aspects. APPLiA is happy to contribute to the legislative process with further details at a later stage. 1 - Improved coherence with New Legislative Framework The GPSR is thought as a “safety net” to Union harmonised legislation, therefore coherence with the New Legislative Framework (NLF) is of utmost importance.

Danish Chamber of Commerce welcomes the revision of the general product safety directive, including in particular the fact that the proposal aims to create compliance with the principles and definitions contained in the harmonised part of the product safety legislation and the market sur-veillance regulation.

The ZVEI supports the objectives of the European Commission to better protect consumers and create better framework conditions for economic operators through the revision of the existing General Product Safety Directive (2001/95/EC).

Cooley is a leading international law firm which represents many of the most innovative and important companies, including in the technology sector. Cooley’s products lawyers have detailed knowledge of the European products regime and in-depth familiarity with EU products guidance. We welcome the opportunity to provide feedback on the European Commission’s proposal for a General Product Safety Regulation.

UNIFAB - Union des Fabricants is the French association for the promotion and defence of intellectual property rights. It represents companies from all economic sectors and offers them an associative framework to promote intellectual property and fight against counterfeiting.

TomTom welcomes the fact that Type-approval for motor vehicles and the General Safety Regulation (GSR) are both listed as “Union harmonization legislation” covering the automotive sector. Obligations on economic operators and their placing on the market of products defined in the GPSD proposal only apply when obligations are not yet covered by Union harmonisation legislation.

The European Public Health Association (EUPHA) welcomes the opportunity to provide input regarding the Commission’s General Product Safety Directive (GPSR). We also consider important the need to comprehend and address emerging challenges; in this context the EU Consumer Legislation, the Digital Market Act (DMA) and the Digital Services Act (DSA), the e-Commerce Directive, the Market Surveillance Regulation and the…

TIC Council, representing independent Testing, Inspection and Certification (TIC) companies, welcomes the European Commission’s proposal to revise the General Product Safety Directive, and the following proposals: • Turning the Directive into a Regulation, • The inclusion of a broader scope (inclusion of concerns coming from the new digital environment: cybersecurity and artificial intelligence, as well as…

The Federation of European Publishers welcomes the possibility to provide feedback regarding the proposed review of the General Product Safety Regulation. FEP and its members have at heart the safety of citizens all over Europe, and publishers’ utmost care goes into ensuring that their products do not present any hazard for readers.

Huawei supports legislations and policy initiatives that strengthen the safety of ICT products in the EU and modernize the legal framework to assess the safety of products using appropriate level of cybersecurity requirements and ensure that consumers can safely enjoy the most advanced technologies available on the market.

The TÜV Association welcomes the Commission’s intention to undertake the existing General Product Safety Directive (2001/95/EC) a substantial revision. Products must be safe and consumers have to rely on their safety. The Commission proposal is clearly a step in the right direction. However, further improvements are needed. Please find our feedback attached.

The Federation of European Producers of Abrasives (FEPA) welcomes the opportunity to comment on the Commission’s legislative proposal of 30 June 2021 on General Product Safety. FEPA welcomes the strong focus of the proposal on the market surveillance, as the problem of unsafe products being put on the market should be addressed through more efficient implementation, closer cooperation of competent Member States’…

CEO represents leading European manufacturers of hand tools and accessory tools for power tools. Most of them are SMEs. Product safety is one of the moist important issues for our members and our association. The safety requirements for most of our products are defined by ISO standards or national standards.

To whom it may concern, On behalf of the Confederation of Danish Industry, I would hereby like to submit our comments on the Commission's proposal for a General Product Safety Regulation (attached). DI supports the European Commission’s initiative to update the existing General Product Safety Directive (GPSD) as well as its transformation into a regulation (GPSR).

The Polish Association of the Cosmetics and Detergent Industry (PSPKD) welcomes the approach of harmonising legislation in the EU and transforming the provisions of the Directive into directly applicable provisions of the Regulation in all Member States.

Filed in Polish · English published by the European Commission

The Polish Union of the Cosmetics Industry welcoming the possibility of cooperation with the Commission on General Product Directive (GPSD) recast from directive to regulation, which will improve the harmonised application of the law across the EU. The GPSD is an important regulatory tool to ensure consumer safety in the EU. It fundamental approach, scope and principles are still relevant and valid.

Filed in Polish · English published by the European Commission

Contribution of the Federation of Commerce and Distribution to the draft Regulation on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and repealing Council Directive 87/357/EEC and Directive 2001/95/EC of the European Parliament and of the Council The FCD welcomes the publication of this Regulation, which partly addresses the major issues raised by the FCD…

Filed in French · English published by the European Commission

Dear Sir, Ma'am, Please find below ACEA Position and feedback to the consultation. Logically, vehicles can clearly be identified by the individual VIN-Number and it is in the interest of vehicle manufacturers that our customer's are aware of the product manufacturer or recall actions triggers for used goods.

The European Rolling Paper Association (ERPA) represents the interests of predominantly small and medium-sized manufacture od specialized paper products. Endowed with this mandate, we welcome the opportunity to provide our position on the Commission’s call for feedback on the review of the General Product Safety Directive (subsequently abbreviated as “draft proposal”).

Forbrugerrådet Tænk strongly supports the proposed General Product Safety Regulation. We agree on the specific objectives and welcome: - Value of the safety net function and precautionary principle -Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States -Stronger traceability in the supply chain and a greater responsibility for safety of…

Construction Products Europe welcomes the initiative proposal COM (2021) 346 final of the European Commission in relation to consumer product safety. However, we identified the need for a sector specific approach when dealing with construction products.

The European Tech Alliance (EUTA) welcomes the European Commission’s revision of the General Product Safety Directive. The new proposal for a Regulation on General Product Safety (GPSR) aims at strengthening consumer protection by ensuring that only safe products are sold on the EU internal market.

The European Aerosol Federation (FEA) welcomes the proposal to replace the Directive on General Product Safety with an EU Regulation as this will facilitate an improved harmonised application of the law across the EU. We also welcome the principles of application expressed in Article 2, i.e.

Brussels Consulting Kft. submits the following concerning the Commission’s draft: • Overall, we support Commission’s proposal and we believe that the proposed (new) requirements are appropriate. • We recognise similar high-level requirements in existing US law, and we suggest that the Commission took a look at them if hadn’t already (e.g. Consumer Product Safety Improvement Act).

Key messages According to SMEunited the proposal contains several provisions and approaches which are very positive, such as: - the need for uniform market surveillance in the EU, - the general approach to AI, - the formal recognition of the imbalance between the rules for physical stores and those for digital platforms.

Etsy, the global two-sided marketplace for unique and creative goods, welcomes the European Commission’s proposal to revise the General Product Safety Directive (GPSD). Etsy believes that marketplaces have a responsibility to help protect consumers. As a business, it’s in our best interest to offer consumers a trusted place to find their favourite independent shops.

Japan Business Council in Europe (JBCE) welcomes the proposal for the Regulation on General Product Safety, which also addresses New Legislative Framework (NLF) and Market Surveillance Regulation and to reduce the costs of transposition with the choice of a Regulation.

The Foundation of Consumers (PL) strongly supports the proposed General Product Safety Regulation. We agree agree with BEUC and ANEC opinion and welcome: -The underlined value of the safety net function and precautionary principle -Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States -Stronger traceability in the supply chain and a greater…

amfori welcomes the proposed General Product Safety regulation and the goal that it seeks to achieve. It is important that consumers can be assured that the products they buy – many of which will be from amfori retailer members – are safe, and to have recourse to action in the, hopefully rare, occasions that proves not to be the case. The enhanced coherence with other, similar, areas is also appreciated.

EuroSafe Calls for an “Pan-European Injury Database”-article to be included into the Commission’s General Product Safety Regulation-proposal The Report on the Implementation of the General Product Safety Directive (GPSD), states that data on the impact of the GPSD is insufficient and uneven across Member States, as the Directive only contains a general monitoring obligation.

The International Trademark Association (INTA) would like to thank the European Commission for the opportunity to provide feedback on its consultation to the General Product Safety Directive (GPSD). INTA previously provided feedback on the inclusion of counterfeit goods in the GPSD in October 2020, here.

ANEC strongly supports the proposed General Product Safety Regulation: The underlined value of the safety net function and precautionary principle Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States Stronger traceability in the supply chain and a greater responsibility for safety of online marketplaces New provisions on connected products…

CONEBI, the Confederation of the European Bicycle Industry, would like to hereby provide its comments on the European Commission’s proposal for a new General Product Safety Regulation (GPSR). For us this legislation is of particular relevance because bicycles as well as certain bicycle parts and accessories fall within the scope of this legislation. Attached you can find our full feedback.

DIN Deutsches Institut für Normung e. V. as the official national standardisation body in Germany appreciates the opportunity to comment on the GPSD draft as follows: 1) General comments: Standardization in support of the EU legislation is a strategic tool for the success of the Single Market and the competitiveness of European companies, as well as the well-being of European consumers and society - a system copied…

The Swedish Trade Federation woul like to share their views on the legal proposal on the General Product Safety Regulation. We welcome the new proposal and belivie that it is a great idea to make a regualtion out of the productsafety legislation. Hence, we also belivie that it is remarkable that the Commission have not apporached the loophole with online marketplaces. 1.

DEKRA welcomes the European Commission’s proposal to revise the General Product Safety Directive. We believe, that many important points to improve consumer safety have been addressed in the proposal. We support the following: • The Commission proposing to turn the Directive into a Regulation • The proposal to integrate the traceability requirements for products and the obligations for economic operators by…

Good Morning ABIMOTA is an Industrial Association that represents Portuguese industries in the two-wheel sector. In this context, ABIMOTA is a member of CONEBI and we worked together to have a common position. In the attached document, we send the common position, also taken by ABIMOTA.

BEUC strongly supports the draft for a General Product Safety Regulation. We agree on the objectives and welcome: • The underlined value of the safety net function and precautionary principle • Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States • Stronger traceability in the supply chain and a greater responsibility for safety of online…

Developers Alliance appreciates the opportunity to provide input to the consultation on the proposal for a Regulation on general product safety. Our comments are strictly limited to aspects related to software development, and in particular on the correlation with other relevant EU legislation and legislative proposals.

The comments of the Robert Bosch GmbH are not exhaustive. They give an overview with regard to some matters that are of particular interest to our company. 1. On the matter of mental health The context and the added value of the WHO definition of ‘health’ for the GPSR is unclear.

We would like to thank for the EU Commission’s Consultation on the proposal for a Regulation on General Product Safety. Our contribution focusses exclusively on the issue of counterfeit goods and their relevance for product safety issues. Counterfeit and pirated products are reported to represent 5,8% of EU-imports (Global Trade in Fakes, OECD/EUIPO, 2021).

Standardization in support of the EU legislation has become over the decades a strategic tool for the well-being of the European Internal Market and European companies, as well as European consumers and society, a system copied by partners around the world. We appreciate that this also applies for the European Commission proposal for a GPSR even though it is not a harmonization legislation.

FSB welcomes the opportunity to provide a response to the Commission’s call feedback on the review of the General Product Safety Directive. The Federation of Small Businesses (FSB) is the UK’s leading business organisation. Established over 40 years ago to help our members succeed in business, we are a non-profit making and non-party political organisation that is led by our members, for our members.

APPLiA (Home Appliance Europe) believes that GPSD has been working reasonably well over those almost 20 years and does not require major revision. However, considering time and efforts already invested in possible review, Option 0 ’Status quo’ is probably not realistic anymore.

Cefic welcomes the opportunity to submit comments on the General Product Safety Directive (GPSD, Directive 2001/95/EC). With 96% of goods manufactured in Europe relying on chemicals, the European chemical industry is committed to ensuring chemical safety for all users.

Retailers and wholesalers are central actors in the supply chain: they are in regular contact with Europe’s 500 million consumers and they operate sophisticated and efficient systems ensuring the reliable and safe sourcing and distribution of consumer goods. They work with suppliers to meet consumers’ demand and keep them safe . Consumer confidence is a key priority for retail and wholesale.

The General Product Safety Directive (GPSD) must be adapted to reflect developments in products and markets and to address challenges and shortcomings identified. In light of the review of the Directive, the European Furniture Industries Confederation believe that option 2 or 3 of the Inception Impact Assessment are preferable, consisting of a targeted revision of the Directive or the full revision and repeal of the…

IKEA recommend revising the General Product Safety Directive with the intent of transforming the Directive into a Regulation. The scope of the regulation should remain limited to the safety of non-harmonised consumer products, while updates should be made to promote harmonised enforcement and efficient recalls. Please refer to the attached file for the rational behind our recommendations.

Cosmetics Europe represents the cosmetics and personal care industry in Europe. The vast majority of Europe’s 500 million consumers use cosmetic and personal care products on a daily basis to protect their health, enhance their well-being and boost their self-esteem.

In principle, all options, except option 0, will have a more or less strong positive impact on the protection of health and the environment, on consumer confidence in products sold in the EU, the competitive conditions of the market participants and, as a result, on the economy in general.

Google welcomes the opportunity to contribute to the European Commission’s consultation on the review of the General Product Safety Directive. In our response we focus on the areas which are related to the emergence of Artificial intelligence, based on our feedback to the earlier consultation on the Commission’s AI white paper.

According to GPSD Art. 2 lit b) iii), ”the presentation of the product, the labelling, any warnings and instructions for its use and disposal and any other indication or information regarding the product” have to be particularly taken into account when it comes to product safety. Such information is increasingly provided in digital form using current technologies.

The European Automobile Manufacturers’ Association (ACEA) believes that the GPSD is still broadly fit for purpose and does not require a major overhaul. At the most, it could be revised in a targeted manner to update some of the definitions with a view to clarifying their applicability.

Revision of the GPSD is an excellent opportunity to demonstrate the EUs’ progressive stance on animal welfare, drawing on the experience of the intent of the animal testing bans in the Cosmetics Directive (7th amendment, in 2003).

Our association represents European manufacturers of hand tools, tools for stationary and handheld machines and similar products. In our opinion, it would be desirable to convert the directive into a regulation in order to rule out national differences in implementation in the future (option 3).

Our association represents manufacturers of paintbrushes, household brushes, personal care brushes, professional hygiene brushware technical brushes and similar products. In our opinion, it would be desirable to convert the directive into a regulation in order to rule out national differences in implementation in the future (option 3).

Our association represents manufacturers of hand tools, tools for stationary and handheld machines and similar products. In our opinion, it would be desirable to convert the directive into a regulation in order to rule out national differences in implementation in the future (option 3).

Bol.com welcomes the opportunity to respond to the General Product Safety Directive Inception Impact Assessment. As a (local) online retail platform operating in the Netherlands and Belgium, bol.com would by means of the attached paper like to provide its views on issues 2, 3 and 4 of the IIA, since they are most relevant to our platform operations.

The Danish Consumer Council strongly supports the announcement of the European Commission to review the General Product Safety Directive. We agree to the problem definition as outlined in the roadmap which emphasises the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance.

The TIC Council is an international trade association representing the third party testing, inspection and certification companies. The GPSD is a historic cornerstone of the Single Market. Nevertheless, it falls short of addressing the challenges raised by digital transformation, the proliferation of online sales channels and the shortcomings of market surveillance in the EU.

The Polish Union od the Cosmetics Industry welcomes the opportunity to engage with the European Commission on the New Consumer Agenda and related files. In regard to the Commission’s roadmap on the review of the General Product Safety Directive (GPSD), the Union considers the following principles are critical elements for the upcoming European Commission policy discussion in this field: • The GPSD is an important…

Energizer is in favour of updating the General Product Safety Directive to ensure that it is fit for purpose and continues to protect consumers in the digital era. As integral components in many household devices, batteries have a critical role to play in guaranteeing the performance of consumer products and as such it is paramount to ensure their safety.

For Bitkom and its members, the safety of the products placed on the market is the top priority. Therefore the General Product Safety Directive (GPSD) has a high priority for us and we appreciate the opportunity to provide feedback on the roadmap for its revision. Since its enforcement the GPSD has made a significant contribution to the safety of consumer products.

The Swedish Consumers’ Association agree to the problem definition, emphasising the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance. We recommend Opt 4.

The revision, of the Directive on General Product Safety, is at a great importance given the significant market developments, particular the globalization of trade and the increase in online sales. Due to these developments it has become clear that the legal framework of product safety needs to be brought up to date.

We agree to the problem definition, emphasising the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance. We recommend Option 4. A full revision of the legal instrument is necessary to address safety risks brought by the Internet of Things and Automated Decision Making, to clarify the obligations of all actors in the supply chain, including online…

BEUC strongly welcomes the announcement of the European Commission to review the General Product Safety Directive. We agree to the problem definition as outlined in the roadmap which emphasises the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance.

Following your request about the revision of General Product Safety Directive (2001/95/EC), we have the following comments: • The General Product Safety Directive protects consumers by ensuring that only safe goods are sold on the EU market.

The General Product Safety Directive (GPSD) is an important tool safeguarding product safety in all EU Member States. EDANA, the association representing the nonwovens industry, welcomes the review of legislation thereby ensuring the protection of health and safety of all consumers in the single market.

Having been monitoring product recalls for almost sixteens years, there are a few things that keep worrying me. First, the amount of work the controlling agencies must do, with the limited funding they have. Resources are spread thin, and thus there is not enough market surveillance.

Unfortunately, the initial revision with commission proposal of 2013 was not successful and a missed opportunity. The GPSD needs now even more a fundamental revision to align its provisions with the goods package from 2008 and to update its safety requirements to new developments in markets, distribution channels and technology (security and privacy aspects). We therefore recommend Option 3.

Alliance for Internet of Things Innovation (AIOTI) is the multi-stakeholder platform for stimulating IoT Innovation in Europe, bringing together small and large companies, start-ups and scale-ups, academia, policymakers, and end-users and representatives of society in an end-to-end approach. GPSD is technology-neutral and safety provisions are fit-for-purpose in the context of new and emerging technologies.

Question: As a result of covid-19, we have recently been involved in the testing/assessment of LED products that claim to sanitize surfaces by 'killing' the virus with UV light. I am aware that some of these products would directly fail GPSD as unsafe products because the UV levels are too high, however we have products which specifically claim to "kill covid-19" but the testing indicates that the UV is not…

To the extent that this evaluation Roadmap addresses Cosmetic products as part of the The General Product Safety Directive, UNI Europa Hair & Beauty would like to raise concerns over the risk assessment methodology of the SCCS which authorises, after assessment, the placement of cosmetic products in the EU market.