Japan Machinery Center for Trade and Investment

JMC would like to ask the European Commission to take into account the following proposals in the further regulatory simplification activities: 1. Exemption of packaging imported into the EU with the HS code within the scope and subsequently replaced with identical packaging that is already placed on the market which is supporting, protecting, or carrying the product therein.

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.

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.

We, JMC would like to request that the final regulation be revised along the proposals outlined below, so that the requirements remain reasonable and simple while in line with Regulation (EU) 2023/1542. 1. ANNEX I: We propose that EUBR Part A Labelling information shall set minimum necessary requirement, and label format in Part B Label design shall be optional.