Elements for a horizontal legislative approach to technical harmonisation

Orgalime Comments on EC discussion paper Certif 2005-16

This position comments on paper on the EC discussion paper Draft Certif. 2005-16 Rev.2, which appears constructive in addressing the problems arising from the lack of harmonisation of the legal framework of New Approach directives.

Orgalime considers that for our industry, where product legislation is deemed necessary, the New Approach can provide a simple and flexible regulatory approach, which, when legislation is properly designed and transposed, provides a substantial internal market for our products, underpinning our international competitiveness and, therefore, the continued potential of the EU as a manufacturing base in the face of ever stronger global competition.

While we fully support the Commission’s proposals for reinforcing surveillance at the borders of the EU and in the internal market, Orgalime urges the Commission to make greater use of Module “A” as the preferred procedure for conformity assessment in revising the framework of New Approach directives.