Elements for a horizontal legislative approach to technical harmonisation

Published: 21 April 2006

Policies & Issues: Internal Market - Compliance, Standards & Enforcement

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.

Related Position Papers

Internal Market: Joint Industry recommendations for effective Harmonised Standardisation [6 July 2021]

Internal Market: Joint open letter on industry competitiveness and EU standardisation [1 February 2021]

Internal Market: Orgalim comments on the NLF evaluation roadmap [2 December 2020]

Internal Market: Orgalim comments on the 2020 draft Blue Guide [13 November 2020]

Internal Market: Orgalim comments on the Draft Guidelines for the practical implementation of Article 4 of Regulation 2019/1020 on market surveillance and compliance of products [22 April 2020]

Internal Market: Shaping a New Deal for the Single Market: Harmonised standards in support of a competitive European industry [27 January 2020]

Internal Market: Suggestions for a revision of the Blue Guide on the implementation of EU product rules 2016 [27 January 2020]

Internal Market: For a restored mutual trust in a market-relevant European Standardisation System [24 September 2019]

Towards effective, efficient EU market surveillance: all for a level-playing field without additional burdens for legitimate manufacturers [6 December 2018]