Internal Market: Orgalim comments on the 2020 draft Blue Guide

Orgalim welcomes the update of the Blue Guide and remains convinced that the New Approach and the New Legislative Framework are the best tools to support the proper functioning of the European Single Market for Goods. We greatly appreciate the amount of work the European Commission has done to accommodate the industry’s need for additional guidance when it comes to the application of NLF.

Orgalim is, however, opposed to any modification of the Blue Guide that would impose new constraints or provisions other than those laid down in the European legislation (e.g. the introduction of a new definition for remanufacturing) or even propose provisions arising from too strict an interpretation of the regulations.

Orgalim considers all the additions and modifications related to standardisation and harmonised standards under section 4.2 Conformity with the essential requirements: harmonised standards to be problematic. We feel the need to stress once more the importance of ensuring sufficient flexibility for the standardisation system. We propose that either the revision of the Blue Guide should be delayed, or section 4.2 should be maintained as in the edition published in 2016, unless a suitable solution has been found.

Finally, Orgalim would propose further developments of the Blue Guide draft, and we stand ready to support the Commission in the improvement of this Guide.

To read our recommendations in full, please download the position above.