Internal Market: Orgalim comments on the NLF evaluation roadmap

Orgalim thanks the European Commission for the opportunity to comment on the Commission’s roadmap for the evaluation of the new legislative framework. As already indicated in our response to the Blue Guide revision, we remain 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. Thus, we believe that changes should be made only in response to clear needs and we therefore welcome this initiative to evaluate the NLF after 10 years of application, insofar as it will identify the areas in which more clarity is needed.

Bearing in mind the ultimate objective of the NLF, which is to strengthen the Single Market by applying the same rules for conformity assessment, market surveillance, CE marking, etc., we are convinced that such rules should not become too cumbersome when applied concretely. Otherwise, they will risk hindering the very goal of achieving a stronger Single Market. In addition, we would like the Commission to promote the NLF principles when developing new legislation (e.g. use of essential requirements in annex, application of harmonised standards, applications of the modules for conformity assessment etc.) as a means to facilitate companies’ compliance.

While we look forward to contributing to the upcoming official consultations, we believe it is relevant for us to provide our views on certain elements that should remain key throughout the evaluation. To read our full recommendations, please download the document above.