Orgalime welcomes the European Commission’s plan to organise seminars on the implementation of Low Voltage Directive (LVD 2014/35/EU), Electromagnetic Compatibility Directive (EMC 2014/30/EU) and Radio Equipment Directive (RED 2014/53/EU). We consider that such seminars could contribute to a more consistent implementation of the Directives by market surveillance authorities and economic operators across the EU and hope that additional seminars for all the other Directives aligned with Decision 768/2008 will follow.
However, manufacturers have also raised an important number of horizontal questions. Therefore, we invite the Commission to organise a seminar which would tackle horizontal questions. We strongly believe that these questions should not be dealt with during the Directive-specific seminars, as this could result in diverging interpretations among the Directives.
Moreover, we expect the Commission to revise parts of the Blue Guide to include the seminars’ results and eliminate any remaining room for misinterpretation of the aligned provisions.
Therefore, please find included in the annex a list of points where the text of the Blue Guide could confuse or misinform the reader.