Revision of the R&TTE Directive (1999/5/EC) - Answer to the public consultation
Published: 15 September 2010
Policies & Issues: Internal Market - Product Safety Legislation
Orgalime greatly appreciates the Commission’s efforts to develop a potentially effective legal framework to harmonise the conditions for placing products on the Community market.
Traceability needs indeed to be improved with flexibility and at the least administrative cost. Nevertheless, it has to be acknowledged that without effective enforcement, traceability measures are pointless. In our view, Decision 768/2008/EC already requires both a clear identification of products made available on the market with 'type, batch or serial number or other element' , and a clear identification of economic operators with 'their name, registered trade name or registered trade mark and the address' . These requirements aim at ensuring traceability and at facilitating 'market surveillance authorities' task of tracing economic operators who made non-compliant products available on the market'.
Therefore, we call on the Commission to maintain consistency when aligning the R&TTED with the New Legislative Framework.