Revision of the R&TTE-Directive comments on the second proposal by the Commission TCAM 32 (10)

Orgalime represents product groups for which various directives apply simultaneously. We therefore, very much welcomed the New Legislative Framework as a means to align the elements of the directives as much as possible. This was also the reason why European industry took many efforts to contribute to the development of the NLF.

Given this background we are very much disappointed by the high number of deviations from the NLF to be noted in the proposal for a new R&TTE-directive, which we have listed below. These even concern critical issues like the DoC, the CE-marking or a newly created article on technical documentation. We urge the commission to further align the R&TTE directive to the NLF and thus enable it to function as foreseen.