
When purchasing products today, a significant and unnecessary amount of paper is needed, as a wide variety of product-related information – such as, for instance, the instructions for use and Declaration of Conformity (DoC) – must still be supplied in paper format for each and every item. Compared to paper-based information, providing information by digital means would come with a number of structural advantages for users, businesses, and the environment. However, outdated and inconsistent legal interpretations with regards to the ‘embodiment’ requirement for accompanying information and the lack of overall consistency in current EU legislation prevent the application and uptake of state-of-the-art digital solutions in the area of product information.
Orgalim therefore calls for the creation of legal certainty. Manufacturers should determine the suitable format of information based on the nature of the product and targeted end-users, taking into account the intended use in each individual case and applying state of the art technology for information transfers. Making product information in digital form available via the internet, for example by scanning a QR code, should be accepted as state of the art.
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