Ondanks de zomerperiode heeft de Europese Commissie een aanzienlijk aantal internetconsultaties gelanceerd die relevant zijn voor leveranciers van PBM, sommige met vrij korte deadlines. Hieronder tref je een overzicht aan van deze consultaties, die ESF voor je op een rijtje heeft gezet. Aarzel niet om er als bedrijf of organisatie aan deel te nemen, want daar zijn ze voor bedoeld. We verzoeken je vriendelijk het ESF-secretariaat op de hoogte te stellen van de feedback, zodat zij deze kunnen bundelen en namens ESF kunnen terugkoppelen. Als je het ESF-secretariaat informeert, doe dit dan uiterlijk één week vóór de deadline via Henk Vanhoutte, Secretary General ESF, [email protected]
Omnibus Regulation Aligning product legislation with the digital age
We kindly refer to this previous article: ESF request feedback: Proposal Omnibus Regulation and impact on PPE Regulation (EU)2016/425. Please provide feedback to the ESF secretariat latest by 18th of August. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14699-Omnibus-Regulation-Aligning-product-legislation-with-the-digital-age_en
Product legislation – ensuring futureproof rules. Rrevision of the New Legislative Framework – NLF (proposal for legislation in preparation)
Summary from the EU website: Following the evaluation of the NLF, which identified areas for greater digitalisation & other improvements, this initiative revises the legal framework for products in the EU, including by updating the rules on notified conformity assessment bodies. Updating the NLF is essential for integrating digital solutions into EU legislation (e.g. by introducing the Digital Product Passport), supporting the EU’s circular economy objectives and better addressing the inadequate practices of notified bodies.
As this legislation is horizontal and the basis for legislation such as the PPE Regulation, this is an important one that ESF will certainly follow in the next period. There is currently the Regulation 765/2008 (for those elements that are not covered in product specific legislation) and the decision 768/2008 (is used in product specific legislation to harmonise between legislations, e.g. definitions). This legislation covers for instance :
- Legal basis for CE marking
- Definitions and roles of economic operators
- Conformity assessment (requirements for notified bodies, accreditation of notified bodies, description of procedures (modules), …)
- Market surveillance mechanisms (e.g. safeguard procedures)
Feedback period: 14/07 till 02/09/2025. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14715-Product-legislation-ensuring-futureproof-rules-revision-of-the-New-Legislative-Framework-NLF-_en
Circular Economy Act (proposal for legislation in preparation)
Summary from the EU website: The Circular Economy Act will enhance the EU’s economic security, competitiveness, while promoting more sustainable production and circular economy business models and decarbonisation. The Act will facilitate the free movement of ‘circular’ products, secondary raw materials and waste. It will also increase the supply of high-quality recycled materials and stimulate demand for these materials in the EU. According to the EU Commission, the act may cover the reform of end of waste criteria; simplification, digitalisation and extension of extended producer responsibility schemes; criteria for public procurement of circular goods, services and works.
Feedback period open from 01/08 till 06/11/2025. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14812-Circular-Economy-Act_en
Protecting workers against cancer-causing substances at work (proposal for directive is published)
Summary from the EU website: This initiative will improve workers’ health & safety by revising for the 6th time Directive 2004/37/EC on the protection of workers from the risks related to exposure to carcinogens, mutagens and reprotoxic substances at work. It takes into account the latest scientific & technical developments for the following chemicals, groups of chemicals or process-generated substances:
- welding fumes
- polycyclic aromatic hydrocarbons
- isoprene
- 1,4-dioxane
- cobalt and inorganic cobalt compounds.
Feedback period open from 05/08 till 06/10/2025. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13606-Protecting-workers-against-cancer-causing-substances-at-work_en
Simplification of administrative burdens in environmental legislation (proposal for legislation is in preparation)
Summary from the EU website: Following the Commission’s commitment to reduce administrative burden for European companies and public authorities, this initiative will simplify and streamline administrative requirements related to the environment in the areas of waste, products, and industrial emissions. The initiative will reduce administrative burden without affecting the policy objectives pursued by the legislation. Also, the initiative will consider permitting challenges relating to environment assessments.
Feedback period open from 22/07 till 10/09/2025. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14794-Simplification-of-administrative-burdens-in-environmental-legislation-_en
Take part in our the impact assessment on the Digital Product Passport
Do you want to contribute to a future where companies, consumers and national bodies all have easy-to-access digital information on products? One where data will be available all along the value chain from their raw materials to being recycled? We have launched 4 surveys for specific groups of stakeholders about the Digital Product Passport (DPP). The aim is to better understand the costs and impacts of future requirements for DPP service providers. Your feedback will also help us determine the feasibility of establishing a certification scheme to ensure compliance with these requirements.
Please respond by 27 August to one of these surveys
- Companies (including SMEs) who primarily work in circularity and waste management. For example, waste disposal companies and those dealing with recycling, repairs, refurbished and re-purposed products will be the among the primary users of DPPs. Organisations representing these companies can also take part.
- Companies and SMEs who as a responsible economic operator, are required to produce a DPP for their products. This survey is also open to service providers hosting DPPs on behalf of others, as well as organisations representing such companies.
- Individual consumers and associations, along with consumer protection authorities or another body representing these interests
- National market surveillance or custom clearance authorities
Consultation period open from 25/07 till 27/08/2025. https://single-market-economy.ec.europa.eu/news/take-part-our-impact-assessment-digital-product-passport-2025-07-25_en
Green-listing certain waste for the purposes of shipments to recovery between Member States (questionnaire in preparation of delegated acts to be issued)
Summary from the EU website: This initiative implements the new Waste Shipments Regulation and complements the objectives of the future Circular Economy Act. It will consider certain waste as green-listed and may also introduce contamination thresholds so that other types of waste can be green-listed. The initiative will be preceded by a consultation process to gather input from a wide range of stakeholders on waste streams to be addressed.
The Waste Shipment Regulation provides for the possibility for the Commission to identify, via delegated acts, specific waste streams which should be subject to the “green-list” procedure for the purpose of shipments for recovery between Member States. The aim of this public consultation is to gather information from stakeholders to prepare such delegated acts “green-listing” certain waste to facilitate the shipments of waste for recovery within the EU.
Consultation period open from 02/07 till 31/10/2025. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/14712-Green-listing-certain-waste-for-the-purposes-of-shipments-to-recovery-between-Member-States_en