CECE believes the base legislation on industrialised products should not change

The New Legislative Framework (NLF) encompasses legislation about conformity assessment procedure, CE marking, accreditation of notified bodies. It sets a basic framework for industrialized goods in the EU market.

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The European Commission is currently evaluating if the NLF continues to be fit for purpose taking into consideration technological changes such as Artificial Intelligence. The evaluation focuses on subjects such as soft- and hardware updates & upgrades, refurbishment & repairs and conformity assessment & accreditation.This evaluation is based on stakeholder feedbacks, provided through two consultation exercises.

Replying to both consultations, CECE delivered its members’ opinion reaffirming the importance of the NLF as it stands. Our members believe that the NLF sets a well-established system that it has proven to work very well during the last decades.

Changing its fundamental approach would likely create divergence between legislations applicable to the same product, adding confusion for economic operators in terms of responsibility, especially after placing the product on the market. It may also create market distortion in case different basis requirements are set for different sectors due to a missing common approach and objective.

On costs, our members indicated that besides the financial costs in contracting the services of a Notified Body, it is important to mention the delays in placing a product on the market. CECE believes that one of the main costs is the mandatory involvement of a third-party certifier during the conformity assessment procedure. We firmly believe that self- certification (Module A) should remain an option whenever revising the NLF and any product legislation.

With regards to the next steps, the EC will publish the results of the evaluation deciding if it will make any changes to the NLF or not. CECE will closely follow any future developments and react accordingly.