Following the 2022 evaluation of the New Legislative Framework (NLF), the NLF, though a cornerstone of EU product legislation harmonization, was found to require modernization for the digital age and support European circular economy objectives. The 2025 Single Market Strategy further confirmed the need for this revision, alongside other legislative initiatives relating to Single Market Policy, including the standardization regulation and the Fourth Package of the Omnibus, on aligning product legislation with the digital age. During this revision, it is essential that these reviews are coordinated to ensure consistency, synergy, and simplification across the EU’s regulatory product framework.
CEN and CENELEC welcome the opportunity to contribute to the revision process by responding to the European Commission’s Call for Evidence, as the NLF is not only at the heart of the success of the European Single Market, but recognizing that standardization has played a fundamental role in supporting this success.
In the response CEN and CENELEC emphasized:
- For the NLF revision to uphold its core principle of public-private partnership. This would ensure the continued balance between regulatory requirements set by the European institutions and harmonized standards developed by the European Standardization Organizations (CEN, CENELEC, and ETSI).
- The need for the Revision of the NLF to be complementary to the upcoming Revision of the Standardization Regulation and Omnibus on aligning product legislation with the digital age. This will ensure regulatory consistency and ease of understanding for standardization stakeholders.
- To ensure the implementation of the Digital Product Passport (DPP) is fully aligned with the revised New Legislative Framework (NLF) to preserve the clarity and legal certainty provided by the CE marking. This includes avoiding overlapping regulatory requirements, ensuring coherence with harmonized standards, while also promoting a mutually reinforced relationship between the DPP and CE marking.
CEN and CENELEC look forward to continued collaboration with the European Commission on the revision of the NLF. The next step in the process is a public consultation, expected by the end of 2025, for the Commission to gather more detailed stakeholder input. The full proposal is expected from the Commission in the first half of 2026.
You can find the CEN and CENELEC response submitted on the website of the European Commission here. The full CEN and CENELEC response is available here.
