The European Commission has confirmed that the revision of the Standardization Regulation (EU Regulation no. 1025/2012) will be carried out in parallel with the revision of the New Legislative Framework Regulation and the Market Surveillance Regulation, resulting in a package of the European Product Act (EPA). CEN and CENELEC support this approach to ensure alignment with the three Regulations to strengthen European quality infrastructure.
In January 2026, CEN and CENELEC replied to the consultations on the revision of the Market Surveillance Regulation and the New Legislative Framework, highlighting that the EPA package should consist of two legal acts:
- A revised Standardization Regulation, and
- A combined Act on Market Surveillance and the New Legislative Framework.
This combination would consider the aspect of services and not be limited to product legislation (Regulation 1025/2012). The European Standardization System (ESS) also addresses issues beyond the internal market, with an organic link between European and International standardization via the Frankfurt and Vienna Agreements.
Clear separation between the legal framework for standardization and market surveillance is essential to preserve the clarity of roles, responsibilities, and objectives, and to avoid unnecessary complexity that would undermine the effectiveness of market surveillance activities.
In the NLF consultation, CEN and CENELEC notably highlighted:
- Standardization have played a fundamental role in supporting the European Single Market through the success of the NLF. The revision of the NLF should therefore uphold its core principle of the public-private partnership between the EC and ESOs, to ensure a continued balance between regulatory requirements set by the European institutions and harmonized standards developed by the ESOs.
- Implementation of the Digital Product Passport (DPP) should fully align with the revised NLF to preserve the clarity and legal certainty provided by the CE marking. This includes avoiding overlapping regulatory requirements, ensuring coherence with harmonized standards, and promoting a mutually reinforcing relationship between the DPP and CE marking.
- In addition to developing the standards used to assess products, CEN and CENELEC provide the standards underpinning the quality infrastructure itself, such as the EN ISO/IEC 17000 Internationally originated harmonized European standards must remain the basis for accrediting conformity assessment bodies. When such standards are not yet harmonized, European standards (possibly adopted from the international level) should be applied to ensure alignment of European accreditation globally. Creating parallel processes or weakening coherence within the European standardization system would undermine the consistency and effectiveness of European accreditation.
CEN and CENELEC emphasize that the EPA should:
- clearly recognize the role of harmonized European standards as the preferred tool for technical implementation,
- ensure stable, transparent procedures for standard citation in the OJEU, and
- support coherence with international standards.
To learn more about the CEN and CENELEC position on these key files, you can find the full position papers from CEN and CENELEC on the Policy page and the position paper on the Market Surveillance revision.
