The European Commission published its 2020 Work Programme on 29 January. It's jam-packed with announcements that are relevant to all those who design, manufacture, buy and sell products. The Work Programme is structured around a number of key ambitions, and includes over 43 new policy objectives.

One of the most notable is the review of the General Product Safety Directive – an overarching piece of EU legislation that affects the majority of products sold in the EU (with the exception of pharmaceuticals, medical devices or food). The focus of the review will be new technologies, online selling, recall effectiveness and alignment with the new European Goods Package (which we blogged about throughout its legislative passage here, here and here).

Also look out for the "European Green Deal", the EU's commitment to be carbon neutral by 2050. As part of this, we will see review (and revision) of a range of legislation, including:

  • revision of the Batteries Directive, or a proposal for a new regulation, which will include end-of-life and sustainability requirements; and
  • evaluation of the Restriction of Hazardous Substances ("RoHS") Directive, looking at the effectiveness and efficiency of adopting substance restrictions as well as consistency with other legislation like the REACH Regulation and Ecodesign Directive.

As part of "A Europe fit for the Digital Age", the Commission will:

  • report on the evaluation of the regulation on the internal market and cross-border e-commerce (geo-blocking), in particular looking at the potential additional administrative and financial burden for traders stemming from different regulatory consumer contract law regimes;
  • evaluate if the Low Voltage Directive ("LVD") is fit for purpose and/or needs amendments to improve its performance; and
  • revise the Machinery Directive to, amongst other things: turn it into a Regulation, address risks stemming from new technologies while allowing for technical progress and allow documents in digital formats.

This is a hugely ambitious and wide-ranging policy agenda, with real significance for all stakeholders. The Cooley team has a lot of experience of the EU legislative process. We can help clients to contribute their views, seek changes to draft proposals and navigate what this programme might mean for their business. If you'd like to discuss any of these developments with us, please feel free to reach out to Rod Freeman, Edward Turtle and Carol Holley.

You can find out more about the 2020 Programme on the Commission's website, here.

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