The European Commission has adopted its 2022 Work Programme. As expected, technology and sustainability are both high on the agenda with the Commission setting out a bold vision for a digitally-empowered, green Europe. We take a look at some of the most critical proposals for those working in the products sphere below. So, what's coming down the pipeline?

The European Commission's 2022 Work Programme contains 42 new policy initiatives, 26 initiatives for regulatory simplification, 76 pending priority proposals and 6 proposals for withdrawal - all related to the EU's 6 headline ambitions. Here's our quick-fire review of the initiatives announced that you should keep on your radar:

Environment, sustainability and the European Green Deal

  • Right to repair and the circular economy. In Q3 2022, we expect to see the publication of a legislative initiative on the right to repair, building on the Commission's Sustainable Product Policy initiatives from 2021. While the details are not yet known, the aim is to extend the useful life of goods and strengthen the rights of consumers to repair products at fair prices, alongside encouraging producers to design goods that last longer. An impact assessment and public consultation will be carried out in Q1 2022.  
  • Zero pollution package. The Commission also announced a revision of Learn more
    Term details'>Regulation No 1272/2008 on hazard classification, labelling and packaging of chemical substances and mixtures (CLP regulation). The legislative proposal is expected in the Q2 2022 and the changes are aimed at improving the safe use of chemicals in the EU and simplifying the existing rules e.g. on labelling. A public consultation on these amendments is open until 15 November 2021.
  • Plastics initiatives. The Commission announced four new initiatives focused on plastics and micro-plastics, including a policy framework for biodegradable and compostable plastics, and measures focused on restricting the use of microplastics. Although again the details are limited, the Commission's zero pollution action plan states that the EU should reduce microplastics released into the environment by 30% by 2030. These new initiatives are likely going to be crucial for that target.

Technology and digitisation

  • Cyber resilience. In Q3, we expect to see the launch of the European Cyber Resilience Act, which in part will propose new rules for connected devices to address potential software vulnerabilities and establish common cybersecurity standards for connected devices. This will be key for anyone working with new tech products, even those with basic connected properties.
  • Priority proposals. A number of existing digital initiatives have also been included as priority pending proposals for 2022, which indicates that they are considered significant and worthy of swift implementation. These include proposals for:
    • a new Artificial Intelligence Regulation, focused on adopting set of AI rules tailored on a risk-based approach;
    • a new Machinery Learn more
      Term details'>Regulation, which was initially proposed as part of the wider "AI Package";
    • a new General Product Safety Regulation, which, amongst other objectives, will address product safety challenges linked to new technologies, online marketplaces, non-harmonised products and recalls;
    • a new Digital Services Act and Digital Markets Act, which will have far-reaching effects for online platforms and marketplaces, as well as a broad range of businesses that sell products and services online; and
    • amended rules standardising chargers for mobile phones and similar categories of radio equipment.

Revision of other existing legislation

  • Learn more
    Term details'>RoHS Learn more
    Term details'>Directive.     The Commission announced that it would put forward a revision of EU rules restricting the use of hazardous substances in electronics. The legislative proposal, to be accompanied by an impact assessment, is expected in Q4 2022.
  • Detergents Learn more
    Term details'>Regulation.     The Commission is expected to address the weaknesses stressed in the evaluation of the Detergents Learn more
    Term details'>Regulation (particularly clarifying its scope) via a legislative proposal in Q4 2022.

Relevant to all of the above, the Commission has confirmed that green and digital ambitions will be more prominent in all evaluations, impact assessments and consultations. As ever, there is a lot to consider. If you'd like to discuss these developments, please do reach out to us. The Cooley products team has a lot of experience navigating the EU legislative process and can help you to contribute your views, seek changes to draft proposals or evaluate what this programme might mean for your business.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.