Omnibus IV – Trilogue Recommendations

Our Proposals

1. Handling paper instructions should not burden distributors: Whereas we welcome digital transition, it is imperative that it does not increase the administrative burden for other operators. It is imperative that distributors are not requested to print or store instructions in place of manufacturers. Where instructions are provided digitally, it should be solely the manufacturer’s responsibility to provide a direct, reliable mechanism for consumers to obtain paper instructions free of charge. 

2. Missed opportunities for digitalisation under the Batteries Regulation 2023/1542
a. Information which is not essential for safety should be moved from the physical product to the digital label (e.g. place of manufacture, critical raw materials).
b. Alignment should be achieved with CS3D.

3. Proportionate obligations for distributors: distributors should only be expected to provide the information that has been explicitly made available to them by previous operators.

4. Common specifications: We support the Council position on common specifications. Common specifications should be introduced in exceptional cases and under specific conditions. Priority should be given to the adoption of harmonised standards. Our detailed position can be found here.