DIGITALEUROPE comments on the draft implementing regulation on labelling of batteries

Executive summary

DIGITALEUROPE appreciates the European Commission is submitting an implementing regulation to ensure marking and labelling requirements are implemented and enforced in a harmonised way.

In line with the European Commission’s goal to cut all administrative costs by at least 25% and estimated saving potential of up to 37.5 bn (Eurostat), we have identified regulatory provisions in this implementing regulation as a candidate for consideration. We agree with European Commission Dombrovski that “simplification is not deregulation” and see a path to achieving the same environmental standard in a less burdensome way.

DIGITALEUROPE is concerned that the current version of the draft is attempting to achieve its objectives with measures that are so specific that they introduce further complexity into what already is a short implementation timeline and overly complex marking regulation. DIGITALEUROPE invites the European Commission to reconsider the implementing regulation with a view to simplifying compliance burden rather than adding further complexity into what is already the most extensive set of marking requirements our industry is subject to. DIGITALEUROPE observes major inconsistencies in the implementing regulation and would like to ask the European Commission to re-consider the current draft.