The digital industry’s remaining concerns about a product database and a potential way forward

DIGITALEUROPE maintains strong reservations against the introduction of a mandatory product energy label database as outlined in a previous paper. The key reasons are repeated below for information.

1. The proposed form of “Energy Label Product registration” is mistakenly seen as a replacement and enhancement of the actual market surveillance. Market surveillance authorities already have limited resources and this proposal will divert those resources to validate data entries and chasing administrative non-compliance, rather than perform essential product testing.

2. The provision of compliance information for surveillance activities is currently already adequately ensured by the legal obligation to provide technical documentation within 10 working days, upon request.

3. There is a very real concern over data confidentiality and effective database management, along with the extensiveness of this proposal compared with other jurisdictions (see Annex).

4. Significant administrative burden for manufacturers and duplication of existing requirements through additional request to provide online labels, fiches and technical documentation.

Another major concern with the database proposal is the potential for the scope to be extended to other product regulations, beyond the energy label, which would certainly make the energy label database unmanageable for manufacturers. Indeed, we can already see proposals for extension to this database and are concerned with how this will be controlled. Selling products in Europe would become a hugely bureaucratic process.

In light of these concerns, DIGITALEUROPE does not support mandatory uploading of documentation to a central database as a market access condition.