CHANGES TO THE EU BLUE GUIDE - October / November 2020

UPDATE : November 2020  Based on Members' feedback to the request below, the LPRA submitted a response - available as a PDF HERE


Dear LPRA Member

At the end of 2019 the European Commission (EC) launched a public consultation of the Blue Guide - the important document that sets out the way in which products may be placed on the European market - in preparation for an update in 2020. 

It has come to the attention of the LPRA council that, subsequently to this consultation, the EC has proposed a significant number of changes to the Blue Guide (sent to members on 19:10:20 - available on request from the Secretariat) and is consulting with a restricted number of stakeholders before publishing the document. As an ETSI member, the LPRA has seen this document and will be submitting its own comments to the European Commission on behalf of its members. 

There is much useful information added to the document, including :

  • Updates to relevant regulation

  • Section 1.3 highlights modernisation of market surveillance provisions

  • Section 3.6 sets out the concept of Responsible Economic Operator

  • Section 2.8.5 sets out details on the impact of the withdrawal of the United Kingdom from the European Union, in particular on the status of UK registered notified bodies, the UK accreditation service, and any products that have been certified by a UK registered notified body. The information contained here goes beyond that available from official UK government websites and is therefore worth noting by UK manufacturers.

  • Section 7.3.2 sets out members states requirements to draw up national market surveillance strategies.

However, it is worth highlighting three specific aspects of concern that we feel it is important to make you aware of :

  • Section 4.2 sets out details of the way in which the EC and its consultants are now engaged in standards writing process is across industries and how they interpret standards as part of European Law. Given a recent challenge by The German government to this interpretation in the form of a legal opinion.

    • The LPRA believe that it is premature to include this verbiage in the document and that it should be removed.

  • Section is set to ban the use of stickers/decals to attach the CE mark.

    • The LPRA will oppose this change.

  • Section will also require that products requiring assembly, the CE marking should remain visible after assembly.

    • The LPRA will also oppose this change.

If you have any further comments that you would like us to make on your behalf, please let the secretariat know by 30th October 2020.

We will of course keep you full informed of all developments.