The main changes that are proposed to be examined are whether:
i) the NLF is fit to address the way products may be changing during their lifetime to both support the take-up of smart connected or remanufactured products and to ensure safety;
ii) the conformity assessment procedures remain fit for purpose and ensure the safety and compliance with the applicable requirements of the products placed on the Union market;
iii) the rules for notified bodies are robust enough to ensure the competence of those bodies;
iv) the accreditation system functions well and ensures that the competence of the notified bodies intervening in the conformity assessment procedures is sufficiently guaranteed;
v) affixing the CE marking and other product information to the product itself continues to be appropriate; and
vi) whether the lack of a crisis instrument for urgency situations renders the NLF less effective or efficient.
The LPRA Council would like to draw particular attention to the two points above highlighted in green, especially the first i), which could see fundamental changes brought about to the way in which products are tested and for post-sale obligations. Not necessarily a bad thing, but something which we need to monitor closely.
We would encourage all members to either respond directly to the Commission with any concerns they have or to send the LPRA Secretariat your comments which will be included in the official LPRA response.
Direct response by midnight Brussels time on the 2nd December 2020
Comment for inclusion in the LPRA response noon UK time on the 1st December 2020.