Euralarm Position Paper on NLF evaluation
Improvements
Euralarm remains convinced that the New Approach and the New Legislative Framework (NLF) are the best tools to support the free movement of goods and the proper functioning of the European Single Market for Goods. The NLF in its broad set-up is fit for purpose to deal with upcoming challenges through technological developments. Thus, Euralarm believes that changes should be made only in response to clear needs, within the existing framework.
Among the main benefits of the NLF Euralarm considers: strengthened coherence across different sectoral legislation, improved legal certainty, higher compliance levels, ease of compliance, improved level-playing field, strengthened CE marking use and functioning. When it comes to conformity assessments, Euralarm strongly believes that Module A, in combination with an effective market surveillance, provides a good and fair level playing field for manufacturers. The combination of modules (particularly the use of Module A, self-assessment), acceptable time to market and good market surveillance system is an essential element of the NLF and the most effective regime to preserve safety and the level-playing-field.
The introduction of the NLF has also been beneficial for SMEs in that it has opened the EU market to them, thanks to the use of hENs and module A. Having a stronger Single Market has further benefitted the global competitiveness of European industries and it has improved the speed of adoption of state-of-the-art technologies, as compared to the old approach. The NLF has set the basis for a strong market surveillance system, notably by providing for a Union framework for market surveillance comprising both competencies and obligations for national authorities and by organising effective administrative cooperation between these authorities on the one hand and with the EU Commission on the other hand.
In the Euralarm Position Euralarm further explains its position towards CE marking itself, harmonised standards, conformity assessment procedures, notified bodies, the accreditation system and digitalisation of the information.
Based on this position, Euralarm believes that a full revision of the NLF might not be necessary to address problems with specific legislation.
