FEM welcomes the Omnibus IV package as a major step towards modernising EU product legislation and simplifying compliance.
However, trilogue compromises risk undermining this objective, especially as far stationary battery energy storage systems (SBESS) are concerned:
• Digital vs paper contradiction: Requiring paper-based instructions for SBESS, while promoting digitalisation and the Battery Passport, creates unnecessary duplication and sends conflicting signals.
• Operational challenges for industry: Requirements on language and availability of instructions may force translation into all EU languages, which is impracticable for manufacturers.
• Unclear framework for the Battery Passport: Key elements—such as the definition of safety information and access rights—remain insufficiently specified, creating legal uncertainty.
FEM calls for:
• Repealing the amendments requiring manufacturers to provide paper-format safety information and instructions for SBESS, in light of the upcoming implementation of the Battery Passport.
• Clarifying the definition and legal basis of safety instructions for SBESS.
• Harmonising the classification of information and access rights of safety information in the Battery Passport.
