FEM welcomes the European Commission’s proposal for an Omnibus Regulation “Aligning product legislation with the digital age” (COM (2025) 504). The initiative is a positive step towards modernising EU product legislation and simplifying compliance procedures.
However, FEM identifies several areas of concern:
• Regulatory inconsistency: The proposal creates contradictions between the Batteries Regulation (EU 2023/1542) and the Machinery Regulation (EU 2023/1230). For example, industrial truck manufacturers could provide digital manuals for machinery but still be forced to supply paper instructions for batteries.
• Scope limitations: Industrial trucks, a cornerstone of the materials handling sector, are excluded from the new provisions.
• Excessive obligations: Extending the right to request paper instructions beyond the time of purchase and to all end-users risks creating uncertainty and administrative burdens, especially in cases of rental or resale.
FEM’s Recommendations:
• Delete Article 6(4)(a) of the proposal.
• Align Article 6(4)(b) with Article 10(7) of the Machinery Regulation to avoid disproportionate requirements.
Read our position paper.