Omnibus simplification of energy-efficient product legislation

8 submissions in the snapshot (5 from organisations), portal total 8. Feedback list on the portal.

5 of 5 organisation submissions analysed; the model reads them as: supports 1 wants changes 4

• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Implement the once-only principle as trusted evidence interoperability instead of database-to-database duplication.

    We recommend that the once-only principle be implemented as trusted evidence interoperability rather than database-to-database duplication.

  • Ensure key product, conformity and authority states become machine-verifiable.

    Key product, conformity and authority states should therefore become machine-verifiable, including source, model identifier, applicable version, timestamp, current status and, where relevant, correction or supersession information.

  • Measure whether interoperability effectively reduces duplicate reporting, verification time, exception handling and administrative costs.

    The Commission should also measure whether interoperability actually reduces duplicate reporting, verification time, exception handling and administrative costs.

• Europäische Feuerstätten Arbeitsgemeinschaft e. V. Business association, DEU; register: Trade and business associations model reads as: supports source
  • Apply a consistent once-only principle for product data and avoid duplicate information requirements.

    a consistent "once-only" principle for product data and the avoidance of duplicate information requirements in EPREL and other EU databases;

  • Use digital product information wherever appropriate instead of unnecessary paper documentation.

    digital product information wherever appropriate instead of unnecessary paper documentation;

  • Ensure sufficient transition periods for manufacturers when new requirements are introduced.

    sufficient transition periods for manufacturers when new requirements are introduced.

• Micro company, FRA Company, FRA model reads as: wants changes source
  • Condition any removal of the physical label on a consumer behavior study ensuring visibility is not degraded.

    1. Conditioning any removal of the physical label (via delegated acts) on a consumer behavior study ensuring that the visibility of information is not degraded.

  • Technically encourage SaaS LCA automation solutions to allow suppliers to generate accurate performance data on a massive scale.

    2. Technically encouraging SaaS LCA automation solutions that allow suppliers (including third-country importers via their authorized representatives - M6) to generate accurate performance data on a massive scale and at a low cost.

  • Mandate open and standardized API formats for uploading to EPREL to reduce administrative costs for suppliers.

    3. Mandating open and standardized API formats (as discussed for M13 on tires) for uploading to EPREL, so that private eco-design software can interface their results (impact calculations, LCA) directly with the European database, thereby drastically reducing administrative costs for suppliers.

• Micro company, FRA Company, FRA model reads as: wants changes source
  • Allow products with a screen to display the official energy class arrow on their own screen instead of using a printed label, providing simple access to the EPREL model fiche.

    For products with a screen, allow, instead of the printed label, the display on that screen of at least the official energy class arrow, which consumers immediately recognise, with simple access to the official model fiche in EPREL: a link, a pressure on the arrow, a QR-code or any other equivalent means.

    machine translation by the Commission, original in FR
  • Establish verifiable conditions requiring the official arrow to be never redesigned, permanently visible without customer action while the shop is open, and with the screen kept on.

    Set verifiable conditions: official arrow never redesigned, permanently visible and without action by the customer while the shop is open, screen kept on.

    machine translation by the Commission, original in FR
  • Maintain the requirement for a printed label for products that do not have a screen or where the screen cannot display the information.

    Keep the printed label for products without a screen, or where the screen cannot display the information: screen switched off, or no means of displaying it on it.

    machine translation by the Commission, original in FR
• Micro company, POL Company, POL model reads as: wants changes source
  • Make the EPREL registration number a standard data element of the DPP registry entry and of the passport itself.

    We propose that the EPREL registration number becomes a standard data element of the DPP registry entry, and of the passport itself, for every energy-related product and tyre, next to the unique product identifier under EN 18219.

  • Allow a single data carrier to serve both the energy label and the Digital Product Passport to avoid printing two codes.

    Delegated acts should allow one carrier to serve both, for example a GS1 Digital Link URI that resolves to the DPP and offers the EPREL record as a linked resource.

  • Extend the existing EPREL public API so that DPP service providers acting under a supplier mandate can read model data.

    We ask that the existing EPREL public API is extended so that DPP service providers acting under a supplier's mandate can read that supplier's model data needed for the passport, and that the "single system for electronic verification of the identity of suppliers for both databases" (recital 8) also covers such mandated providers, so that a supplier verified once does not repeat the process for each tool it uses.