European Product Act: Upgrading the Single Market for Products in the Digital Age

The European Product Act (EPA) will reframe Single Market access, addressing e-commerce, connectivity, and the circular economy. For the home appliance industry good product regulation is the prerequisite for fair competition and the basis of the free movement of goods, one of the freedoms of the Single Market. Therefore the EPA’s success is a strategic necessity.

APPLiA’s recommendations aim to restore the CE mark’s integrity and streamline the New Legislative Framework (NLF). Based on our ongoing engagement with DG GROW, this paper outlines the reforms needed to maintain fair competition and a functional Single Market. We welcome the opportunity to further discuss these insights with the Commission’s experts.

Key Messages

• Upgrade the CE mark to a QR code-based digital identifier linked to a mandatory EU product registry.
• European legislation should require a single EU QR Code on products, covering all regulatory legal requirements, rather than a proliferation of different data carriers¹
• APPLiA supports a rigorous, product-by-product impact assessments before any mandatory DPP rollout
• Mandate digital-only user manuals and Declarations of Conformity (DoC) as the horizontal EPA baseline, paper on request only.
• Strengthen the NLF for the circular economy by mandating safety re-assessments for refurbished goods and clarifying operator liability for consumer protection.
• Online marketplaces must be recognised as economic operators and bear co-liability for non-compliant products on their platforms
• Authorised Representative must become a legally empowered 'authorised recipient' for judicial proceedings, not just a nominal contact
• Introduce the deemed importer concept to in the Market Surveillance Regulation to ensure product safety accountability for goods sold via distance channels
• Create a dedicated EU-level market surveillance authority for coordinated, cross-border enforcement
• Self-assessment must remain the default conformity route for home appliances. Third-party assessment should not become mandatory without solid justification
• Harmonised standards must remain voluntary; delays in OJEU publication must be ; Common Specifications must remain an exceptional, last-resort tool