KAN position statement on Commisson's omnibus package IV

The proposals also include amendments relating to digitalisation. They are part of the fourth omnibus package aimed at reducing bureaucracy and administrative burden for companies in the EU.

Common specifications are European implementing acts that are intended to serve as an alternative to harmonised standards in the event that, despite standardisation mandates having been issued, the European standards organisations CEN, CENELEC and ETSI fail to deliver harmonised standards, or deliver standards that are deemed inadequate. KAN examined this instrument critically in a position paper in October 2024. With the new proposals, common specifications are now to be introduced as an ‘alternative to harmonised standards’ in legal acts in which they have not as yet been provided for.

Comments on both the proposed regulation and the proposed directive can be submitted via the European Commission's Have Your Say portal until 3 September 2025.

KAN has participated in this process and submitted a position statement on the regulation and directive proposals.

In its position statement, KAN addresses in particular the following points:

• The precedence of harmonised European standards over alternative solutions such as Common specifications
• The need for narrowly defined conditions for the adoption of Common specifications in order to ensure consistent application within the Single Market and to prevent further fragmentation and inconsistency in the regulatory framework
• The development and adoption of common specifications based on clear, legally binding criteria and within a transparent process
• The involvement of stakeholders
• The establishment of a horizontal legal framework.