In the letter, the signatories, one of which is Ecommerce Europe, reiterate their full support for the efforts to combat unsafe and non-compliant products from being placed upon the European market. However, the letter voices the industry’s concern with the ongoing discussions on the proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods Package) in the EU Council, particularly on Article 4, and its implications for cross-border ecommerce.
The proposed Article 4 would mandatorily require the appointment of a ‘responsible economic operator’ established in the EU for placing harmonized products on the EU market, including the labelling of this person on the product, packaging, parcel or accompanying document. This will have significant trade impeding impacts on trade with third countries, which will ultimately lead to less choice and less competitive prices for EU consumers who will be geo-blocked from international offering. Additionally, third countries could view this provision as a protectionist measure.
Consequently, this legislation could trigger a domino effect, by which EU exporters could face additional costs and burdens exporting to third countries in the longer term.
Finally, the signatories call on the EU Council to use its right to call for a new impact assessment, given the crucial importance of Article 4 for product and consumer safety, doubts on the previous impact assessment and substantial changes in the text.
Read the full letter here.