Omnibus IV: The EU co-legislators ready to start Interinstitutional negotiations on digitalisation and common specifications

While discussions on the final text are still ongoing, the IMCO vote provides a clear indication of the Parliament’s approach to the upcoming changes to the Machinery Regulation and the Batteries and Waste Batteries Regulation, both of key relevance for CECE. 

A Stronger Push Towards Digitalisation 

The Omnibus IV package further advances the EU’s shift towards digital product information. 

For the Machinery Regulation (MR)  (EU) 2023/1230, the Parliament’s negotiating mandate foresees that the Declaration of Conformity (DoC) must be provided exclusively in electronic format and be directly accessible via a web link or QR code, free of charge and without login or the provision of personal data. Consumers may request paper instructions within 24 months after purchase. For professional users, the period remains 6 months. Manufacturers must provide the requested instructions within 15 working days. Safety information for consumer products would need to be provided in paper form or marked directly on the product, whereas for professional users it would be required only in digital format. The EC would also be required to assess the effectiveness of digital safety information within three years. The amendments linked to the MR would apply from 20 January 2027, in line with its application date, while other provisions would generally apply 24 months after entry into force. 

Regarding the Batteries and Waste Batteries Regulation (EU) 2023/1542, the Parliament proposes the inclusion of the definition of ‘digital contact’, referring to up-to-date and freely accessible online communication channels. This would make digital contact details an integral part of compliance requirements across the battery value chain, including for construction machinery manufacturers. 

While the move towards digital Declarations of Conformity represents a step forward, mandatory electronic-only access raises practical concerns within CECE membership, including the risk of multiple QR codes on a single machine. The extended period for consumer requests for paper instructions is welcome, but the shortened 15-day deadline for responding to authorities will require careful planning by manufacturers. 

CECE regrets that certain elements of this “simplification” package would in practice introduce additional administrative and technical burdens for machinery manufacturers. After long and complex negotiations on the Machinery Regulation—where a balanced compromise was reached on digital documentation—the new amendments risk overturning those carefully crafted provisions. If the current phrasing is confirmed in the upcoming trialogue negotiations, OEMs will be obliged to comply with different and burdensome requirements only a short time after having adjusted their processes and systems to the MR as adopted. This abrupt regulatory shift creates uncertainty for manufacturers and undermines the predictability that EU product legislation should ensure. 

Clear Limits on the Use of Common Specifications 

Another key outcome of the IMCO vote concerns Common Specifications, which allow the Commission to set technical requirements in the absence of harmonised European standards. IMCO clearly confirmed that Common Specifications should be used as an exceptional fall-back solution. To prevent overuse, several safeguards were introduced, including clearer definitions of what constitutes an urgent situation, mandatory involvement of expert groups when preparing implementing acts, and a requirement for Council authorisation where suspended cooperation with European standardisation bodies affects the setting of standards.  

CECE welcomes this approach, which reflects the joint position put forward by CECE, Orgalim and other industry associations.  

Next steps 

As IMCO has granted a mandate to enter interinstitutional negotiations, the usual plenary vote will not take place. The mandate will be announced during an upcoming plenary session, and only a formal objection by Members of the European Parliament would trigger a vote. Given the strong support at the committee level, this appears unlikely. The Parliament is therefore expected to start trialogue negotiations with the Council and the Commission shortly in spring 2026 under the Cypriot Presidency. 

CECE will continue to closely monitor developments and keep members informed as the negotiations progress.