The European Commission is working on a proposed revision of the New Legislative Framework (NLF) for CE-marked products, with plans to use this as a vehicle to roll out requirements for digital product passports (DPPs) to become the main tool for sharing product information in the European Union.
The NLF (Decision No 768/2008/EC and Regulation (EC) No 765/2008) sets out the template for rules governing CE-marked products in the EU. There are 30 legal acts aligned to the NLF template – so a revision to the NLF would have a broad impact. The aim of the revision is to boost harmonisation, cut regulatory burdens and leverage digital tools to improve compliance and safety.
The call for evidence outlines the potential legislative options being explored by the European Commission. These range from targeted amendments, through to comprehensive revisions, including amendments to the NLF and product harmonisation legislation to:
- Introduce mandatory DPPs, which would be a digital record of a product’s compliance and supply chain information.
- Revise conformity assessment processes.
- Align definitions with other EU legislation, such as the Market Surveillance Regulation (EU) 2019/1020.
- Address certain practices of notified bodies and strengthen oversight of notified bodies.
- Ensure timely and consistent responses to noncompliant and dangerous products across Member States.
The European Commission previously outlined its ambitions to progressively roll out DPPs to become the main tool for disclosing and sharing product information across all new and revised EU product legislation using the proposed revision of the NLF in its Single Market Strategy in May 2025. This would build on the framework for DPPs currently being established under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781 (ESPR), where requirements for DPPs will be laid down for specific product groups, such as textiles, by future delegated acts made under the ESPR. There are also requirements for DPPs for certain products included in recently revised rules – such as the provisional agreement for the new Toy Safety Regulation, the new Construction Products Regulation (EU) 2024/3110, and for certain large batteries under the Batteries Regulation (EU) 2023/1542.
We don’t know yet how quickly the European Commission plans to roll out the expansion of DPPs under the NLF revision. If future requirements for a DPP are progressively added to existing pieces of product harmonisation legislation as those rules come up for review, or when new product harmonisation rules are made, this would result in a much slower rollout. Alternatively, if proposed amendments introducing requirements for DPPs across a number of pieces of product harmonisation legislation are contained in an omnibus proposal presented at the same time as the amendments to the NLF template legislation, this process could be much faster – and we could see widespread adoption of DPPs in the next few years.
The revision of the NLF builds on the shorter-term simplification measures proposed in the Omnibus IV package of draft legislation presented in May 2025 and currently working its way through the EU legislative process. The Omnibus IV proposals include amendments to 20 pieces of EU harmonised product legislation for CE-marked products and seek to introduce digital Declarations of Conformity (DoCs) and flexibility to provide digital instructions for use, and empower the European Commission to adopt common specifications to fill the gap where harmonised standards are not yet in place. The Omnibus IV proposals would require the DoC and instructions be provided on a DPP, where a product is required to have a DPP under EU law.
Whilst one of the focuses of the Omnibus IV proposals is to reduce administrative burdens, in practice, we consider that there is a real risk that they will have the opposite effect. For example, the proposals include new obligations that may mean changes will need to be made to hardcopy labelling, in-box materials, digital instructions and DoCs – potentially increasing burdens and costs in the short term. Similarly, whilst we are aware of widespread industry support for e-labelling, if the NLF revisions mandate much wider adoption of DPPs, this will increase burdens for businesses in the short term, which will need to digitalise product compliance documentation for existing products.
A public consultation for the proposed revision of the NLF is planned for Q4 2025. Draft legislation is expected to be presented around Q3 2026, as part of the proposed European Product Act announced in the European Commission’s 2026 work programme. We will continue to blog updates on this topic on Productwise.
