The leaked draft of the European Product Act contains several provisions that risk undermining key principles of the New Legislative Framework and creating unnecessary regulatory burdens for industry. In particular, the draft expands the concept of essential requirements, broadens the definition of substantial modification, reintroduces extensive paper-based information obligations, and fails to introduce a horizontal exemption for spare parts.

The BDI supports modernising EU product legislation but urges the Commission to preserve technology-neutral and proportionate requirements, enable digital information solutions, and strengthen repair and circular economy objectives through a horizontal repair-as-produced principle.