Position Paper | Revision of the Blue Guide

Bitkom would like to take the opportunity to provide feedback on the Commission’s draft for the revision of the Blue Guide.

From Bitkom's point of view, the Blue Guide is an essential guide for economic actors in Europe.

However, we have some general remarks on the draft and would like to deal specifically with chapters 2.1 and 4.2, as these are of particular relevance to us and require correction.

The draft for the revision of the Blue Guide contains various points which are not required by any NLF directive and have no legal basis. A guidance document does not have the purpose of adding new requirements.

Furthermore we suggest that before the revision of the Blue Guide, the status of the Guide of Article 4 of Regulation (EU) 2019/1020 on market surveillance and compliance of products should be clarified.  The Blue Guide should clearly reflect the agreed guidance on Article 4 though as consistency is key to compliance and clear enforcement. Please avoid duplicate or even contradictory requirements.