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Positionspapier Position Paper on guidelines on the implementation of Article 4 of Regulation (EU) 2019/1020 on market surveillance and compliance of products

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Bitkom appreciates the opportunity to provide its views and feedback on the Commission’s draft guidelines on the implementation of Article 4 of Regulation (EU) 2019/1020 on market surveillance and compliance of products and welcomes the initiative of the European Commission to consider such a guidance document. However, some definitions made in the document are not necessary as they are already given in the Blue Guide. The requirements defined in the Blue Guide should not be exceeded in this document in order to avoid contradictions and legal uncertainties. The concept of the NLF and the explanations in the Blue Guide are a successful model that should be preserved. A guideline on the implementation of Article 4 of Regulation (EU) 2019/1020 should only cover aspects of Article 4.

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