The findings of these groups, made up of delegates from member states, are one of the last opportunities to address any issues with the revision.Take the opportunity to comment
BSIF members have already been invited to comment on the revised text, and their comments passed on to the UK representatives at the working groups, and this will continue as an ongoing process over the coming months. Comment from the UK delegation is, however, that "the earlier we can propose any amendments, the better chance we have of their being addressed”, so BSIF advice is to review the text at your earliest opportunity. The European Safety Federation (ESF) has completed a section by section comparison of the current and new versions which is being circulated to BSIF members, and BSIF will provide further guidance and information at meetings, along with feedback on the progress of the proposal.
New and greater responsibilities
The revision will take the form of a Regulation, rather than a Directive, so it will apply legally as soon as it is in force and does not require transposition into national law. The new text places largely similar responsibilities on manufacturers, importers, own-brand suppliers and distributors, grouping them all under the term ‘economic operators’ for many of its requirements. It proposes that the Regulation will become binding two years after its publication, with a further year of transition when the old Directive and new regulation will be applicable. Add to this the time for deliberation within the European Parliament, and it may be at least four years before it is in place alone. However, that time will fly by, so aim to familiarise yourself with the changes that are coming and contact the BSIF with any comments or questions you may have.