In a lengthy position paper entitled “Simplifying the EU Digital Rulebook: Clarity, Simplicity, and Agility for Competitiveness” and published on Thursday 17 July, BusinessEurope is jumping on the European regulatory simplification bandwagon, detailing, regulation by regulation, the changes that the employers’ organisation believes should be made to European rules for the digital sector to ensure better application by businesses and avoid losing competitiveness.
According to the organisation, one of the biggest points to rectify remains the “harmonisation” and “overlapping” of numerous pieces of legislation. It cites as examples the Digital Services Act and the General Product Safety Regulation, which do not have the same definition of “non-compliant” and “illegal” products (see EUROPE 13668/13).
Harmonisation of key terms (such as “product“, “risk” or “substantial modification”) and definitions is singled out as being too “diverging”.
The organisation recommends the creation of a “centralised / domain glossary of standardised terms within the EU legal frameworks”, with an obligation to systematically cross-reference definitions when drafting new legislation.
It also recommends aligning certain terminology relating to the AI Act and the DSA to ensure genuine transparency of algorithms, as well as reviewing existing legislation to combat ‘addictive patterns’ and other ‘dark patterns’ in online applications and platforms (see EUROPE 13638/14), before seeking to create new legislation (see EUROPE 13683/12).
BusinessEurope also states that many of the ‘reporting’ obligations are redundant, and points to the introduction of the digital product passport (see EUROPE 13618/33), which should be authorised as a replacement for the Declaration of Conformity (DoC) documentation and not as a parallel addition of administrative documentation.
Overall, the organisation claims that the main problem remains the excessive and uncoordinated complexity of Europe’s digital regulatory framework, which creates a disproportionate administrative burden and legal uncertainty for businesses, at the risk of weakening their competitiveness.
To see the document: https://aeur.eu/f/hyi (Original version in French by Isalia Stieffatre)