As part of its ongoing effort to simplify Single Market regulation, the European Commission recently published the Omnibus IV Simplification Package, which aims to support commerce by streamlining EU rules and reducing regulatory burdens for stakeholders. Omnibus measures, like this, are becoming an increasingly common way for the Commission to apply sweeping updates across a range of instruments. However, Omnibuses can bundle-in ancillary measures, which may not obviously fit with the thrust of the reform and which may go unnoticed. Stakeholders should therefore interrogate the measures to ensure they remain ahead of the curve and are not caught out by updated provisions flying under the radar.
Changes in overview
Omnibus IV, published on 21 May 2025, introduces amendments to eight legislative acts , with a clear focus on reducing red tape for Small and Medium-Sized Enterprises (SMEs) and Small Mid-Cap Enterprises (SMC). For example, their reporting obligations have been modified. Two key updates will also directly affect larger commercial operations and are especially relevant to manufacturers, importers and producers of consumer goods in the EU who have been subject to a raft of new measures in recent years. These updates are:
- Digital regulation framework – a move to 'digital by default' for compliance.
- Postponement of battery due diligence – a delay to dates by which manufacturers are expected to comply with battery due diligence.
In focus: digitalisation
A new directive and regulation have been proposed to harmonise digitalisation across several legislative instruments, with respect to reporting compliance and displaying product information. At present, paper-based compliance information may still be required for different products. This overhaul is intended to ensure that product information is 'digital by default'.
The EC's dominant digital measure is the Digital Product Passport (DPP). DPPs will enable producers and distributors to digitalise instructions and usability information, making instructions available for download and storage throughout a product's lifetime and digitally processing declarations of conformity.
Some key measures harmonised by the amending directive are:
- Directive (EU) 2011/65 – the Restriction of Hazardous Substances (RoHS) Directive
- Directive (EU) 2014/30 – the Electromagnetic Compatibility (EMC) Directive
- Directive (EU) 2014/32 – the Metrology Directive
- Directive (EU) 2014/35 – the Low Voltage Directive
- Directive (EU) 2014/53 – Radio Equipment Directive (RED)
Key measures harmonised by the amending regulation are:
- Regulation (EU) 2016/425 – the Personal Protective Equipment Regulation (PPE)
- Regulation (EU) 2023/1230 – the Machinery Regulation
- Regulation (EU) 2023/1542 – the Batteries Regulation
- Regulation (EU) 2024/1781 – the Ecodesign Regulation
Stakeholders should consider which of the amended measures apply to their products to be clear on what these updates may mean for them and which of their products will require a DPP, if digital measures aren't already in place. It will be crucial to review digital systems for current capabilities in order to ensure compliance with DPP requirements.
In focus: delayed battery due diligence
The Commission also proposes to extend the deadline for compliance with corporate battery due diligence measures set out in Regulation (EU) 2023/1542 (which we have outlined below) to 18 August 2027.
This is intended to allow time for proper compliance with the extensive new standard of due diligence in accordance with Guidance which the Commission is expected to publish by 26 July 2026.
The Commission is currently waiting to negotiate this proposal with the European Parliament, to give these changes legal effect.
Battery due diligence – compliance refresher
By the extended date of 18 August 2027, stakeholders will be expected to:
- have their battery due diligence policies verified by a notified body and ensure these are maintained and audited going forward
- keep documentation demonstrating compliance, including policy verification
- have in place a policy addressing: raw materials, transparency and traceability – including supporting documentation on material origin and quantities
- incorporate this policy into contracts and agreements
- structure management to comply with these points
- identify and assess risks to carbon impact in the supply chain and to prevent, identify, mitigate and address risks
- prepare an annual report on battery due diligence policies
- prepare public disclosure of recycling information and conclusions on the same (where applicable)
- ensure policies are disclosable to market surveillance bodies.
Whilst the delay to battery due diligence compliance has offered a brief respite, this does not mean that stakeholders should lower their standard of vigilance, and we would suggest that economic operators ought to consider the following:
- Preparation – awareness should be paid to the more onerous and resource intensive requirements of battery due diligence, for example, care should be paid to anticipating geo-political factors which may change the origin or supply chain characteristics of materials in advance of the updated due diligence deadlines, being aware of the impacts any changes may have.
- Monitoring – care should be taken when considering how to monitor this and to ensure compliance both at corporate, factory and intermediate levels is crucial.
- Policy design and integration – conducting ongoing reviews of draft and working policies, as the EC gives further guidance, may be a good way to stay on top of regulatory obligations.
- Public communication – remaining aware of the public participation requirements and what this may mean for your business.
Key takeaways
The proposed changes do not represent anything new for large companies but instead broaden and delay the effects of recent EU legislation. Stakeholders should carefully review each stage of their business and current working practices, drawing up internal long-term plans to help with futureproofing such as risk mapping, reviewing supply chains, and engaging suppliers.
Updates to EU law will not apply in the UK but companies placing products on the EU market will need to comply and should carefully consider how they may be affected. In the meantime, it remains to be seen whether the UK Government will follow suit and update the law on batteries.
Our international product liability and product safety team can support you in making sure you are fully compliant with all regulatory requirements. We monitor legislative developments closely and you should watch this space for further updates.
