The European New Legislative Framework (NLF) is the foundation for safe products, fair competition and reliable market rules in the EU Single Market. To ensure that this framework remains effective for new or revised EU legislation, it is not sufficient to establish clear requirements, procedures and responsibilities. The necessary accreditation and notification structures must also be fully operational by the date the legislation becomes applicable.
The TÜV Association emphasizes that accreditation readiness is a key prerequisite for the effective implementation of EU product legislation. If accreditation services are not available in a timely manner at national level, Notified Bodies cannot carry out their tasks on schedule. For companies, this means delayed market access, reduced conformity assessment capacity and unequal competitive conditions within the Single Market.
Key Recommendations of the TÜV Association
- Accreditation readiness is an indispensable prerequisite for ensuring that EU harmonisation legislation can be effectively applied from its date of application.
- National accreditation bodies must provide publicly accessible, digital and harmonised information on which accreditation services are actually available at any given time.
- An accreditation service should only be considered available if it is not merely offered formally, but can be processed and completed within a reliable timeframe based on established assessment criteria, sufficient technical expertise, assessor capacity and decision-making structures.
- If a required accreditation service is not currently available at national level, conformity assessment bodies should automatically be entitled to apply for that service from an accreditation body in another Member State and complete the procedure there, without requiring prior approval or a formal statement of unavailability from the national accreditation body.
ENSURING ACCREDITATION READINESS, STRENGTHENING THE SINGLE MARKET
Accreditation readiness is not a technical detail but a prerequisite for a functioning Single Market. Only when accreditation structures are available in a timely manner can conformity assessment bodies perform their tasks effectively and enable companies to place new products on the market in compliance with regulatory requirements.
The revision of the NLF should therefore be used to introduce clear rules on transparency, availability and access into Regulation (EC) No. 765/2008. The objective is neither a fundamental change to the accreditation system nor a reduction of substantive requirements. Rather, the goal is to establish a legally robust mechanism that prevents a lack of national accreditation readiness from becoming a bottleneck for innovation, product safety and market access.
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Position Paper "Accreditation readiness as a precondition for a functioning EU Single Market"
