Europe · Draft / Proposal

The proposed European Product Act (EPA) aims to consolidate and modernize EU product legislation by creating a single horizontal legal framework for product compliance. It seeks to simplify compliance obligations, improve market surveillance, strengthen digital compliance tools, and align product legislation with the digital and circular economy.

What’s New / Comparison

Proposed Framework
European Product Act (EPA)
Instead of complying with multiple product-specific horizontal rules, the EPA proposes a unified framework covering common obligations for manufacturers, importers, distributors, conformity assessment, technical documentation, digital product information, and market surveillance. It is intended to complement existing legislation such as the General Product Safety Regulation (GPSR), ESPR, Cyber Resilience Act, and sector-specific regulations.

Key Dates & Compliance Deadlines

  • Official Publish/Release Date: June 17, 2026
  • Effective Date: Legislative proposal under discussion; no legal effective date
  • Compliance Deadline: Not available. Compliance dates will be established only after the proposal is adopted and published in the Official Journal.

Affected Industries

  • Automotive
  • Electronics
  • Machinery
  • Consumer products
  • Electrical equipment
  • Toys
  • PPE
  • Construction products
  • Importers, manufacturers, distributors
  • Online marketplaces
  • Authorized representatives placing products on the EU market

Who Is Affected

  • Manufacturers
  • Importers
  • Distributors
  • Authorized representatives
  • Fulfillment service providers
  • Online marketplaces
  • Notified bodies
  • Market surveillance authorities

Prohibitions, Restrictions & Exemptions

The proposal does not introduce new substance restrictions. It focuses on harmonized product compliance obligations, digital documentation, traceability, conformity assessment, and market surveillance. Sector-specific exemptions will continue to be governed by existing EU legislation.

What Companies Should Do

  • Monitor the legislative progress of the European Product Act.
  • Review existing product compliance processes for potential harmonization.
  • Prepare for increased use of digital technical documentation and product information.
  • Assess interactions with the Digital Product Passport, GPSR, ESPR, and other EU product legislation.
  • Follow European Parliament and Council negotiations for amendments.
Key Takeaway

This medium-priority update affects automotive OEMs and suppliers with operations or sales exposure in Europe. Compliance and product stewardship teams should review applicability against current BOMs and supply agreements, and note the compliance dates above.

Reference:
https://www.europarl.europa.eu/thinktank/en/document/EPRS_BRI(2026)789349

 

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