The implementation of short transition periods for legislative proposals in connection with mandatory third-party certification is causing major problems for German and European manufacturers. This strongly affects their ability to continue selling their products after the deadline for the implementation of those legislative proposals without delays.
Capacities of third-party conformity assessment bodies are designed for regular demand and not for the assessment of a large number of products on the market for a target date. Delays in the citation of harmonised standards in the EU Official Journal additionally burden third-party conformity assessment bodies. This is because more and more legislative proposals stipulate the mandatory involvement of a Notified Body (certifier) in cases where harmonised standards are not cited or not applied (e.g. Radio Equipment Directive, Machinery Regulation, Cyber Resilience Act, AI Act). There is need for an extension of the transitional period for the Radio Equipment Directive. Without such an extension and without the timely citation of harmonised standards for cyber security in the EU Official Journal, there is a threat of market disruptions as of 1 August 2024.