Regulatiivse kontrollnõukogu arvamus - SEC(2026) 565, SWD(2026) 565, SWD(2026) 566, COM(2026) 565

EUROPEAN COMMISSION

22.05.2026

SEC(2026) 565

REGULATORY SCRUTINY BOARD OPINION

{COM(2026) 565}

{SWD(2026) 565-566}

Impact assessment / Omnibus to simplify energy product legislation

________________________________

This opinion concerns a draft impact assessment which may differ from the final version.

Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 [email protected]

EUROPEAN COMMISSION REGULATORY SCRUTINY BOARD

Brussels, RSB

Opinion

Title: Impact assessment / Omnibus1 to simplify energy product legislation

Overall opinion: Not qualified

(A) Policy context The omnibus focuses on the labelling framework and foresees the amendment of Regulation (EU) 2017/1369 of the European Parliament and of the Council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU (Energy Labelling Regulation) and of Regulation (EU) 2020/740 of the European Parliament and of the Council of 25 May 2020 on the labelling of tyres with respect to fuel efficiency and other parameters, amending Regulation (EU) 2017/1369 and repealing Regulation (EC) No 1222/2009 (Tyre Labelling Regulation).

(B) Key issues The Board notes the need for improvements to the quality of the report and makes the following recommendations for the lead Service to rectify: (1) The report’s analysis of non-compliance requires further development. (2) The report does not clearly differentiate the two policy options and does not

adequately assess the social impact.

(C) What to improve (1) The report should improve explanations regarding non-compliance with labelling

obligations (Problem 2), including when providing estimates on the share of non- compliance for tyres and energy labelling. The report should more effectively support its assessment by drawing on the data from the implementation reports for the Energy Labelling Regulation and the Tyre Labelling Regulation. The report should improve

1 This initiative is an omnibus on which, following the President decision P(2026)1 of 28.4.2026, the Board shall issue an opinion that is not qualified.

2

the description of the import market for the products in scope and explain better the issue of level playing field for suppliers.

(2) The report should more clearly take into account data gaps when assessing economic impacts (e.g. for M10). The report should enhance its analysis of social impacts, in particular on consumer behaviour. Regarding M3, the report should explain how it will be ensured that electronic labels are fully legible and enable informed choice. The report should also be clear about the obligations for consumer testing. Regarding M4 and M5, the report should describe what the changes will be in terms of overlaps of products at the point of sale with reviewed and non-reviewed labels and analyse the potential consequences for consumers’ ability to make informed choices.

(3) The report should more clearly present the two policy options as distinct scenarios, given that the bulk of the proposal is identical. The comparative analysis of impacts should be further developed and the comparison of the effectiveness of the two policy options should be better explained, in particular with regards to entry into force. Assumptions should be systematically described: the costs and benefits for M14 and M15 are not sufficiently explained which weakens the comparison between the two options. The report should outline the total figures and expected cost savings, including in terms of monetised administrative savings.

(D) Conclusion The lead Service should revise the report and the executive summary in accordance with the Board’s recommendations before launching the interservice consultation.

Full title Omnibus to simplify energy product legislation

Reference number PLAN/2025/2742

Submitted to RSB on 29 April 2026

Date of RSB meeting 20 May 2026

Electronically signed on 22/05/2026 12:04 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121