regulations

Omnibus IV: Proposal Contents and Impact on DPP

The Omnibus IV digitalisation proposal (COM(2025) 504) introduces digital product information and common specifications. What changes vs what stays a proposal.

4/3/2026 · 9 min read · InfoDPP

What This Article Covers — and What It Does Not

This article analyses the Omnibus IV legislative package based on the official Commission proposals (COM(2025) 504 and COM(2025) 503, registered by the Council as ST 7242 2026 INIT and ST 7208 2026 INIT). Everything described below refers to what is in the proposal text. Where the outcome is uncertain because the co-decision process is ongoing, we say so explicitly.

This is not a prediction article. It is a reading of what the Commission put on the table.

Proposal status as of April 2026: legislative proposal — not adopted law.

Update, June 2026: On 9 June 2026 the Council presidency and European Parliament negotiators reached a provisional political agreement on Omnibus IV. The deal covers the digitalisation and common-specifications strand described in this article, plus a separate strand that creates a new “small mid-cap” (SMC) company category (fewer than 1 000 employees and up to EUR 200 million turnover, or up to EUR 172 million balance sheet). The agreement explicitly references Toy Safety among the affected product rules. It remains a provisional agreement: Council and Parliament still have to formally endorse it, followed by legal-linguistic revision, before adoption and publication in the Official Journal. The DPP-relevant analysis below is unchanged by the agreement.

What Is Omnibus IV

Omnibus IV is a European Commission legislative package proposed on 21 May 2025. The Council of the European Union registered the texts in March 2026. Its digitalisation and common-specifications strand consists of two instruments:

A draft Regulation — COM(2025) 504 — amending seven existing regulations: (EU) No 765/2008 (accreditation and market surveillance), (EU) 2016/424 (cableway installations), (EU) 2016/425 (personal protective equipment), (EU) 2016/426 (gaseous-fuel appliances), (EU) 2023/1230 (machinery), (EU) 2023/1542 (Battery Regulation), and (EU) 2024/1781 (ESPR), as regards digitalisation and common specifications. It does not amend the F-gas Regulation: within the wider Omnibus IV package, the F-gas Regulation (EU) 2024/573 is amended by a separate instrument, COM(2025) 501, which simplifies F-gas registration obligations and is unrelated to the DPP.
A draft Directive — COM(2025) 503 — amending 13 existing product-legislation directives (machinery, RoHS, recreational craft, pressure equipment, marine equipment, and others) as regards digitalisation and common specifications.

The package is part of a broader simplification initiative targeting administrative burden across EU product law. It is not specific to DPP — but it directly changes how DPP-relevant information is communicated, standardised, and enforced.

What Is in the Text: Three DPP-Relevant Points

1. Broader Digitalisation of Compliance Information, But Not a Blanket “QR-Only” Rule

The proposal expands how product-law information can be provided digitally, but not in one uniform way for every product. Across the amended texts, the recurring elements are:

a mandatory digital contact for the manufacturer on the product and in the EU Declaration of Conformity
wider use of an internet address or machine-readable code for the EU Declaration of Conformity in the amended directives
the possibility, where a sectoral act allows electronic instructions, to provide those instructions electronically with safeguards for end-users
where other Union law already requires a DPP, certain DoC and instruction information to be stored only in that DPP instead of duplicated elsewhere

In the directive text, the “digital contact” is a freely accessible online communication channel, such as an email address or website contact form, that should not require registration, extra apps, or personal-data disclosure merely to contact the economic operator.

What remains outside this simplification: Essential safety information, on-product warnings, and, in several amended acts, paper instructions on request or core paper safety content.

Why this matters for DPP: Omnibus IV supports the use of the DPP as a single digital location for compliance documents where a sectoral passport already exists. It streamlines documentation around the DPP; it does not create a DPP for every product by itself.

💡 Real-world example: If a product is already subject to a sectoral DPP and an amended directive allows the DoC or electronic instructions to be accessed online, the manufacturer can consolidate those documents in the DPP instead of maintaining separate digital storage locations. Critical warnings still stay on paper or on the product where required.

2. Common Specifications as an Exceptional Fallback

The proposal introduces common specifications (CS) as implementing acts that can provide a route to compliance when harmonised standards do not offer a usable route in time or do not adequately address the requirement. In the operative text, this is framed as an exceptional or last-resort mechanism, not a general shortcut around CEN/CENELEC standardisation.

CS can still provide a presumption of conformity. The safe takeaway, however, is narrower than many summaries suggest: Omnibus IV opens a fallback path if harmonised standards are absent, insufficient, or not available in time; it does not make CS the new default for DPP implementation.

Why this matters for DPP: The DPP infrastructure still depends on harmonised standards from CEN/CENELEC JTC 24. If those standards are not usable in time for a sectoral obligation, CS could provide interim technical certainty. That would still be a backup path, not the normal route.

💡 Real-world example: If a future sectoral DPP obligation starts to apply before the harmonised standard offers a workable compliance route, the Commission could use the CS mechanism to bridge that gap. That would be an exceptional fallback, not a permanent replacement for the standardisation process.

For a detailed explainer on common specifications: Common Specifications: The EU’s Fallback Plan for DPP Standards.

3. Single Digital Storage Where a DPP Already Exists

One recital and several operative amendments point in the same direction: if another applicable Union act already requires a DPP, information from the DoC and, where relevant, instructions provided electronically may be placed only in that DPP.

Why this matters for DPP: This is the clearest DPP-specific compliance effect in the package. It reduces duplication across overlapping product rules, especially for products that already fall under a passport regime such as batteries.

💡 Real-world example: A product covered both by a sectoral passport regime and by an amended product directive would not need parallel digital repositories for the same compliance documents, provided the sectoral act already requires the DPP.

Where the DPP-Relevant Effects Sit

Part of package	DPP-relevant effect
Draft Regulation — COM(2025) 504	Aligns ESPR/battery-related product-law architecture, extends the common-specifications fallback, and allows certain DoC/instruction information to sit only in a DPP where another Union act already requires one
Draft Directive — COM(2025) 503	Requires a digital contact on the product and in the DoC, and broadens electronic delivery of DoC/instructions in amended directives under sector-specific conditions

What This Does Not Do

To keep the factual boundary clear:

Omnibus IV does not create any new DPP data fields or requirements. Those are defined in sector-specific delegated acts.
Omnibus IV does not create a universal DPP obligation for every product covered by the amended acts.
Omnibus IV does not allow all instructions and safety information to move to QR-only form. The scope remains sector-specific and paper/on-product safeguards remain.
Omnibus IV does not change the DPP timeline. Battery passport still starts 18 February 2027; detergents DPP still 23 September 2029; toy DPP still 1 August 2030.
Omnibus IV does not replace harmonised standards. Common specifications are explicitly designed as a fallback, not a replacement.
Omnibus IV is not yet adopted law. As of June 2026 the co-legislators reached a provisional political agreement (9 June 2026), but formal adoption and Official Journal publication are still pending, and the final text may differ from the agreed version.

What Happens Next

The proposal enters the ordinary legislative procedure:

European Parliament — committee review (IMCO is the lead committee), amendments, plenary vote
Council of the EU — working party discussions, possible general approach
Trilogue — negotiation between Parliament, Council, and Commission
Formal adoption — if agreement is reached
Publication in the Official Journal — entry into force

As of June 2026, steps 1 to 3 are complete: the co-legislators reached a provisional agreement on 9 June 2026. The file now awaits formal endorsement and legal-linguistic revision (steps 4 to 5) before entry into force. Exact timing for adoption and Official Journal publication is not fixed in the texts themselves and depends on the closing procedural steps.

What Companies Should Do Now

If you are preparing for DPP

The core preparation work does not change regardless of whether Omnibus IV is adopted:

Structure your product data — composition, environmental evidence, supplier traceability, identifiers. This is the same work whether compliance documents arrive on paper or digitally.
Monitor the CS discussion — if your sector depends on standards that are not yet published, the CS mechanism may provide technical clarity earlier than the full harmonised standards path.
Map where your products already have, or soon will have, a sectoral DPP — those are the clearest cases where Omnibus IV can reduce document duplication.

If you are an importer

Digital-only product information means that compliance verification shifts further towards digital systems. This reinforces the direction confirmed by the March 2026 customs reform agreement.

Official Sources

Need to prepare your product data for digital-first compliance? Start free on OriginPass.eu — no credit card required.

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