The EU’s Green Deal is a comprehensive package of measures aimed at making the EU climate-neutral by 2050. A key aim of these policy initiatives is to empower consumers to make informed choices for more sustainable products and services. Users should have easy access to information about the environmental and social impact of products and thus become the driving force for change towards sustainable practices. Technical communication plays a crucial role here.
Manufacturers are responsible for placing safe products on the extended single market of the European Economic Area (EEA). They have to check their products meet safety, health, performance, and environmental requirements which they must identify in the applicable legislative acts and harmonized standards. Manufacturers have to carry out a conformity assessment before affixing the CE marking to the product and draw up the EU declaration of conformity.
The New Legislative Framework defines the rules for market surveillance and clarifies the use of the CE marking. Among the new, fundamental updates of the existing legislative acts are the The Green Deal and A Europe fit for the digital age.
As part of the Green Deal, the Digital Product Passport aims to provide detailed information on the environmental impact of products and to enable transparent traceability of resources and recycling processes.
With the policy of A Europe fit for the digital age, the European Commission aims to set rules with a focus on technology, data, and infrastructure. This also aims to achieve a climate-neutral Europe by 2050.
It is important for technical communicators to understand the concepts and interdependencies of these product legislative acts. Sustainability, circularity, and digitalization have a direct influence on the way in which products are developed, marketed, and used, and which and how product-related information and data will be delivered to target audiences.
The Green Deal
Ecodesign Regulation for Sustainable Products
With the Ecodesign Regulation for Sustainable Products (ESPR) (EU) 2024/1781, the European Union has set the legal framework for defining ecodesign requirements that are intended to help improve key product aspects. This is a decisive step towards promoting the sustainable production and use of products. The specific product groups to which the requirements relate will be specified in delegated acts.
The ecodesign requirements are intended to ensure products are designed to be environmentally friendly and sustainable throughout their life cycle. This includes:
- Durability and reliability
- Reusability and reparability
- Upgradeability and possibility of maintenance and refurbishment
- Information about any of substances of concern
- Energy, water, and resource efficiency
- Conservation of resources and recyclability
- Environmental impact including CO2 footprint
- Minimizing the amount of waste
The scope of the ESPR includes all physical products, their components and intermediate products. Exceptions are food, animal feed, living beings, vehicles, and medicines.
The regulation is aimed at a large number of stakeholders including customers and economic operators. New stakeholder groups, such as professional repairers and independent operators, are still being defined, the latter including refurbishers, repairers as well as publishers of technical documentation.
A key component of the ESPR is providing comprehensive product information to ensure both compliance with legal requirements and the sustainability and recyclability of products. Products need to be labeled accordingly to provide customers and market surveillance authorities easy access to relevant information.
The Digital Product Passport (DPP) is intended to provide digital access to comprehensive product-specific information relating to sustainability, the circular economy, and compliance with legislation. This includes technical documentation, a declaration of conformity, certificates, user manuals, instructions, warnings, safety information, and tracking information. The given information must comply with the applicable EU product legislative act.
The EU DPP registry will be made accessible to all economic operators, supply chain actors, and consumers as well as market surveillance authorities and customs authorities. A web portal is planned to be set up for consumers and stakeholders to facilitate access to this information.
Construction Products Regulation
The new Construction Products Regulation (CPR) (EU) 2024/3110 will replace the existing CPR 305/2011. It was enforced in January 2025 and will apply as of January 8, 2026. Elements of the ESPR – including the DPP – are incorporated in the Construction Products Regulation (EU) 2024/3110.
Right to Repair Directive
The Right to Repair Directive, which came into force in 2024, aims to empower consumers to make sustainable choices. It provides comprehensive repair information and help for finding a repairer. This directive addresses the B2C market. The scope of this directive covers a limited range of products, including household appliances such as vacuum cleaners, washing machines, refrigerators, electronic displays, and mobile phones.
A central element of the Right to Repair Directive is the European Repair Form, which provides information on the type of repair, the costs, and the repair time. The aim is to enable consumers to make informed, sustainable decisions.
In addition, a European Repair Platform will be introduced, where consumers can find repairers, sellers of refurbished goods, and buyers of defective goods.
Green Transition Directive
The Empowering Consumer for the Green Transition Directive (EU) 2024/825 is another legislative act in the B2C context. It aims to provide consumers with better information on the environmental and social characteristics of products and to protect them from unfair practices such as greenwashing. The directive highlights the importance of transparency and accurate information in the digital age and in industrial ecosystems. Its core aspects are:
- The prohibition of greenwashing and misleading information about ecological and social product characteristics
- The consistency of environmental information across all information channels (websites, instructions, labels, catalogs)
- The obligation to document and verify environmental claims
For technical writers, these regulations mean that they must ensure all information provided is clear, correct, and consistent. Violations of the requirements can result in severe penalties for economic operators.
A Europe fit for the digital age
As part of the A Europe fit for the digital age action plan, several new pieces of legislation and supplementary regulations have been enacted, including a digital law on the sharing of information and data. These highly complex regulations are particularly important for technical communication, as their implementation will have a significant impact on how information is provided and exchanged in the future and, above all, requires the provision of comprehensive information and instructions for use. The Artificial Intelligence Act and the Cyber Resilience Act are two examples important for technical communication.
Artificial Intelligence Act
The European Union Artificial Intelligence Act 2024/1689 is a far-reaching and detailed regulation that aims to make the development and use of AI systems safe and transparent. The act defines various stakeholders who play a role in connection with AI systems:
- Provider: a person, company, or organization that develops an AI system
- Deployer: a person, company, or organization that uses an AI system under its supervision
- Economic operators: persons or organizations involved in the development, sale, or operation of AI systems
- Affected persons: people who are affected in one way or another by the use of AI systems.
An important aspect of the AI Act concerns safety components, which are defined as components of a product or AI system that fulfill a safety function. The malfunction of these components can endanger the health and safety of persons or property.
Within the AI Act, AI systems are divided into risk classes, with the highest risk level being associated with strict requirements. An example of a high-risk AI system is AI-based medical software, which is subject to special requirements regarding user information and safety.
Another key issue is transparency: AI-generated content must be clearly labeled as such, and chatbots in particular must clearly inform users that they are interacting with AI. This is to protect users from misunderstandings and false assumptions.
A particularly important point of the act is the ban on social scoring by governments or companies. This practice is seen as a significant threat to people's fundamental rights and is therefore strictly prohibited in the EU. Mass surveillance by state or private actors also falls under these prohibited practices (unless there are specific exemptions such as in the area of counter-terrorism).
The act places specific requirements on high-risk AI systems, which are relevant for technical communication:
- Technical documentation: Before commissioning a high-risk AI system, detailed technical documentation must be prepared and kept up-to-date.
- Record-keeping: Automatic recording of events during the lifetime of the system must be technically possible.
- Instructions for use: AI-systems shall be provided with instructions for use, which shall be made available in an understandable digital format or by other means. These instructions must contain clear, complete, and relevant information, including the characteristics and limitations of the system and its safety aspects.
Cyber Resilience Act
In the scope of the Cyber Resilience Act (CRA) (EU 2024/2847) are products with digital elements. These products include a direct or indirect logical or physical data connection to a device or network:
- Hardware products and components: including laptops, mobile phones, and network equipment; in other words, connectable devices
- Software products and components: examples are operating systems, games, or mobile apps which can be accessed by e-mail, stream, download, or other ways of access.
Remote data processing solutions if performing a product function also fall within this scope. Products must have an appropriate level of security. All user information and instructions shall provide clear, understandable information about the product with digital elements, its secure use, and security-relevant information. A “new” type of information is described in the CRA, namely the Software Bill of Material (SBoM) which is a formal record containing details of components included in the software of the product with digital elements.
Annex I of the CRA describes the essential cybersecurity requirements, which contain an appropriate level of security, security aspects which are based on the cybersecurity risk assessment and vulnerability handling requirements (e.g. information about fixed vulnerabilities and free-of-charge security updates.
For technical communication this means that manufacturers, importers, and distributors must ensure that their products are provided with the necessary instructions, either in paper form or electronically. These instructions must be clear, understandable, and legible, written in a language that can be easily understood by users and market surveillance authorities.
Machinery Regulation
The Machinery Regulation (EU) 2023/1230 entered into force in 2023 and will apply as of January 14, 2027 to replace the Machinery Directive 2006/42/EC. The regulation is applicable for the B2B and the BC2-market.
In the digital age, connectable machines shall comply to the concerned EU legislative act. The AI Act, the CRA and other legislative acts are applicable when AI is used in machinery, in smart machines, Internet of Things or remote maintenance. Safety components must be evaluated due to their physical and digital components.
That means, based on the risk assessment, the information given to all stakeholders, the manufacturer shall evaluate the physical safety and the digital security aspects of the machine.
Future prospects
These new legislations will have a lasting impact on product development and the market in the EU. With the aim of promoting the circular economy and supporting responsible consumption, they form the basis for a comprehensive transformation of the entire product landscape. Manufacturers and other economic operators face the challenge of implementing far-reaching changes and taking measures to comply with the new requirements.
As the Green Deal and the legislation of the digital age introduce extensive information obligations for products, this will have a significant impact on technical communication. This will become relevant for a wide range of products with more detailed information required for existing and new target audiences. As a result, technical communication will become even more important and an indispensable part of the product strategy.