Omnibus IV brings some simplifications, especially in product law

The EU Commission proposed the fourth omnibus package on May 21, 2025. Omnibus IV contains simplifications in relation to numerous product law requirements and for SMEs and companies with up to 750 employees. EU companies should be able to save a further 400 million euros in total through Omnibus IV.

With the Omnibus initiative, the EU Commission wants to reduce bureaucracy for companies and streamline numerous EU regulations to achieve this. The Commission presented the first omnibus package on February 26. It primarily provides for changes to the CSRD, the CSDDD and the EU taxonomy.

EU Commission defines new company category “Small Midcaps”

Companies with up to 250 employees are considered small and medium-sized enterprises (SMEs), while companies with more than 250 employees are currently considered large companies. In many areas, they have significantly stricter compliance obligations than SMEs. The EU Commission now wants to exempt more companies from these strict rules. To this end, it is defining a new category, small midcaps (SMCs). According to the Commission, this includes almost 38,000 companies in the EU, namely companies with between 250 and 750 employees and either a maximum turnover of 150 million euros or a balance sheet total of up to 129 million euros. The simplifications for SMCs include product law simplifications, specific exemptions from the General Data Protection Regulation (GDPR) and simplified requirements for listing on the stock exchange.

In detail, the Commission’s proposal provides for the following measures, among others:

EU Battery Regulation

Specifically for the battery industry, the European Commission is giving all affected companies more time to adapt to the new rules on compliance with due diligence obligations under the EU Battery Regulation. The start of application of these due diligence obligations is to be postponed from August 18, 2025 to August 18, 2027.
At the same time, the Commission’s guidelines on due diligence obligations, which should have been available since February 18, 2025, are now to be published by July 26, 2026. The delay of this document, which is important for practical implementation, was a key reason for the proposed postponement of the due diligence obligations.

According to the proposal, companies or groups of companies with a turnover of less than 150 million euros should also be completely exempt from the regulations on due diligence and the tracing of supply chains for battery raw materials. Previously, this limit was 40 million euros.
All affected companies would also be subject to this: Public reporting in relation to due diligence obligations should only take place for the first time within one year of the start of application and then only every three years and no longer annually.

Ordinance on fluorinated greenhouse gases

Importers and exporters of products and equipment containing fluorinated gases (F-gases) must currently register on the EU F-gas portal. This affects around 2,000 companies every month, including many small used car dealers. Under the Omnibus IV proposal, they would only have to register:

• Importers who exceed certain annual F-gas thresholds
• Exporters of certain products and equipment containing F-gases with particularly high global warming potential, which are banned in the EU and subject to export restrictions.

In product law, many documents in paper form are to be eliminated

In many areas of product law, companies currently have to provide declarations of conformity and instructions for use in paper form, among other things. In future, the digital form will be sufficient in many areas. It should also be possible to provide digital contacts. Among other things, this is intended to take account of the fact that 94% of households in Europe will already have internet access by 2024 and that consumer habits have changed considerably.

For example, for the EU Battery Regulation, the documentation of the conformity assessment procedure, the corresponding correspondence and the declaration of conformity should now be in electronic form. The instructions and safety information for stationary battery energy storage systems can also be made available in electronic form. Exceptions should only apply with regard to safety information and only if the battery energy storage systems are intended for consumers or will be used by consumers in a foreseeable manner. A digital contact is also to be included in the labeling requirements in future. Thirteen directives and eight product regulation ordinances are to be modernized in a similar way.

Recording in accordance with the General Data Protection Regulation

The record-keeping obligation of the General Data Protection Regulation (GDPR) is to be reduced for SMCs. According to the Commission’s proposal, they should only keep records if the processing of personal data poses a “high risk”.

Simplified procedures for protection against dumped and subsidized imports
The Regulation on protection against dumped imports and the Regulation on protection against subsidized imports are also to be simplified. These are intended to protect trade in the EU. They are intended to combat dumping and the granting of subsidies by non-EU countries and ensure a level playing field in the internal market.

Conclusion

The Omnibus IV package provides for a wide range of changes in the area of product law. The exemptions from the F-Gas Regulation and the postponements and simplifications in relation to the EU Battery Regulation will be of particular relevance to many companies. However, companies in the new category of small mid-caps will also feel the benefits in a variety of ways. It is to be expected that there will be further exemptions for these companies in the future.