The European Materials Handling Federation (FEM) has raised concerns about a proposal by the European Commission (EC) to modernise product legislation, saying it is contradictory around the requirements for stationary battery energy storage systems and printed instructions.

The Omnibus IV Regulation proposal, “Aligning product legislation with the digital age COM (2025) 504”, looks at the digitalisation of instructions and safety information.

The FEM’s concerns are around the Batteries Regulation (EU 2023/1542) related to the instructions and safety information for stationary battery energy storage systems and the Machinery Regulation (EU 2023/1230) regarding end-users' ability to request printed instructions.

The FEM says while it supports the proposal which simplifies compliance and updates outdated processes, it is concerned safety information and instructions for stationary energy storage systems which can now be provided digitally, must continue to be printed for any systems used, or likely to be used, by consumers.

The FEM says this is problematic for three main reasons.

The rule only applies to stationary battery energy storage systems, and excludes industrial trucks, even though they often use batteries and are a major part of the materials handling industry.

Under Article 3 of the Batteries Regulation, “industrial batteries” and “stationary batteries” are defined differently. As such, the FEM says this leaves out digital instructions for batteries used in industrial trucks.

Lastly, the Machinery Regulation (Article 10(7)) already allows digital instructions for equipment, but neither the Batteries Regulation nor the new proposal (COM 2025/504) extends that same flexibility to industrial batteries.

This, the FEM says, ultimately leads to a contradiction where a manufacturer can provide digital instructions for the machine, but must still provide printed manuals for the battery—causing confusion and extra work.

“In light of the above-explained issues, FEM recommends that Article 6(4), paragraph (a) of COM (2025) 504 is deleted and paragraph (b) is aligned with the provisions of Article 10(7) of the Machinery Regulation,” the industry body states.

The FEM was founded in 1953 and now represents more than 1,000 companies with 160,000 employees and covers 80% of eligible European firms in the materials handling sector.