Joint Statement - ‘Digital by default’ or ‘digital only’ approaches in European legislation are not neutral

19 September 2023

The European social partners representing companies and workers in the printing and paper sectors, Intergraf, Cepi, UNI Europa Graphical, FEPE, and IndustriAll Europe, have issued a joint statement, expressing their concerns about the increasing promotion of digital documents and communications as the default option in European legislation.


As the digital transition is a key priority of the European Commission, it is referenced in every piece of European Union legislation. Even though we recognise the importance of the digital transition in a broad aspect, one unfortunate consequence is that, as a result, many examples of EU legislation include references to the elimination of printed paper products (for instance, in the context of industrial products, medical products, and other consumer information). Recent examples include the consultation on an implementing regulation regarding electronic instructions for use of medical devices in 2021[1], the revision of the machinery directive in 2022[2], and the revision of the EU general pharmaceutical legislation in 2022[3]. The 2022-23 fitness check on EU consumer law[4] also focuses on digital fairness but fails to consider that promoting digital communications can affect existing offline rights. These examples are all underpinned by the Commission’s general approach to the digital transition, most recently presented in its declaration on European digital rights and principles[5], which repeatedly fails to address that digital is not neutral and print is indispensable for an inclusive digital transition which respects the fundamental rights of access to information to everyone. Print also positively contributes to inclusion and education – especially of the elderly and of people without access to digital means.


The full text of the joint statement is available here.


[1] Consultation on implementing regulation regarding electronic instructions for use of medical devices, 2022

[2] Revision of Machinery Directive and Annex, 2022

[3] Consultation on the revision of the EU general pharmaceuticals legislation, 2022

[4] Digital fairness – fitness check on EU consumer law, 2022-23

[5] Declaration on European digital rights and principles, 2022