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8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles

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Public consultation

ID: 1194

Lobbying Activity

27 responses

European Auto Industry Backs Lead Battery Exemptions

Association des Constructeurs Européens d'Automobiles, 13 Apr 2017

The associations support the draft amendment and request extended review periods for lead exemptions. They propose changing review timelines to four years for most entries and seven years for aluminum alloys, measured from publication rather than entry into force. They also seek terminology corrections to avoid confusion.
This gives them more time for R&D on alternatives while maintaining current production systems.

Enel urges protection for business secrets in public data

ENEL SpA, 21 Jun 2022

Enel requests removing non-financial statements and management reports from shared datasets to protect business secrets. They propose uniform specifications for data publishing and suggest adding area emission saturation levels to environmental categories. The framework should align with the EU's common dataspaces.
Excluding certain reports protects proprietary business strategies from being accessed by competitors.
Transparency groups lose the ability to easily access and compare corporate sustainability performance.

Transparency International demands full disclosure of beneficial owners

Transparency International Liaison Office to the European Union, 20 Jun 2022

Transparency International calls for including full company ownership and beneficial owner data in high-value datasets. They argue current proposals provide only basic information, failing to combat corruption or money laundering.
Access to this data enables the organization to investigate corruption and monitor financial crimes effectively.
Corrupt individuals and money launderers lose the anonymity used to hide illegal financial activities.

Insurance Europe urges free access to high-value public datasets

Insurance Europe, 21 Jun 2022

The group supports establishing a list of datasets available free via digital tools. They also request including company ownership and road traffic safety data.
Better data allows insurance companies to create more sophisticated and competitive risk models.

German industry group DIHK opposes new data reporting burdens

Deutsche Industrie- und Handelskammer, 21 Jun 2022

The DIHK supports innovation through public data but insists no new obligations for companies are created. They argue that additional requirements or the loss of existing options would create burdens for businesses.
This would allow companies to avoid costs associated with providing data in specific formats.

Consultation response

Boliden Group, 13 Apr 2017

Boliden Bergsöe som är en del av Boliden koncernen anser att det är mycket viktigt med en fortsatt förlängning/dispens med minst 5 år för användning av blybatterier till och inom fordonsindustrin. Vi stöder det bilagda dokument med de ställningstaganden som tagits fram av ACEA, JAMA, KAMA, EUROBAT…

EGEC demands open geological data to boost geothermal energy

European Geothermal Energy Council, 21 Jun 2022

EGEC calls for the public availability of all geological data related to reservoirs and other subsurface usage. They specifically request access to data from exploration licenses that did not result in operational projects.
This would help the industry identify geothermal resource areas for heating and cooling applications.
Existing license holders lose their competitive advantage by being forced to share hidden exploration data.

Finnish IT Center Backs Swift Release of High-Value Datasets

CSC – IT CENTER FOR SCIENCE LTD., 21 Jun 2022

CSC calls for swift enforcement of high-value datasets to boost research and innovation. They emphasize data quality and suggest the proposed implementation timeline is overly ambitious. They prefer soft law to avoid establishing new regulatory barriers.
Enhanced data access would increase the efficiency of public administration and research competitiveness.
Standardized legislative bodies lose authority as the center advocates for reduced regulation and soft law.

Consultation response

Association of European Automotive and Industrial Battery Manufacturers, 13 Apr 2017

Lead batteries are essential for all current and future European cars.The EU must allow the continued use, with a min. 5 years before the next review of Exemption 5. The automotive/battery industries welcome the conclusions that: -As mass-market alternative battery technologies to lead starter…

ARTICLE 19 demands free access to company ownership data

ARTICLE 19, 16 Jun 2022

ARTICLE 19 urges the Commission to include legal and beneficial ownership data. They request financial statements and ownership details be published free of charge. Without names, data is ineffective for journalists investigating corruption and business due diligence.
Open data allows the organization to detect and deter money laundering more efficiently.
Corrupt actors and tax evaders lose the anonymity needed to hide illicit activities.

International Lead Association urges five-year vehicle battery exemption extension

International Lead Association, 13 Apr 2017

The industry requests a minimum five-year extension for lead battery exemptions. They argue mass-market alternatives are currently unavailable and require significant research and testing.
The exemption avoids expensive vehicle redesigns while protecting thousands of European manufacturing jobs.
Non-European lithium-ion manufacturers lose the opportunity to enter the mass-market starter battery sector.

Consultation response

EUREC - The association of European Renewable Energy Research Centres, 21 Jun 2022

The European Commission will in Q3 adopt the Digitalisation of Energy Action Plan. The Implementing Regulation on High Value Data Sets was mentioned by DG ENER during its series of workshops held on the Action Plan in February…

Wikimedia Europe urges expansion of reusable high-value public datasets

Wikimedia Europe, 16 Jun 2022

They demand that all datasets financed by EU funds be categorized for reuse. The group also proposes including company ownership, procurement, and justice data as high-value.
This would allow the organization to integrate vast amounts of public information.
Publicly-owned enterprises would face increased transparency requirements regarding their granular spending records.

Consultation response

Stadtwerke München GmbH, 21 Jun 2022

Der Entwurf für die Draft Implementing Regulation für high-value public datasets ist in der Form zu begrüßen. Der Einbezug von öffentlichen Stellen in den Anwendungsbereich ist ausreichend.

GÉANT Association urges persistent identifiers for high-value datasets

GÉANT Association, 21 Jun 2022

GÉANT recommends including persistent identifiers to support dataset discovery and citation. They also seek alignment with the European Open Science Cloud and existing data portals.
Standardizing identifiers would allow the association to accurately track and cite dataset impact.

Consultation response

The Daphne Caruana Galizia Foundation, 21 Jun 2022

The Daphne Caruana Galizia Foundation is participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as we believe that open company data is a vital tool in the fight against financial crime. The draft Implementing…

VDV Supports Limiting Scope of High-Value Mobility Datasets

Verband Deutscher Verkehrsunternehmen, 21 Jun 2022

VDV requests that mobility datasets exclude sensitive operational data. They agree data from public undertakings should remain outside the regulation's scope.
This helps transport operators avoid sharing commercially sensitive data with their competitors.

Consultation response

K-Monitor Közhasznú Egyesület, 21 Jun 2022

K-Monitor is participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as K-Monitor believes that open company data brings multiple important benefits to society: Discovery and deterrence of money laundering,…

Consultation response

FORSETI (Doctrine), 20 Jun 2022

Doctrine, a French legaltech company providing legal information services to law professionals, welcomes the opportunity of commenting on the draft implementing Act, which is unfortunately a disappointment for many re-users who expected new opportunities due to the 2019 Directive. About Article 4…

Consultation response

A123 Systems LLC., 17 Apr 2017

As a representative of the lithium-ion battery community, we disagree with the position of the lead-acid community and seek to follow the review timing recommendation of the Öko-Institut, which is the EU's own independent technical consultant on this matter. Starting the next technical review in…

Consultation response

Johnson Controls, 10 Apr 2017

We Johnson Controls Batterie AG believe that a continued exemption of at least 5 years for lead batteries is vital for future automotive applications, and support the submitted position of ACEA, JAMA, KAMA, EUROBAT and ILA.

Consultation response

, 21 Jun 2022

Sehr geehrte Damen und Herren, anbei finden Sie die Stellungnahme der Bundessteuerberaterkammer zum Entwurf des delegierten Rechtsakts “Commission Implementing Regulation laying down a list of specific high-value datasets and their arrangement for their publication and re-use” mit der Bitte um…

Consultation response

Fundación Ciudadana Civio, 20 Jun 2022

I am participating in this public consultation on the Open Data Directive, with respect to the high value dataset on Companies and Company Ownership, as I believe that open company data brings multiple important benefits to society: - Discovery and deterrence of money laundering, which costs the EU…

Consultation response

The Society of Motor Manufacturers and Traders Ltd., 18 Apr 2017

SMMT welcomes the opportunity to provide input the consultation on the Commission Draft “8th Amendment to Annex II to Directive 2000/53/EC on end-of life vehicles”, (ID Ares(2017)1520534), which the industry welcomes. Since the entry into force of the heavy metal restrictions in July 2003, the…

Consultation response

Comité des Constructeurs Français d'Automobiles, 18 Apr 2017

We CCFA believe that a continued exemption of at least 5 years for lead batteries is vital for future automotive applications, and support the submitted position of ACEA, JAMA, KAMA, EUROBAT and ILA.

Consultation response

Federazione Nazionale Imprese Elettrotecniche ed Elettroniche, 13 Apr 2017

ANIE - Federazione Nazionale Imprese Elettrotecniche ed Elettroniche, represents the association of italian battery manufacturers. ANIE Federation is one of the largest organizations of Confindustria, for size and representativeness. At ANIE adhere over 1,200 companies in the electrotechnical…

Consultation response

Campine, 13 Apr 2017

Campine NV a producer of Lead and Antimony based on batteries is based in Beerse, Belgium. We, Campine NV believe that a continued exemption of at least 5 years for lead batteries is vital for future automotive applications, and support the submitted position of ACEA, JAMA, KAMA, EUROBAT and…