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AGORIA

Agoria represents technology companies in Belgium, supporting over 2,000 members with consulting, business development, and policy advocacy services.

Lobbying Activity

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

26 Jan 2026 · European Competitiveness Fund

Agoria proposes new metrics for EU Digital Decade monitoring

24 Dec 2025
Topic — Review of the Digital Decade Policy Programme to assess if 2030 targets require amendment.
Message — Agoria recommends including 5G uptake and AI adoption as key performance indicators for 2030. They suggest measuring the removal of national telecom obligations to ensure regulatory simplification. The group cautions against frequent KPI changes to maintain consistent tracking over time.12
Why — These changes would lower administrative burdens and provide clearer international investment comparisons for companies.34
Impact — Specialized fiber providers might lose policy focus if technology-specific coverage metrics are scrapped.5
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Meeting with Yvan Verougstraete (Member of the European Parliament)

4 Dec 2025 · EU Industrial Policy

Meeting with Benoit Cassart (Member of the European Parliament)

4 Dec 2025 · Surcapacité de l'acier sur le marché européen

Meeting with Kathleen Van Brempt (Member of the European Parliament)

16 Oct 2025 · Impact EU-US trade deal on the manufacturing industry

Agoria demands export solutions before extending the CBAM scope

16 Jul 2025
Topic — The consultation concerns extending the carbon border adjustment mechanism to include downstream products.
Message — Agoria states expanding the scope is impossible without an export solution. Without an export solution, the mechanism should be put on hold. They suggest sandboxing to test the expansion before it is rolled out.123
Why — An export solution would ensure manufacturing competitiveness is not further negatively affected.4
Impact — European companies face a competitive disadvantage on non-European markets, increasing carbon leakage.56
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Response to EU rules on medical devices and in vitro diagnostics - targeted evaluation

14 Mar 2025

As the opportunity is given, this document provides some feedback on the MDR and outlines potential solutions. While some European organizations with whom we are in contact, primarily represent large corporations, this feedback focuses therefore on the perspectives of startups, small and medium entreprises, innovation in general, and the need to foster an industrial fabric in Europe. Recommendations: To make the EU MDR more attractive for startups or SMEs launching innovative medical solutions, key changes should focus on reducing costs, speeding up approval times, and providing regulatory flexibility without compromising patient safety. Here are some opportunities: 1. Introduce a Fast-Track Pathway for Startups & Breakthrough Devices Problem: Startups face long and costly approval processes, making it difficult to bring innovative solutions to market. Solution: Create an EU equivalent of the FDAs Breakthrough Devices Program, offering: Priority review by Notified Bodies for devices with significant clinical benefits. Flexible clinical evidence requirements for breakthrough technologies. Dedicated regulatory guidance to help startups navigate MDR efficiently. 2. Reduce Notified Body Bottlenecks & Costs Problem: Limited Notified Bodies capacity leads to long delays and high certification costs, which startups cannot afford. Solution: Increase the number of Notified Bodies and streamline the accreditation process and harmonize the review between Notified Bodies. Introduce government-supported Notified Bodies fee reductions or subsidies for startups. Set maximum review timelines (e.g., 6 months for Class I/IIa devices). 3. Create a Startup-Friendly Approval Path for Digital Health & AI-Based Devices Problem: MDR treats software and AI-driven medical devices the same as traditional hardware, making the approval process slow and costly. Solution: Develop a dedicated software/AI regulatory framework, with: Agile approval processes for rapidly evolving AI models. Risk-based classification that avoids over-regulation of low-risk digital health tools. Continuous learning AI updates allowed without requiring full re-certification. 4. Reduce Clinical Study Burden for Startups & Small Patient Populations Problem: Clinical trials for MDR compliance are too expensive and time-consuming, especially for rare diseases or niche innovations. Solution: Allow reliance on real-world evidence and retrospective data instead of full clinical trials. Introduce an orphan medical device pathway (similar to FDAs HDE) with lower evidence burdens. Offer conditional approvals where startups can launch with limited data and collect real-world performance data post-market. 5. Improve EU-US Regulatory Alignment Problem: The FDA 510(k) process is often faster & cheaper, leading startups to launch in the U.S. first instead of Europe. Solution: Create a mutual recognition framework where MDR accepts FDA-approved devices with minimal extra steps. Establish joint EU-US pilot programs for global-first innovation approvals. Conclusion We applaud the European Parliament's initiative to seek feedback on the MDR and hope that this evaluation will be a genuine opportunity to evolve the MDR while retaining its positive aspects. About Agoria Agoria is the Belgian technology industry federation representing over 2,300 companies across various sectors, including HealthTech. The HealthTech cluster counts about 180 companies that provide technological solutions for hospitals, the pharmaceutical and life sciences industry, general practitioners and healthcare providers, and the medical industry.
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Meeting with Kathleen Van Brempt (Member of the European Parliament) and Vereniging VBO and

21 Jan 2025 · Rondetafel industrieel beleid, clean industrial deal en blik op komende wetgeving

Agoria urges mandatory iron and phosphorus inclusion in battery recycling

18 Oct 2024
Topic — The consultation establishes methodology for calculating recycling efficiency and material recovery for waste batteries.
Message — Agoria demands that iron and phosphorus be included in the mandatory recycling efficiency calculation for lithium batteries. They argue current rules allow recyclers to ignore half the battery weight and landfill these materials.12
Why — This ensures innovative recyclers are not disadvantaged by competitors using basic, low-cost methods.34
Impact — Low-tech recyclers would lose their ability to claim high efficiency while landfilling battery waste.56
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Meeting with Bernd Lange (Member of the European Parliament)

17 Jul 2024 · General exchange of views

Meeting with Bruno Tobback (Member of the European Parliament)

11 Jul 2024 · Industry challenges for the upcoming mandate

Response to Carbon footprint methodology for electric vehicle batteries

27 May 2024

The Commission's decision to deviate from product environment footprint (PEF) methodology on the use of energy attribute certificates in the draft delegated act, is based on a lack of trust in notified bodies and will have a general negative impact on the PEF methodology also in other markets. It organizes double counting and, it is questionable whether this fundamental change fits in with the Commission's mandate within the battery regulation to stay close to the PEF rules. All responsible investors in the battery value chain have engaged in green power purchase agreements to reduce their carbon footprint. It is essential that this is recognized. If not, the calculated carbon footprint of EU batteries will increase significantly not reflecting the reality and having significant impact on investments in the battery value chain, the use of Guarantees of Origin, the decarbonization effort of countries, the just transition, etc. Therefore, our suggestion is to stay close to JRC report, by preferring a combination of energy attribute certificates (guarantees of origin) and residual energy mix under strict conditions. Furthermore, the use of national average energy mixes is not in line with the EU internal energy market policy: if an average value is to be used, let it be the EU average, to be on par with our main competitors in China and in the U.S. Agoria demands that the mandate of the battery regulation is respected, and the delegated act is put in line with the PEF methodology. As for recycling, the lithium-ion battery family is too large to work with just one set of defaults. A separate set of default values must be established for specific battery chemistries such as LFP..
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Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

2 May 2024 · Green Industrial Deal

Meeting with Tom Vandenkendelaere (Member of the European Parliament, Rapporteur for opinion)

14 Nov 2023 · Net zero industry act, competitiveness, internal market completion

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

15 Jun 2023

Agoria, the sector federation for the technological industry in Belgium, fully supports the proposal to extend the applicability date of the Commission Delegated Regulation (EU)2022/30. It is important that the timing for the expected delivery of the harmonized standards and the applicability of the delegated regulation go hand in hand to ensure that manufacturers have the necessary time to adapt their products and to complete the relevant conformity procedure. Even with the proposed extended applicability date manufacturers will still have to work with a tight schedule to bring their products in conformity.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament, Rapporteur)

13 Jun 2023 · Non-road mobile machinery

Meeting with Cindy Franssen (Member of the European Parliament, Shadow rapporteur)

12 Jun 2023 · Lood/Richtlijn betreffende de limietwaarden voor lood

Meeting with Johan Van Overtveldt (Member of the European Parliament)

24 May 2023 · Speaker - industrial policy in the EU and in Belgium

Meeting with Tom Vandenkendelaere (Member of the European Parliament) and Umicore and

10 May 2023 · Critical raw materials act

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur) and Umicore

9 May 2023 · Critical raw materials acts

Meeting with Kathleen Van Brempt (Member of the European Parliament)

4 May 2023 · GDIP: critical raw material + net zero industry and the viewpoint of chemical and metal industry Belgium - APA

Meeting with Liviu Stirbat (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

27 Apr 2023 · Green Deal Industrial Plan, skills, research and innovation.

Meeting with Ciarán Cuffe (Member of the European Parliament, Rapporteur) and Stichting European Climate Foundation and

7 Feb 2023 · EPBD

Response to Revision of seven Technical Specifications for rail Interoperability: LOC&PAS, WAG, INF, ENE, NOI, PRM and RINF

27 Jan 2023

Agoria, as representative of the railway sector in Belgium, supports the comments of UNIFE concerning the "CCS TSI". These comments are detailed in the documents attached. We hope the votes of early February can at least be postponed till end of March 2023. Best regards, Amélie Cardyn, for the business group Smart Railway Solutions Agoria - Federation of the Belgian technological industry
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Meeting with Kathleen Van Brempt (Member of the European Parliament) and VERBOND VAN BELGISCHE ONDERNEMINGEN / FEDERATION DES ENTREPRISES DE BELGIQUE and

17 Jan 2023 · Roundtable discussion - A stronger Europe in the World

Agoria warns EU fluorinated gas rules will stall heat pumps

29 Jun 2022
Topic — The European Commission is reviewing rules to further reduce fluorinated greenhouse gas emissions.
Message — Agoria requests keeping the current 2030 timeline for phasing out gases. They also propose removing product bans for heat pumps.12
Why — This would allow their members to avoid the high costs of rapid product redesigns.3
Impact — Environmental targets suffer if equipment bans limit options for homeowners to switch to heat pumps.4
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

As representatives of the building technology sector in Belgium, Agoria greatly supports the efforts are being made with the Fit for 55 package to provide the right incentives for the realisation of a climate neutral building stock. The revision proposal for the Energy Performance of Buildings Directive (EPBD) contains important steps forwards. With a number of technical recommendations, Agoria hopes to further contribute to maximising the impact of the proposed policy measures upon national and regional implementation. Please find attached our feedback to the 2021 revision proposal for the Energy Performance of Buildings Directive (EPBD).
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Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

8 Mar 2022 · 50 Shades of Hydrogen

Response to Revision of the Machinery Directive

4 Aug 2021

Agoria and its members welcome the European Commission’s proposal for a regulation on machinery products. The proposal will ensure and enhance safety, by establishing ameliorations on the principles, adaptation of the current elements and by adding new elements. It will create a more clear and stable legal framework that will increase the safety of our industry. Nevertheless, Agoria submits in its accompagning position paper comments and suggestions to properly achieve those objectives.
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Response to Requirements for Artificial Intelligence

29 Jul 2021

Full position as attachement First, Agoria suggests refining the scope, by adjusting the proposed definition of AI systems, the classification of identified high-risk AI applications and the allocation of roles. The scope of the regulation is essential, requiring clear definitions that are easily interpretable and applicable. The relevant stakeholders must be able to assess whether their systems and applications are subject to the regulation and which rules apply. Second, Agoria proposes to clarify the possibilities to amend the annexes to the regulation. Additional clarification is required as to the relevant criteria, consultation procedures and implementation process. Modifications to the regulation and in particular to the scope would compromise legal certainty and predictability for the stakeholders, as well as their application of the regulation. Therefore, modifications to the regulation would require adequate consideration and consultation, which should be duly specified in the draft. It is vital that industry stakeholders are involved in the process of modification in order to provide legal clarity and bring trust. Third, the timeline will be important for the providers, for the application of both the regulation in its initial version and the modifications made afterwards. Fourth, Agoria suggests focusing on the intended uses of the AI applications, as determined by the providers. The concept of “reasonably foreseeable misuse” will undoubtedly make the application of the regulation more difficult for providers and result in discussions between the stakeholders. Also, the providers should not be liable in case of the users’ misuse of the AI application, especially if such misuse is intentional or if the provider has no means of avoiding this risk. Fifth, as regards the support for innovation, Agoria notes that the proposal recognized the administrative and financial impact it has on providers of AI systems. Agoria expects that the proposed support mechanisms will not suffice to ensure that our European companies can continue to innovate. In general, most SMEs believe that this regulation will put them at a huge disadvantage, as their size and limited resources will make it difficult to comply with this regulation. This matter should get more attention, as often it is the small-scale providers that drive AI innovation and build the applications needed to improve the quality of our lives. On the measures for small scale providers and users, Agoria supports the proposal although we consider that these measures need to be extended. While these small-scale providers and users have priority access to legal sandboxes, participating in them will require a huge time investment from their side and Agoria is of the opinion they should be financially encouraged to participate. It is positive that there will be a reduction of the cost on third-party conformity assessment, although this should be further extended to specific funding for companies that undergo a self-assessment procedure. In Belgium we see that start-ups, scale-ups and SME’s develop many of the most innovative AI applications. We think that this regulation will put them at a competitive disadvantage compared to bigger companies that already have a lot of experience with compliance mechanisms. As a final point, the European Union should consider that this regulation will have a considerable impact on its place in the AI world. A negative impact on AI applications that could have a positive impact on our society should be avoided at all costs. If the regulation hinders innovation and deters investments in the EU markets, the providers will offer their applications elsewhere. The aim to build trust in AI is crucial and so is mitigating the potential negative impact of AI, while this should not prevent the EU from reaping all the positive benefits that AI can bring to our society.
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Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Agoria, the Belgian Federation for the Technology Industry has been actively involved in the Belgian participation in IPCEIs through information sessions for Belgian companies, the setup of national cooperation platforms to gather all relevant stakeholders, the coaching of individual companies willing to make use of the IPCEI instrument. We believe that IPCEIs can be a useful instrument to develop key European industrial initiatives and to strengthen the strategic European value chains, for which public support is necessary but nevertheless the IPCEI instrument should – as it is currently defined – remain an exception only to be used when other instruments are not adequate. The main issue we want to address is the fact that, by its own nature, IPCEIs cause distortions among the Member States & Companies and that funding synergies with other EU funding programmes should be sought. SOLVE THE DISTORTION ISSUE IPCEI’s inevitably cause distortions by the fact that projects are financed by national/regional governments and not directly by EU funding programmes. The Summer IPCEI on batteries (first train of the IPCEI on Batteries) involves 17 direct participants from 7 Member States. The direct participants could receive up to approximately €3.2 billion in funding. More specifically, Belgium has sought approval to grant up to approximately €80 million; France up to approximately €960 million; Germany up to approximately €1.25 billion; Italy up to approximately €570 million; Poland up to approximately €240 million (...) (European Commission, Press release, 9 December 2019). The ratio “national support/number of companies involved” varies from €250 million per company in one Member state to less than 30 €million per company in another one. Several factors can explain this large variation but the size of the R&D national budget is undoubtedly one of them : small Member States/Regions- even if they almost reach the 3%. R&D expenditure target– are disadvantaged in comparison with other Member states. We therefore plead for the addition of EU funding to IPCEI’s and the creation of funding synergies in order to lower the discrepancies among Member States/regions in the support of their companies. Additional EU-funding as part of a more proportionate funding gap support for all individual projects, a better level playing field could be created between different Member States and between companies located in these different Member States with different support capabilities. FOSTER THE PARTICIPATION OF SME’S The barrier for SME’s to participate in IPCEI’s is quite high. Not only is the communication about IPCEI’s “for experts only” but the whole administrative parcours (eligibility, preparatory work,…) is too challenging for SME’s. Procedures should be simplified, harmonized among Member states and clearly communicated to industrial stakeholders. IMPROVE TRANSPARENCY & GOVERNANCE The whole governance of the IPCEI’s is subject to improvement : definition of the key priorities, type of projects to be supported by the IPCEI instrument, communication between Members states (a coordination by the Commission is needed) and within Member states (incl training of national civil servants), definition of KPI’s, reporting, evaluations,… We strongly encourage the definition and publication of a clear framework allowing for a maximal transparency and strong governance of the IPCEI instrument. Agoria believes that the transparency of the process would be improved if the European Commission would take the initiative to launch a Call for Expression of Interest at the EU-level for the strategic value chains (covering both EU-funding and state-aid within the IPCEI framework). Currently Calls for Expression of Interest for IPCEI’s are launched by the individual members states, if they chose to do so, in a scattered and incoherent way. This leads to a lot of uncertainty among companies (especially companies operating in several member states).
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Response to Requirements for Artificial Intelligence

10 Sept 2020

“Agoria is the Belgian federation for the technology industry. We are paving the way for all technology-inspired companies in Belgium pursuing progress internationally through the development or application of innovations and which, together, represent some 300,000 employees. We are proud that more than 1,900 member companies trust in the three pillars of our services: consulting, business development and the creation of an optimal business environment.”. Agoria thanks the European Commission for its efforts to foster Artificial Intelligence and for the opportunity to provide inputs regarding its Proposal for a legal act laying down requirements for Artificial Intelligence, which presents several options for future legislation. Firstly, Agoria is in favour of Option 1 of the alternative options to the baseline scenario, i.e. EU “soft law”, implying a non-legislative approach to facilitate and spur industry-led intervention without putting forward an EU legislative instrument. In addition, we believe that a “soft law” approach could build upon existing national initiatives and encourage a quicker industrial transformation using AI-driven systems to automate and reinvent fundamental industrial processes. Secondly, we acknowledge that others may see specific risks relating to the usage of AI in certain situations, justifying a legislative intervention. However, we must stress that the possibility of such risks arising at some point in the future does not imply that this is the case today, neither sporadically nor systematically. We urge the European Commission to analyse what is wrong in practice, before considering the optimal means of resolving these issues. Once this is clear, requirements for these specific high-risk situations will become evident and remedies may be needed. Where remedies are needed, enforcement methods should be considered, but not beforehand. Suggesting ex-ante enforcement mechanisms without any background is causing a lot of uncertainty, and SME’s specifically will be put at a disadvantage by this. Agoria believes that before choosing any option for a legislative intervention, existing regulation must be analysed carefully, identifying potential gaps precisely. This analysis should help to propose the adequate tools to fill those gaps and to establish a legally sound definition of AI. Given that AI has many meanings for different people and that many definitions of this term exist already, it is vital for the success of any AI related legislative action to define AI in a robust way. The most important aspect to keep in mind is that AI is not a product in itself, but rather a technology embedded in products, services and applications, which may be used in an extensive array of sectors, which puts all concerns related to AI in another perspective. For example, the health sector is already heavily regulated, and additional requirements should fit into the existing mechanisms. Additional unnecessary AI-related requirements within the EU product legislation should be avoided.
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

Agoria, the Belgian federation for the technology industry, supports the objectives of the European Green Deal in which technological innovations will have an important role to play to make the EU the world's first climate neutral continent by 2050. We are grateful to assist the Commission during the entire review process of the F-gas regulation. This should focus on creating a level-playing field for manufacturers across Europe and in an international context, reinforcing compliance and avoiding circumvention of current rules, removing barriers to flammable refrigerants, guarantee the reuse of recycled and reclaimed refrigerants, and retrofitting existing equipment, without compromising energy efficiency, reliability, and safety throughout the lifecycle. It is key that the revised regulation differentiates between the different sectors and their varying levels of technological readiness, allowing further innovation. Each sector has its own specific technical and commercial characteristics, with consequences for the ability to transition to lower-GWP refrigerants. Alignment with Montreal Protocol The used definitions, baselines and timelines are different between the F-gas regulation and Montreal protocol, which makes it difficult to assess potential non-compliance with the Montreal Protocol after 2030. An in-depth assessment of both, the EU F-gas Regulation and the Montreal Protocol, is required before concluding on a non-compliance of the EU F-Gas Regulation with the Montreal Protocol beyond 2030. An aligned – and if deemed necessary revised- HFC phase-down schedule under the F-Gas Regulation should in any case be announced adequately and sufficiently timely to allow the industry to adapt. Enforcement of Compliance Agoria fully supports the current F-gas Regulation and the proposed HFC phase-down but regrets the ample non-compliance with a number of aspects of the current framework which undermine the environmental objectives, create unfair competition and may also endanger the reliability and safety of the equipment. Agoria is pleased to see that in the inception impact assessment maintaining the current Regulation without changes is considered as the baseline. is. If a revision is deemed necessary, the focus should be on enforcing the existing legislation: - Avoiding circumvention of the HFC quota system, mostly by illegal imports - Strengthening F-Gas certification requirements by having stricter control and verification of products e.g. brough to market by online sales - Ensuring the safe handling of all refrigerants by increasing training opportunities for installers. A binding framework (and resources) for fact-based data regarding leakage rates and recovery rates is also necessary. Energy efficiency A technological neutral approach, ensuring innovation, is key in which both direct (via refrigerants) and indirect (via energy consumption) greenhouse gases should be taken into account, thereby respecting the objectives and requirements of the Energy Efficiency Directive, the Energy Performance of Buildings Directive, and the Ecodesign Directive and its Implementing Regulations. A system which is extremely energy efficient running on a particular HFC refrigerant can result in less emissions over its lifetime than a system which is less energy efficient but with a lower-GWP refrigerant. The correct balance may be different for each application and varies from sector to sector. Technological readiness differentiation per sector Decarbonising heating & cooling in all type of buildings by cutting energy consumption and fossil fuels is vital to achieve climate-neutrality by 2050. As outlined in other strategic communications of the Green Deal (i.a. Renovation Wave, EU Strategy on Energy System Integration) heat pumps will be a crucial technology in fulfilling these ambitious objectives.The revised F -Gas Regulation should take into account the benefits of new efficient heating and cooling technologies.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

23 Jul 2020

Agoria paves the way for all technology-inspired companies in Belgium that increase our quality of life through the development and application of technological innovations. The ETS is the EU’s flagship instrument to combat climate change, establishing a level playing field for decarbonisation for industrial plants across the EU. The MRR is an important framework for a correct accounting in ETS while also contributing to this competitive level playing field. The MRR should strive to have every emitted CO2 accounted only once while creating the same requirements for zero rating in ETS and non-ETS applications. Emission Factors for biomass should depend on the source stream used and not on the ETS installation characteristics nor location. Agoria, the Belgian federation for the technology industry, has therefore four major comments on this draft MRR revision: 1. Lack of accounting rules for CCU & CCS: The current MRR rules do not yet contain consistent accounting rules for CCU and CCS and are neither considered in this consultation. The update of the MRR provides a perfect opportunity to recognise avoided CO2 emissions by providing a consistent accounting framework i.a. for CCU materials (where the captured CO2 remains bound in the use phase) and Carbon neutral fuels (where the captured CO2 is used to make a product which releases the CO2 during the use phase) 2. Sustainability and GHG saving criteria: the zero rating of biomass can’t be considered as a “financial support scheme” as it originates from IPCC guidelines to guarantee consistent international reporting and tracking of fossil emissions. The criteria should therefore be also similar for ETS and non-ETS installations. The direct coupling of the MRR with article 29 of the RED II directive is discriminatory between ETS installations, especially paragraph 10 stipulating the greenhouse gas emission savings percentages depending on their use or entry into operation. 3. Location-specific criteria for biogas and GO’s are limiting the further production of renewable gases: the application of the revised article 39.4 requires the allowance of the member state and adds an additional condition that the operator and the producer of the biogas are connected to the same gas grid. These restrictions emphasise the lack of level playing field for the (industrial) use of biogas across the EU ETS. Some member states have more potential, certainly in the next couple of years, to produce biogas while others have a very limited potential. An ETS installation in any EU member state should be able to buy biogas without physically being connected to the same grid. We therefore believe a coherent and if possible unique framework for European Guarantees of Origin needs to be developed that facilitates cross-border trade of renewable and low-carbon gases. 4. Need to extend the scope of MRR to decarbonised, low-carbon and renewable gases (other than biogas) such as hydrogen: The draft MRR is focused on treatment of biogas for the purpose of emissions monitoring and accounting. To create a future-proof framework for accounting in the next trading period the revised MRR should be extended to ensure that other low-carbon gases receive a similar treatment as biogas. This proposal, in particular, relates to gases injected into gas networks and would help an ETS Operator burning a blend of hydrogen and methane to document the hydrogen share in its fuel.
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Response to Implementation modalities of the smart readiness indicator for buildings

16 Jul 2020

The attached position paper includes the response of Agoria to the proposal of two Implementing Acts on the development of a definition and an implementation path for the SRI, which are based on two studies that were conducted by the European Commission from 2017 to 2020. Integration into existing schemes rather than a new certificate We feel the Smart Readiness Indicator would be most successful in achieving its purpose upon integration in existing national policy schemes. We therefore would like to share the following recommendations: • Integrate options for the assessment of smart technologies in the EPC methodology • Implement possibilities for the valorisation of smart technology in the minimum energy performance requirements methodology (EPB) • Develop a (common) blueprint for the integration of smart technologies in the EPC and minimum energy performance requirements (EPB) methodologies to support Member States in a harmonised European implementation. A credible European climate policy instrument We are concerned that the focus of energy efficiency and climate change cannot be realised in practice as the benefit of applying smart technology will lie in an enhanced well-being, health and flexibility. the current focus on a new certification scheme is a missed opportunity as it will require every Member State to carry out studies individually on how to implement the SRI into their existing policy schemes. We therefore would like to share the following recommendations: • Be clear on the real benefit the SRI can offer • Support a harmonised implementation between Member States within their existing policy schemes The way forward Agoria recommends to change the approach of a separate certification scheme to the provision of supporting tools for a harmonised integration of the SRI within national legislation. These tools could range from a central organisation of the performance data to insight into ways to approach the valorisation of smart technologies in the minimum energy performance requirements (EPB) or energy performance certificate (EPC) schemes. The SRI would greatly benefit from an inclusion of other stakeholders (e.g. suppliers of flexibility) than those involved the EPC certification scheme as due to a difference in added value between the certificates. Without a clear vision on added value, the certification scheme is likely to lead to a large public costs without a clear benefit to the climate objectives in which case implementation is not recommended.
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Response to Establishment of a smart readiness indicator for buildings

16 Jul 2020

The attached position paper includes the response of Agoria to the proposal of two Implementing Acts on the development of a definition and an implementation path for the SRI, which are based on two studies that were conducted by the European Commission from 2017 to 2020. Many obligations, limited benefits The proposal for the scheme includes many descriptions for obligations, but the benefits are less clear. As implementation is voluntary, it seems an attractive business case is key to a successful implementation in Member States. We therefore would like to share the following recommendations: • Redirect the focus of the SRI towards comfort, wellbeing and/ or flexibility • Involve energy suppliers in the implementation of the scheme • Transfer the benefit of the energy supplier or network operator to the end consumer A credible European climate policy instrument We are concerned that the focus of energy efficiency and climate change cannot be realised in practice as we expect the benefit of applying smart technology will lie in an enhanced well-being, health and flexibility. The current focus on a new certification scheme feels like a missed opportunity if it will require every Member State to carry out studies individually on how to implement the SRI into their existing policy schemes. We therefore would like to share the following recommendations: • Be clear on the real benefit the SRI can offer • Support a harmonised implementation between Member States within their existing policy schemes The way forward Agoria recommends to change the approach of a separate certification scheme to the provision of supporting tools for a harmonised integration of the SRI within national legislation. These tools could range from a central organisation of the performance data to insight into ways to approach the valorisation of smart technologies in the minimum energy performance requirements (EPB) or energy performance certificate (EPC) schemes. The SRI would greatly benefit from an inclusion of other stakeholders (e.g. suppliers of flexibility) than those involved the EPC certification scheme as due to a difference in added value between the certificates. Without a clear vision on added value, the certification scheme is likely to lead to a public costs without a clear benefit to the climate objectives in which case implementation is not recommended.
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Meeting with Didier Reynders (Commissioner) and

16 Jul 2020 · AI, data protection and DSA

Response to EUGEA001 Brexit Contigency Measure

29 Jan 2019

Agoria would like to express its opinion in favour of the proposal to amend Council Regulation (EC) No 428/2009 by granting a Union General Export Authorisation for the export of certain dual-use items from the Union to the United Kingdom of Great Britain and Northern Ireland. We believe it is important in the preparedness in the event of a no-deal Brexit.
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Meeting with Piet van Nuffel (Cabinet of Commissioner Marianne Thyssen) and Council of European Employers of the Metal, Engineering and Technology-based Industries

18 Oct 2018 · Impact of Posting of Workers Directive on European companies

Response to Energy labelling requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU’s own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) computers, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. The last stakeholder meeting provided some rough estimates of active usage patterns from one Energy*compliant Notebook. The conclusions suggest that “estimates around how long computers are used for vary considerably across different studies even for the same type of computer (e.g. desktop computer)”. No actual data has been collected to quantify and therefore provide a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study to assess the significance of active power is necessary and if active power is deemed significant, selection of the right workloads will become another challenge to properly measure active mode power of computers. Without such a study, proposing an energy label based on active power metric is premature. Industry would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterize a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label We like to remind that introducing an Energy Label for computers would be a complex exercise, high configurability of computer products and based on active performance requires specific analysis together with other information requirements detailed on the Energy Label. The existing Energy* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European Green Public Procurement. Regardless the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and supports its continued basis for the Computer Ecodesign regulation review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number “hybrid devices” in the market which combine notebooks and tablets together. Further innovative designs are to be expected as customer acceptance increases. Legal uncertainty for such devices is a risk if they were to be regulated by two different regulations with potentially different requirements. Material efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of personal computers product group" in February 2017. While a few of these comments have been integrated into the final report, many of the proposed measures to improve the material efficiency of computers still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes do not make use of the information. Industry is also convinced consumers do not seek information on technical performance details such as the IP class of a device, or the battery management features. Any material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Response to Road circulation requirements for mobile machinery

18 Dec 2017

• Agoria welcomes the initiative to achieve a single market for mobile machinery. • There exists a strong need for a legislation for road circulation harmonisation that takes into account the complexity of existing technical requirements, including from occupational safety, and sector specific requirements. • Agoria wants a full EU conformity procedure without multiple approvals anymore for placing mobile machines on the market. Only having system approvals is not favoured by industry. • The conformity procedures must be such that administration and testing requirements do not produce any unnecessary costs for manufacturers and certainly of the many low volume highly specialised machines. • The new legislation should ensure a high level of on-road safety of mobile machinery. However, most aspects can be self-tested by the manufacturers without compromising safety. For this principle of self-testing no accreditation is necessary. Full third-party testing should only be done for following safety critical aspects: braking and steering. • The mobile machinery fulfilling the EU requirements should not be subject to any further technical requirements in the member states. • The drafting and maintenance of this legislation should happen as close as possible to the Commission services having the necessary legislative expertise on machinery occupational safety (Machinery Directive). • There shall be no direct relationship to the automotive sectors . The EU type approval rules for very large volumes (100 k – 200 k) are not suitable for low volume, low speed mobile machines that use roads only occasionally. Solutions from the automotive should not be pushed for problems that are non-existing and non-suitable for mobile machines. • A dedicated working group under the lead of the Commission should be set-up (It is overall recognised that the most suitable Member States experts come from the transport ministries). • The new legislation should be without prejudice to any other legislation applying to machinery and avoiding interference between the existing and the new legislation as much as possible. • The new legislation should be without prejudice to national non-technical requirements for road circulation.
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen) and Council of European Employers of the Metal, Engineering and Technology-based Industries and Gesamtverband der Arbeitgeberverbände der Metall- und Elektro-Industrie e.V.

21 Apr 2017 · Social dimension of Europe and the European Pillar of the Social Rights

Response to Commission Implementing Regulation -information provided for in Article 10 (10) of the RED 2014/53/EU

12 Feb 2017

Agoria suggests a longer transitional period than the 6 months stated in article 3 of the draft Implementing Regulation on article 10(10). In our view a 12 months period is more appropriate to finalize the complete process (from redesign over production to delivery) for updating product packaging. Agoria suggests to include in Annex II also the possibility to use the abbreviation EU in case there exists in all Member States a restriction or a requirement for authorisation.
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Response to Ecodesign requirements for electronic displays

17 Jan 2017

Agoria is the Belgian technological industry federation representing producers of TVs and displays as well as products where these displays are integrated in. The Belgian technological industry has some serious concerns regarding the new proposal for ecodesign requirements for displays. SCOPE One of the main points we would like to stress is that the scope of the proposal is too broad. The impact on a large number of type of displays was not assessed during the preparatory work. Art.15.4(b)ED, requires that an implementing measure can only include products that have been subject to prior assessment of the “impact on the environment, consumers and manufacturers (…) innovation, market access and costs and benefits”. This has not been the case for a vast range of products now potentially affected by the scope, notably for displays integrated into other products, such as industrial equipment, machinery, smart meters, boilers, heaters, automation and control equipment or domestic household equipment to name but a few. We would like to highlight the following specific problems: - LED tiles: It is at the moment not clear if these are covered by the scope. For technical reasons it is not possible to meet certain requirements and for recycling it is clear that these displays are different than others. We strongly believe these should be excluded from the scope. - 8K TVs: The assessment of technical requirements only focused on 2K and 4K TVs. To avoid inappropriate requirements with these TVs it’s necessary that they are not included until a proper assessment is carried out. - Signage displays are different than other displays but the proposed definition is too narrow - For all other ICT products it is better to wait for the assessment as part of the new ecodesign work plan 2016-2019. We therefore believe that the original scope of this draft regulation should remain limited to TV’s and computer monitors. TIMELINE Next to the scope Agoria strongly believes that the current timeline is not realistic. Considering that the final requirements are not yet known to the manufacturers the introduction date is too early. Especially taken into account the strict energy efficiency requirements. These pose a serious threat to over half the current TV models in a very short time. Therefore Agoria proposes to make the introduction more realistic by easing the energy efficiency requirements and postponing the introduction dates. RESOURCE EFFICIENCY REQUIREMENTS Requiring manufacturers not to use welding or gluing techniques other than the use of double-sided adhesive tape is far too intrusive and restrictive . It can be necessary for certain of those products to glue or weld certain parts for safety reasons or to ensure the quality of the product (such as for medical displays). The suggested repair and end of life documentation requirements seem ineffective such as for displays in industrial equipment. Overall, it should be asked if providing all information and introducing all requirements is really beneficial for recyclers and does not just impose an unjustified burden to manufacturers.
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Meeting with Günther Oettinger (Commissioner) and BUSINESSEUROPE and

8 Sept 2016 · Dual use

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

12 May 2015 · Ventilation system