OpenLobby.EU
Explore

Alliance des industriels des solutions électriques et numériques du bâtiment au service de ses occupants

IGNES

IGNES est l'Alliance des industriels qui proposent des solutions électriques et numériques pour donner vie et animer le bâtiment au service de ses occupants.

Lobbying Activity

Response to Requirements for access to data required for switching electricity supplier

17 Jun 2025

The Commission, through this text, expresses its ambition to establish a reference model that is technologically neutral, with the aim of the seamless and efficient data exchange, supporting the broader objectives of transparency, competition, and consumer empowerment in the retail electricity market. In this regard, IGNES takes the opportunity of this consultation to draw the Commissions attention to emerging practices of electricity suppliers related to energy coaching and consumption management, which are increasingly being offered as preferential or free-of-charge features within supply contracts. These services, often provided via apps, typically require specific configuration in connection with the buildings technical equipmenta task that demands attention, time, and a certain level of technical understanding from the consumer. This configuration must generally be repeated when switching electricity suppliers, which can act as a deterrent to change. Such new solutions could swiftly become barriers to supplier switching, effectively locking in customers. Indeed, consumers may be implicitly discouraged from changing suppliers due to the burden of reconfiguring their energy management system.
Read full response

Response to Update of EU rules on radio equipment for reconfigurable radio systems

27 May 2025

IGNES welcomes the willing of the European Commission to ensure that safe devices are placing on the market and that these devices remain safe during their lifetime. Enforcing Article 3(3)(i) and Article 4 of the RED would unnecessarily increase burden, without any real added value for consumers. Since it is already the responsibility of the manufacturers to ensure that their devices remain safe and compliant with RED after software updates and uploads, IGNES supports option 0 or option 1. In case, the decision will be to another option, it is essential to define clearly which device is considered as reconfigurable radio systems. Only products capable of hosting third-party software, not developed by the equipment's market provider, should be considered reconfigurable.
Read full response

Response to Technical description of important and critical products with digital elements

11 Apr 2025

IGNES (Alliance des industriels des solutions électriques et numériques du bâtiment au service de ses occupants) would like to submit some comments (see attached file).
Read full response

Response to Review of ecodesign and information requirements for external power supplies (EPS)

16 Dec 2024

IGNES would like to draw the attention on the scope of the proposed revised text, which is not as clear as the current Regulation 2019/1782. In the proposed revised regulation for EPS (EU) 2019/1782, we don't understand exactly what is covered by "household and office products". A definition would be welcomed. Such unclarity may lead to legal uncertainties. IGNES proposes to reintroduce the list of products to be powered by EPS based on (EU) 2023/826, Annex II, in order to have a clear understanding of the regulation and its application. What's more, EPS used in fixed home and building power distribution systems (such as Video door phone syetms, wired doorbells...) seem to be covered by the proposed revised regulation; however some of the requirements (for example, requirements of interoperability given in Annex I at article 3 item c, no load condition) are not suitable for such EPS. IGNES proposes to exclude such products as well as PoE products from the scope of the regulation. Lastly IGNES would like to point out the requirements on Marking (Annex I article 5, Table 6).The required markings on the nameplate are unrealistic when compared to the actual sizes of the products, they dont fit on the products. IGNES proposes to reduce the amount of data, in relation with the output values, provided on the nameplate to make it understandable to the user and to make it more compatible with the size of the products. IGNES supports all the comments proposed by CECAPI (the European Committee of Electrical Installation Equipment Manufacturers).
Read full response

Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

IGNES together with GIMELEC take note of the evaluation roadmap presented by the European Commission in order to evaluate the Directive 2014/94/UE on the deployment of Alternative Fuels Infrastructure five years after its adoption. Ex-post evaluation represents an important tool of “Better Regulation” that is fully supported. In this context, this evaluation will help to assess the implementation of Directive 2014/94/UE and to favor the development of a more sustainable mobility in Europe especially through the deployment of e-mobility, that highly contributes to EU overall sustainable development’s objectives. Concerning the scope of this evaluation, the coherence of the regulatory framework corresponds to a major dimension. This dimension should also include the interaction of other European legislations with this Directive, with the goal of supporting a strong European industry in the emerging markets for alternative fuels, in consistency with EU industrial policy objectives. Market surveillance concerning the implementation of the requirements could also be integrated in the evaluation.
Read full response

Response to Evaluation of the Low Voltage Directive 2014/35/EU

17 Nov 2017

IGNES Position on the Evaluation of the Low Voltage Directive 2014/35/UE IGNES (Companies for Digital, Energy and Security Technologies) takes note of the Fitness Check Roadmap published the 30th of October 2017 and would like to thank the European Commission for the opportunity to give its views on the evaluation of the Low Voltage Directive 2014/35/UE (LVD). As a consequence, IGNES wants to share with the European Commission the following views and suggestions: 1) LVD has been revised recently as it fully applies since the 20th of April 2016, let’s implement it before changing it again. Following issues could be usefully further improved in order to implement the current LVD: • The full process for having all relevant standards cited in the OJEU; • The management of the New Approach Consultants is in complete revision and thus the impact of this is unknown; • The situation regarding the legal requirements applicable to standards to be cited in the OJEU could be clarified. 2) The scope of the current LVD is adequate. 3) LVD has been implemented for more than 40 years and has demonstrated that it works well. 4) The technical aspects and requirements of the current LVD are sufficient and answer to its objectives regarding safety and health. The safety level of products complying with the LVD is good. 5) In this framework, the current LVD should be fully implemented within the European Union and Market Surveillance is of the utmost importance. IGNES therefore suggests: a) To call for an effective Market Surveillance by Market Surveillance Authorities (MSA) in order to fight against non-compliant products within the EU, for the benefit of the safety of consumers and a level playing field for economic operators. b) To improve the recognition of private data by MSA: • This recognition should of course be part of a fully secured process that guarantees confidentiality, impartiality and the respect of compliance rules. • It will represent an economic gain for the whole society and contribute to the efficiency of MSA activities especially in reducing the processing time of their actions. c) To improve market surveillance through the Product Safety and Market Surveillance Package. 6) Concerning the relationship with other EU Directives, IGNES considers that the interaction should be improved especially with the Radio Equipment Directive (RED) 2014/53/UE. This Directive does not in fact authorize the double conformity with RED and LVD. The requirement of a double listing seems to be questionable, as a legal cross-reference to the LVD safety requirements already exists in the RED and LVD standards cited in the OJEU already give presumption of conformity. 7) If it is decided to revise the LVD, then the unnecessary burden on manufacturers shall be reduced, such as to provide an alternative to the postal address marking by marking a Web address. This will additionally ease the action of MSA when they want to find or contact an economic operator. A web address can enable a rapid access to information, especially to a unique physical address in different countries, which can be updated when needed. In conclusion, IGNES calls for a stronger public-private partnership and remains at the disposal of the European Commission to support their efforts to improve safety for the benefits of all stakeholders.
Read full response