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APPLiA (Home Appliance Europe)

APPLiA

APPLiA is a trade association representing the home appliance industry in Europe.

Lobbying Activity

Meeting with Jessica Polfjärd (Member of the European Parliament) and Electrolux Home Products Europe

29 Jan 2026 · CBAM

Meeting with Marlena Maląg (Member of the European Parliament) and Amica

27 Jan 2026 · Sytuacja branży AGD

Meeting with Piotr Müller (Member of the European Parliament) and Amica

27 Jan 2026 · Competitiveness of European industry

Meeting with Arba Kokalari (Member of the European Parliament, Rapporteur)

20 Jan 2026 · Digital omnibus on AI

Meeting with Peter Liese (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

8 Jan 2026 · Austausch

APPLiA urges simplified EU taxonomy rules for home appliances

5 Dec 2025
Topic — A review update to the technical screening criteria within the EU taxonomy framework.
Message — The group asks for taxonomy criteria to align with existing chemical legislation like RoHS. They propose including unlabelled energy-efficient appliances and household appliance repair services in the scope. They also recommend reducing spare part availability periods to avoid unnecessary stock costs.123
Why — Alignment with existing laws would reduce compliance costs and allow more sustainable classifications.45
Impact — Circular economy advocates may see environmental goals weakened by shorter spare part requirements.6
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Meeting with Svenja Hahn (Member of the European Parliament)

1 Dec 2025 · Steel safeguards

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

27 Nov 2025 · Participation as speaker at APPLiA Autumn Session

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

7 Nov 2025 · CBAM and Environmental omnibus

European appliance industry urges stronger enforcement of circular economy rules

6 Nov 2025
Topic — New EU Circular Economy Act on sustainable production and recycled materials.
Message — The industry coalition calls for streamlined EU-wide regulations, harmonised enforcement across member states, and removal of barriers like double taxation and complex cross-border procedures. They request realistic WEEE collection targets, mandatory quality standards for recyclates, and stronger market surveillance to prevent non-compliance.123
Why — This would reduce their regulatory burden and create fairer market conditions against non-compliant competitors.45
Impact — Non-compliant actors lose their ability to avoid waste management obligations and undercut responsible competitors.67
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Meeting with Michalis Hadjipantela (Member of the European Parliament)

4 Nov 2025 · Meeting about Digital Product Passport

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

APPLiA calls for stricter online marketplace enforcement to stop non-compliant products

23 Oct 2025
Topic — EU Digital Fairness Act proposal addressing consumer protection gaps in online commerce.
Message — The organization requests that all traders selling products in the EU must have a responsible person in the EU, or online marketplaces should assume legal responsibility. They want enforcement powers strengthened and existing databases like EPREL utilized for compliance monitoring.123
Why — This would create a level playing field by preventing cheaper non-compliant imports from undercutting European manufacturers.45
Impact — Third-party traders from outside the EU lose the ability to sell without EU legal representation.67
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Meeting with Veronica Manfredi (Director Environment)

17 Oct 2025 · APPLiA requested a meeting to discuss the non-inclusion of hafnium, a substance used in their hot water storage products, in the European Positive List.

Home Appliance Industry Urges Simplification of Digital Regulations

14 Oct 2025
Topic — Revision of EU digital legislation to reduce regulatory burden on businesses.
Message — APPLiA requests clearer definitions in the AI Act to avoid unjustified high-risk classifications, stronger trade secret protections in the Data Act, and maintenance of voluntary cybersecurity certification. They argue that overlapping digital regulations create duplication and compliance conflicts with existing product safety rules.123
Why — This would reduce compliance costs and avoid conflicting obligations under multiple legislative frameworks.45
Impact — Consumers may receive weaker data access rights and reduced protections if trade secret safeguards are strengthened.67
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Meeting with Dario Tamburrano (Member of the European Parliament)

8 Oct 2025 · Passaporto digitale del prodotto

Meeting with Danuše Nerudová (Member of the European Parliament)

8 Oct 2025 · new legislative framework for products

Response to Targeted revision of the EU rules for medical devices and in vitro diagnostics

6 Oct 2025

APPLiA represents hosehold appliances manufacturers in Europe. More info about us can be found at www.applia-europe.eu. We would like to respond to the Medical devices and in vitro diagnostics targeted revision of EU rules call for evidence with follwoing comments/questions. In general there is a strong emphasis on too much bureaucracy in this legislation, but nothing specific for our products falling under Annex XVI. Some members pointed out at following issues: - Can consumer LED devices still be sold in the market as low voltage devices for use on humans (i.e. with no intended medical purpose) even though professional medical LED units can be listed under MDR? - Does professional" mean used in the medical office rather than sold in the office for use at home? - Notified Bodies claim that they cannot evaluate LED home use products as they are Out of scope. - While for a medical device and an accessory for a medical device there are definitions that determine the meaning of the two terms, for Annex XVI products EU MDR Regulation does not provide any definition. Maybe we should consider further clarity on definition?
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Home Appliance Industry Urges Flexible CBAM Rules for Complex Goods

24 Sept 2025
Topic — EU Carbon Border Adjustment Mechanism methodology for calculating embedded emissions starting 2026.
Message — APPLiA requests a tiered approach with three calculation methods of varying complexity, from simple default values to actual emissions data. They emphasize that default values are essential for extending CBAM to complex manufactured goods like home appliances.123
Why — This would reduce compliance costs and administrative burden when importing home appliances containing CBAM materials.456
Impact — Climate goals suffer if high default values aren't calibrated properly or fail to incentivize low-carbon production.78
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and

23 Sept 2025 · Exchange of views on the Environment Omnibus

APPLiA urges exemption for motors in regulated appliances

22 Sept 2025
Topic — Revision of EU ecodesign requirements for electric motors and variable speed drives.
Message — The association requests maintaining exemptions for motors integrated into appliances already regulated by product-specific ecodesign rules. They oppose recycled content requirements for electric motors, arguing manufacturers cannot control metal supply chains and recycling infrastructure is inadequate.123
Why — This would avoid duplicate compliance costs and preserve their ability to optimize appliance efficiency as complete systems.45
Impact — Environmental advocates lose potential efficiency gains from stricter component-level standards and increased recycled material use.6
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Meeting with Yannis Maniatis (Member of the European Parliament)

17 Sept 2025 · Introductory Meeting

Meeting with Wojciech Saryusz-Wolski (Head of Unit (Ad interim) Communications Networks, Content and Technology)

12 Sept 2025 · The Commission’s Digital Omnibus – simplification of Data Act and AI Act

Home appliance industry calls for fully digital manuals

3 Sept 2025
Topic — Legislative proposal to modernize product documentation and technical specifications for the digital age.
Message — The home appliance industry requests the option to provide all user manuals and energy labels in digital formats. They argue that requiring paper safety instructions creates unnecessary workload and legal uncertainty. Furthermore, they demand that new technical specifications only be introduced if traditional standardisation processes fail.123
Why — Moving to digital documentation would eliminate millions of euros in printing and handling costs for manufacturers.45
Impact — Standardisation bodies would lose influence if the Commission gains power to bypass their technical processes.6
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APPLiA urges EU to allow fully digital manuals and labels

3 Sept 2025
Topic — Updating EU laws to allow digital documentation and set rules for technical specifications.
Message — APPLiA wants manufacturers to have the choice between digital and paper formats for all instructions. They also recommend digitising energy labels and limiting the use of technical specifications.1234
Why — This shift would significantly lower production costs and reduce the environmental impact of paper waste.5
Impact — Standardisation bodies lose their authority as the Commission bypasses established technical consensus-building processes.6
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

APPLiA, representing the European home appliance industry, acknowledges the European Commissions initiative to revisit the New Legislative Framework (NLF) way of functioning. In a time of significant digital and environmental transitions, and amid growing global competition, product legislation must offer legal certainty, coherence, and practical enforceability while safeguarding consumer safety and supporting industrial innovation. Drawing from its members longstanding engagement with EU product legislation, APPLiA would like to offer the following key recommendations that we are happy to further develop during the upcoming stages of public consultations. Please find them in the attached pdf file.
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Response to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Directive

25 Aug 2025

APPLiA would like to share its detailed comments on the Omnibus IV (Paper vs. Digital documentation & Common Specifications). You can find all the details in the attached pdf. We remain available for further exchange on this with anyone interested.
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APPLiA urges EU to expand carbon border tax to appliances

5 Aug 2025
Topic — A consultation on expanding the carbon border tax to include finished industrial products.
Message — APPLiA requests including home appliances in the carbon border mechanism's scope extension. This would stop manufacturers from moving production abroad to avoid climate-related costs. The group proposes three ways to calculate carbon costs for imported goods.123
Why — The measure would protect European appliance makers from competition with cheaper, high-carbon imports.4
Impact — Foreign importers would face higher financial charges and more complex administrative reporting requirements.5
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

28 Jul 2025

APPLiA is thankful for the continued opportunity to provide feedback on the work around designing the layout and content of the harmonised notice and label. Comments on each tool are provided in the attached file.
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APPLiA Warns Critical Raw Materials Rules Risk Fragmenting EU Single Market

25 Jul 2025
Topic — Implementing regulation identifying products with critical raw materials recovery potential under CRMA.
Message — APPLiA requests minimum harmonization principles at EU27 level to avoid fragmentation, clarification on interaction with existing frameworks like WEEE Directive, and precise thresholds rather than broad 'CRM' terminology. They want home appliances exempted or carefully scoped given low critical raw material content.123
Why — This would preserve unified product design for the single market and avoid fragmented national requirements.45
Impact — Member states lose flexibility to design national circularity programs tailored to local conditions.6
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Response to Revision of the Standardisation Regulation

17 Jul 2025

APPLiA represents household appliance industry in Europe. We would like to give our feedback to the Call for Evidence of the Standardisation Regulation Revision. See the details in the attached file. We remain available for further consultations in the future regarding this topic.
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APPLiA urges more flexibility in reporting unsold consumer products

10 Jul 2025
Topic — EU initiative specifying disclosure requirements for companies disposing of unsold consumer products.
Message — APPLiA requests extra time to establish reporting systems and clearer product classification codes. They advocate for internal verification systems instead of mandatory external audits for reporting accuracy.123
Why — This would reduce operational costs by replacing mandatory external audits with internal checks.4
Impact — Environmental stakeholders lose the assurance of independently verified data regarding discarded consumer goods.5
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Meeting with Ioana-Maria Gligor (Head of Unit Secretariat-General)

2 Jul 2025 · Exchange of views on the upcoming Digital omnibus

Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Cristina-Adriana Vasile (Head of Unit Trade)

24 Jun 2025 · Exchange on trade, competitiveness and sustainability

Response to Revised ecodesign requirements for refrigerating appliances

20 Jun 2025

APPLiA Europe appreciates the opportunity to provide feedback on the revision of the ecodesign and energy labelling requirements for refrigerating appliances. Please find our position attached.
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Response to Revised EU energy labelling rules for refrigerating appliances

20 Jun 2025

APPLiA Europe appreciated the opportunity to provide feedback on the revision of the ecodesign and energy labelling requirements for refrigerating appliances. Please find our position attached.
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APPLiA urges EU to streamline overlapping cybersecurity regulations

20 Jun 2025
Topic — The initiative revises the Cybersecurity Act and improves the European certification framework.
Message — APPLiA calls for harmonized reporting for multinationals and clearer definitions for service providers. They also recommend withdrawing specific radio equipment rules once new cyber laws apply.12
Why — This approach would reduce administrative costs and provide legal certainty for manufacturers.3
Impact — National authorities may lose flexibility as harmonized rules force consistent entity classification.4
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Response to Declaration of conformity and verification by independent auditor

16 Jun 2025

With this paper, APPLiA, the association representing home appliance manufacturers in Europe, aims to contribute to the discussion and provide our input on the proposed changes. We have identified certain provisions that could create additional burdens for manufacturers and importers of pre-charged equipment with hydrofluorocarbons (HFCs). This paper addresses these concerns and proposes adjustments for a more effective and streamlined implementation.
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Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

4 Jun 2025 · Chemical legislation (including the REACH revision & PFAS)

Home appliance industry urges practical AI integration and clear rules

3 Jun 2025
Topic — EU strategy to accelerate AI adoption and boost competitiveness across strategic sectors.
Message — APPLiA requests practical support for integrating AI into production and products, clear rules under the AI Act that avoid stifling innovation, and continuous industry collaboration during strategy implementation. They want harmonized standards as the primary compliance route, with common specifications only as a backup when standardization fails.123
Why — This would help manufacturers maintain their competitive edge while reducing regulatory burdens and costs.45
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Meeting with Dimitris Tsiodras (Member of the European Parliament)

26 May 2025 · Environmental and consumer policies

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union) and

20 May 2025 · Physical meeting - Exchange of views on the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

19 May 2025 · Meeting between DG GROW and APPLiA on Standardisation and New Legislative Framework

Appliance industry seeks phased implementation of EU deforestation rules

13 May 2025
Topic — This consultation concerns amendments to the product list covered by EU deforestation rules.
Message — APPLiA calls for phased implementation dates and a narrower scope for the regulation. They propose removing rubber and exempting safety manuals or small imports. They also suggest easing the strictness of the recycled content criterion.123
Why — These changes would reduce administrative costs and prevent redundant due diligence across supply chains.45
Impact — Environmental monitoring could weaken if rubber and small shipments are excluded from reporting.6
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Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

13 May 2025 · Discussion of the challenges that the European manufacturers face and potential solutions.

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra) and Electrolux Home Products Europe

31 Mar 2025 · CBAM

APPLiA urges simplified reporting rules for home appliance manufacturers

26 Mar 2025
Topic — Proposed amendments to make EU Taxonomy reporting simpler and more cost-effective for companies.
Message — APPLiA supports deleting specific chemical criteria and introducing a ten percent reporting threshold. They argue that compliance requirements should be significantly simplified to reduce complexity.123
Why — Companies would lower their administrative costs and improve resource allocation for core businesses.4
Impact — Environmental standards lose rigor as chemical reporting drops to the regulatory baseline.5
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Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and Climate Action Network Europe and

14 Mar 2025 · Security of Energy Supply

APPLiA pushes for appliance subsidies in EU water strategy

4 Mar 2025
Topic — The consultation seeks views on a multi-annual strategy for achieving water resilience in Europe.
Message — APPLiA recommends financial incentives like tax breaks to make high-efficiency appliances more affordable. They also argue that separate EU water consumption regulations are redundant and unnecessary.12
Why — The industry avoids new regulatory costs while benefiting from state-funded demand for premium appliances.34
Impact — Taxpayers would fund the financial incentives that primarily help households buy premium appliances.5
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

26 Feb 2025 · Energy efficient appliances, Clean Industrial Deal and Affordable Energy Action Plan

Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

11 Feb 2025 · The impact and role of the home appliance industry in the EU’s economy

APPLiA warns against short deadlines for lead use exemptions

10 Feb 2025
Topic — This consultation evaluates lead exemptions for electrical and electronic components under EU law.
Message — APPLiA requests longer deadlines for lead exemptions and rejects splitting them into complex sub-categories. They argue that safe, technically viable alternatives are currently unavailable for many appliances.12
Why — This would prevent costly production halts and reduce the administrative burden of regulations.3
Impact — Consumers risk using unsafe appliances and losing access to essential household electronics.45
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Appliance industry urges longer lead exemptions for electronics

10 Feb 2025
Topic — This consultation concerns exemptions for lead as an alloying element in electronic equipment.
Message — APPLiA requests extended deadlines and opposes splitting exemptions into specific sub-entries. They argue the proposed changes create unnecessary complexity and administrative burdens.12
Why — Maintaining current exemptions prevents supply chain disruptions and avoids unnecessary administrative costs.34
Impact — Consumers could face reduced product availability and safety risks from untested material alternatives.56
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and Electrolux Home Products Europe and BSH Hausgeräte GmbH

10 Feb 2025 · Circular economy

APPLiA demands harmonized rules to end Single Market fragmentation

31 Jan 2025
Topic — The consultation aims to remove regulatory barriers and promote cross-border trade.
Message — APPLiA calls for streamlining and simplifying rules to ensure equal standards for industry. They argue that diverse national sustainability requirements for household appliances create significant trade obstacles.12
Why — This would reduce costs by eliminating the need for market-specific products.3
Impact — National governments lose the authority to implement unique local environmental labels.4
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Meeting with Radan Kanev (Member of the European Parliament) and Orgalim – Europe's Technology Industries and

28 Jan 2025 · European Forum for Manufacturing Dinner- Decarbonisation through a technology neutral approach

Response to Amendment of Reg (EU) 2024/1834) on ED for fans driven by motors with an electric input power between 125Wand 500kW

24 Jan 2025

APPLiA appreciates the possibility of providing feedback on the amendment of the ecodesign requirements for industrial fans. Please find our position attached.
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Meeting with Kristin Schreiber (Director Internal Market, Industry, Entrepreneurship and SMEs) and GROUPE SEB and

16 Jan 2025 · Possible PFAS restriction in cookware, cutlery and home appliances under the REACH Regulation

Meeting with Alessandro Ciriani (Member of the European Parliament)

14 Jan 2025 · Introductory meeting

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

13 Dec 2024

APPLiA appreciates the possibility of providing feedback on the revision of the ecodesign requirements for external power supplies. Please find our position attached.
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Meeting with Emma Wiesner (Member of the European Parliament, Shadow rapporteur) and Ecolabelling Sweden and Stiftelsen Miljømerking i Norge (Ecolabelling Norway)

13 Dec 2024 · Green Claims

Response to Repairability score for tumble dryers

2 Dec 2024

Clear legal conditions and transition time for manufacturers. APPLiA would like to submit comments to the proposals for amendments to the energy labelling (EU) 2023/2534 for household tumble dryers published by the EU Commission on 5th of November 2024. While the association supports the introduction of a repairability index for this appliance, we reinforce the request to adopt it based on scientific evidence and in line with the horizontal methodology set up by the JRC. Finally, we recommend to include the amendments to ensure the correct applicability on the market.
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Response to Minor technical amendments to Commission Regulations on ecodesign requirements for stand by and household tumble dryers

28 Nov 2024

Clear legal conditions and transition time for manufacturers. APPLiA would like to submit comments to the proposals for amendments to the ecodesign (EU) 2023/2533 for household tumble dryers published by the EU Commission on 31st of October. While the association supports the amendments, several issues need to be addressed before its adoption.
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Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

14 Oct 2024 · discussions on Green Claims Directive

Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

Meeting with Karin Karlsbro (Member of the European Parliament)

12 Sept 2024 · Prioriteringar inför ny mandatperiod

Meeting with Jeannette Baljeu (Member of the European Parliament)

17 Jul 2024 · Green claims

Response to Minimum requirements for certification programmes and training attestations for RACHP equipment

7 Jun 2024

APPLiA, the European Trade Association representing manufacturers of home appliances, including ventilation, air conditioning and heat pump equipment, would like to share the following comments as a response to the consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council establishing minimum requirements for the issuance of certificates to natural and legal persons and the conditions for the mutual recognition of such certificates, as regards stationary refrigeration, air conditioning and heat pump equipment, organic Rankine cycles and refrigeration units of refrigerated trucks, refrigerated trailers, refrigerated light-duty vehicles, intermodal containers and train wagons containing fluorinated greenhouse gases or their alternatives, and repealing Commission Implementing Regulation (EU) 2015/2067. Main messages Scope It is APPLIAs understanding that the extension of training and certification requirements to non-fluorinated refrigerants (Art. 10 of the F-Gases Regulation) means that in order to obtain an F-Gas certificate, technicians also need to have training on non-fluorinated gases. However, those technicians that only work with non-fluorinated gases (natural refrigerants), do not need an F-Gas certificate and are out of scope of this Regulation and Implementing Act. The scope of the F-Gases Regulation is fluorinated greenhouse gases. The Regulation cannot go beyond that. Since there seem to be different interpretations on this between stakeholders, APPLiA would appreciate a clarification. Article 2 of Regulation 2024/573 clearly specifies that the legislation applies to the fluorinated greenhouse gases listed in Annexes I, II and III, whether alone or as mixtures; and products and equipment, and parts thereof, containing fluorinated greenhouse gases or whose functioning relies upon those gases. Natural gases are not mentioned in the scope article. Article 10 of Regulation 2024/573 on certification states that Natural persons shall hold at least a training attestation to carry out the following activities involving fluorinated greenhouse gases within the meaning of Article 4(7), Article 5(1) and Article 8(3), covering the fluorinated greenhouse gases specified therein, or involving relevant alternatives to fluorinated greenhouse gases, including natural refrigerants. Requiring an F-Gas certificate for technicians working solely with natural refrigerants would suddenly make activities like fridge or freezer repairs permissible only for those who possess such a certificate. Small charge category should be maintained The Commissions proposal for updated categories for the certification of persons (Art. 3) does not include a category for smaller systems. This is a change from todays situation, where the current Category II is specifically aimed at systems with refrigerant charge <3kg. In view of the future uptake of heat pumps, in particular in the residential market, such a category remains important.
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Response to Update of format of F-gas labels

4 Jun 2024

APPLiA, the European Trade Association representing manufacturers of home appliances, including ventilation, air conditioning and heat pump equipment, would like to share the following comments as a response to the consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council as regards the format of the labels for certain products and equipment containing fluorinated greenhouse gases and repealing Commission Implementing Regulation (EU) 2015/2068. Main messages 1. Transition time The F-Gas Regulation in Art. 38 and the draft text in Article 3 specify that the labelling requirements shall apply from 1 January 2025. If the final text outlining the format of labels is only published in September 2024, this leaves very little transition time for manufacturers to adapt and implement the changes. In other pieces of legislation, involving changes in labelling, such as the Energy Labelling Framework and its implementing regulations, even a transition time of 18 months between entry into force and applicability can be quite challenging. Manufacturers usually have several tiers of warehouses, e.g. factory to regional warehouse to local warehouse to dealer. Warehouses can be organised in different ways, e.g. first-in-first-out, last-in-first-out, randomly. We would therefore ask for some consideration on this and a degree of leniency from authorities for the first 6-9 months after the application of the new Regulation to allow the time for production processes to adjust. 2. Possibility to use a digital link The draft text outlines in Art 1.10 that where the size of a product referred does not allow for the legibility of the full information the text Contains fluorinated greenhouse gases' in the languages already used on the product may be complemented by a digitally readable link to the information referred to in Article 12(3), points (b) and (c), of Regulation (EU) 2024/573 in accordance with Article 12(4), second subparagraph, of that Regulation. REGULATION (EU) 2024/573 Art 12 (3) (b) the accepted industry designation for the fluorinated greenhouse gases concerned or, if no such designation is available, the chemical name; (c ) from 1 January 2017, the quantity expressed in weight and in CO2 equivalent of fluorinated greenhouse gases contained in the product or equipment, or the quantity of fluorinated greenhouse gases for which the equipment is designed, and the global warming potential of those gases. Art 12 (4) second subparagraph - The label shall be written in the official languages of the Member State in which the good is to be placed on the market, made available or supplied. In our opinion, some of the information related to the type and weight of the refrigerant could be linked to safety and waste information that is not appropriate to show via digital means. Such information should remain on the label as this is necessary for installers and for the verification by authorities. However, there could be an opportunity to simplify the amount of text shown on the label, which can be confusing. The other language versions of the text Contains fluorinated greenhouse gases' could be made available digitally. This should, however, not only be possible for products with limited size as is proposed in Art 1.10, but it should be a possibility for all products in scope of the requirements. Current practice should of course also remain possible.
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Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

12 Apr 2024

APPLiA, the European association representing home appliances manufacturers which provides a single, consensual voice for the home appliance industry in Europe, promoting industrys mission to advance Europeans' lifestyles would like to share our comments on the draft 18th amendment in the attached document.
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APPLiA demands 36-month transition for new bisphenol rules

8 Mar 2024
Topic — The Commission is proposing new restrictions on bisphenol chemicals in food contact materials.
Message — APPLiA requests an explicit list of all covered substances and the establishment of tolerance thresholds for accidental contamination. They propose extending the implementation period to 36 months to allow the entire supply chain to adapt.12
Why — A longer transition avoids financial losses from unusable inventory across the manufacturing chain.3
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Meeting with Erik Burckhardt (Cabinet of Commissioner Paolo Gentiloni), Fabrizio Balassone (Cabinet of Commissioner Paolo Gentiloni) and Beko Europe Management S.r.l.

4 Mar 2024 · Outlook of the appliance sector

Response to Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods

29 Jan 2024

APPLiA represents household appliance industry in Europe. Our FINAL response to the Mutual recognition of goods - evaluation of Regulation (EU) 2019/515 - call for evidence can be found in the attached file.
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Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

20 Nov 2023

APPLiA members welcome the proposed act as a way to clarify some critical aspects of the database. APPLiA feedback is provided on an article by article basis in the attached document.
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Response to Drinking water - procedures and methods for testing and accepting final materials

16 Nov 2023

APPLiA (Home Appliance Europe) appreciates the opportunity to provide input to the Implementing Act on procedure and methodologies for testing and accepting final materials. Below you will find APPLiA's position, but please note that you can find the comments for this specific Act on pages 6-9 of the document.
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Response to Drinking water - methodologies for establishing and amending the European Positive Lists

16 Nov 2023

APPLiA (Home Appliance Europe) appreciates the opportunity to provide input to the Implementing Act on methodologies for testing/accepting substances, compositions & constituents in European positive lists. Below you will find APPLiA's position, but please note that you can find the comments for this specific Act on page 1 of the document.
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Response to Drinking water - establishing the European Positive Lists of starting substances

16 Nov 2023

APPLiA (Home Appliance Europe) appreciates the opportunity to provide input to the Implementing Act on establishing the European positive lists of starting substances, compositions, and constituents. Below you will find APPLiA's position, but please note that you can find the comments for this specific Act on pages 2-4 of the document.
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Response to Drinking water - conformity assessment procedure

16 Nov 2023

APPLiA (Home Appliance Europe) appreciates the opportunity to provide input to the Delegated Act on conformity assessment procedure for products that come into contact with drinking water. Below you will find APPLiA's position, but please note that you can find the comments for this specific Act on pages 10-12 of the document.
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Response to Drinking water - Establishing the procedure for amending the European Positive Lists ('EUPLs')

13 Nov 2023

APPLiA (Home Appliance Europe) appreciates the opportunity to provide input to the Delegated Act on adding or removing starting substances, compositions or constituents from the European positive lists. Below you will find APPLiA's position, but please note that comments for this specific Act are on page 5 of the document.
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Response to Establishing harmonised marking to be used for products in contact with drinking water

13 Nov 2023

APPLiA appreciates the opportunity to provide input to the Delegated Act on the marking of products in contact with drinking water. Below you will find APPLiA's position, but please note that you can find the comments for this specific Act on pages 13-15 of the document.
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Response to Regulatory measure on the review of ecodesign requirements for industrial fans

2 Nov 2023

APPLiA welcomes the opportunity to provide input during the feedback period on the draft regulation on industrial fans. While APPLiA supports efforts targeted at achieving higher energy efficiency, we want to stress (i) the importance of avoiding double regulation for fans integrated into products regulated by product-specific ecodesign regulations and (ii) exempting spare parts for fans integrated into products regulated by ecodesign and those that are already exempted by Article 1. We kindly ask that these would be taken into consideration for the further development of the final regulation. Please find a more detailed position below.
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Meeting with Petros Kokkalis (Member of the European Parliament, Shadow rapporteur) and Association Internationale de la Savonnerie, de la Détergence et des Produits d'Entretien

26 Oct 2023 · Green Claims

Meeting with Laura Ballarín Cereza (Member of the European Parliament, Shadow rapporteur) and Microsoft Corporation and FoodDrinkEurope

18 Oct 2023 · Green Claims

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

5 Oct 2023 · F-gas regulation; net zero industry act

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

European standardisation evaluation call for evidence APPLiA response points. APPLiA - Home Appliance Europe represents the interest of household appliance industry in Europe. 1. While the overall New Legislative Framework (765/2008 (with 2019/1020), 768/2008, is still fit for purpose 2. in our view the European Standardisation System undergoes some difficult moments those days. There are delays in listing harmonised standards in the OJEU or the standards are not listed at all for a long time. That undermines the critical link between the European Legislation and European Standardisation, putting competitiveness of the EU industry in jeopardy. 3. The listing of standards in the Official Journal also constitutes a source of information for the authorities in charge of reviewing and enforcing the legislation. 4. The lack of listing in the OJEU or the listing of outdated standards leads to uncertainty for both manufacturers and surveillance authorities. 5. APPLiA has, for a long time, pointed out the need for a careful and thoughtful revision of the Standardisation Regulation 1025/2012. Standardisation Regulation 1025/2012/EU leaves lots of room for interpretation and uncertainty for all players including the European Commission. After the ECJ ruling in the so called James Elliott case, the European Commission has introduced a more sophisticated system. However, this has two weaknesses: a. It lacks clear requirements for the key processes, in particular deadlines and clear rules for all actors (ESOs /CCMC and COM/consultants alike) b. Commission services are, or feel, bounded by legal formalities that create innumerable small barriers to the inclusion of standards in the register. This concerns all key processes: i. The Standardisation Request ii. The acceptance for being listed iii. The Formal objections 6. We are therefore convinced that a targeted recast of the regulation is necessary to address these specific issues. 7. APPLiA would be willing to support this process with our ideas and concrete proposals. We therefore assume that we will be able to participate in the upcoming consultations, especially the targeted consultation.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Apple Inc. and Carbon Gap ASBL

28 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Energy labelling requirements for electronic displays

21 Sept 2023

APPLiA welcomes the opportunity to provide feedback to this call for evidence. Please find our position below.
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Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

APPLiA's comments to the European Union Agency for Cybersecurity and EU cybersecurity certification framework evaluation are available in the attached file.
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Sonae SGPS, S.A.

7 Sept 2023 · Green Claims

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur) and Carbon Gap ASBL and Round Table on Responsible Soy Association (RTRS)

6 Sept 2023 · Green Claims Directive

Meeting with Mercedes Bresso (Member of the European Parliament, Shadow rapporteur) and Back Market

5 Sept 2023 · proposal for a directive of the European Parliament and of the Council on common rules promoting the repair of goods

Meeting with René Repasi (Member of the European Parliament, Rapporteur)

22 Aug 2023 · Exchange of Views on the Right to Repair/ Recht auf Reparatur (R2R)

Home appliance makers urge delay for new green claim rules

20 Jul 2023
Topic — New EU rules requiring companies to scientifically substantiate their voluntary environmental product claims.
Message — APPLiA proposes making the rules uniform across Europe by using a Regulation. They suggest extending the application timeline to 30 months and removing requirements to compare products against competitors.123
Why — Companies would avoid disclosing confidential commercial information and the expense of reworking packaging.45
Impact — Consumer advocates lose the ability to compare specific environmental performance between competing brands.6
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APPLiA warns CBAM reporting risks disrupting global manufacturing chains

11 Jul 2023
Topic — Consultation on reporting obligations during the transitional period of the Carbon Border Adjustment Mechanism.
Message — The association requests the unrestricted use of default values and the immediate release of technical guidance. They also want third-country suppliers to have direct access to the registry to simplify collection.12
Why — This would prevent import bottlenecks and reduce the effort of calculating primary emission data.34
Impact — Non-EU suppliers face higher costs if default values are set at the highest level.5
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

11 Jul 2023 · Energy efficiency potential and related regulatory initiatives

APPLiA urges flexible ecodesign rules to prevent banning large ovens

26 May 2023
Topic — Commission review of energy efficiency and ecodesign standards for household cooking appliances.
Message — APPLiA requests a hybrid efficiency approach for electric ovens to avoid banning larger models. They advocate for keeping current definitions of portable ovens and excluding combi-microwaves from limits. They also propose more lenient efficiency requirements for radiant hobs.12
Why — This would allow manufacturers to maintain current production lines and avoid significant technical costs.3
Impact — Consumers would face higher prices for basic appliances and a restricted choice of models.4
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APPLiA urges regulatory coherence for EU heat pump deployment

26 May 2023
Topic — A European Commission initiative to speed up heat pump installation across buildings.
Message — APPLiA calls for coherence between deployment goals and refrigerant restrictions. They urge policymakers to preserve the Single Market and fund installer training.123
Why — Alignment prevents premature bans on existing products, protecting industry research and development investments.4
Impact — Consumers may face higher costs and safety risks from forced technology transitions.56
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Response to Ecodesign for Sustainable Products - Product priorities

10 May 2023

To whom it may concern, Please find attached APPLiA's position paper on the Working Plan under the Ecodesign for Sustainable Products Regulation (ESPR). Below are also included APPLiA's two key messages on the drafting of the Working Plan: The success of the ecodesign is a product-by-product approach. Horizontal measures should not impose common requirements to a set of products. Therefore, we suggest considering a common principle and/or a methodology to be applied on a product-by-product basis, when appropriate. The downside of the ecodesign: the cascading approach. APPLiA recommends caution when regulating components, subassemblies or material parts of a finished product and recommends regulating intermediate products only until the cradle-to-gate level. Thank you for the opportunity to provide our input. Kind regards, Anton Arabadjiev on behalf APPLiA Europe
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Response to Promoting sustainability in consumer after-sales

4 May 2023

APPLiA welcomes the publication of both Commission initiatives to promote repair and to substantiate green claims. The two texts bring stakeholders the complete picture of proposed requirements in the area of environmental and consumer protection together with the initiatives on ESPR and empowering consumers. Looking specifically at the provisions proposed in the Commission text on promoting the repair of goods, APPLiA would like to share some initial observations as per attached.
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Home appliance industry warns EU taxonomy lacks scientific feasibility

3 May 2023
Topic — The initiative classifies sustainable economic activities to guide environmental investment purposes.
Message — APPLiA requests deleting bans on hazardous substances and fluorinated gases. They argue criteria must be aligned with existing ecodesign legislation to ensure scientific feasibility.123
Why — Avoiding stricter storage requirements prevents stock destruction and reduces manufacturer compliance costs.4
Impact — Environmental groups lose as allowing hazardous substances can inhibit recyclability.5
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Meeting with Ivan Štefanec (Member of the European Parliament)

25 Apr 2023 · Packaging and Packaging Waste Regulation

Meeting with Krzysztof Hetman (Member of the European Parliament, Shadow rapporteur)

20 Apr 2023 · Exchange of views on Product Liability Directive (meeting delegated to parliamentary assistant)

Response to Ecodesign requirements for local space heaters (review)

18 Apr 2023

APPLiA, Home Appliance Europe, representing household appliance manufacturers, thanks the Commission for the opportunity to comment on the latest version of the draft ecodesign regulation for local space heaters. While we support the proposal, in the attached document we provide some input to improve the text. Thank you for taking them into consideration.
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Response to Energy labelling requirements for household tumble dryers [review]

29 Mar 2023

APPLiA welcomes the new ecodesign and energy labelling rules for household tumble dryers. These appliances unveil a true potential in terms of energy savings and will highly contribute to the objective set by the European Union through the Green Deal. Nevertheless, we recommend policymakers to consider our set of recommendations below to ensure the correctness of the regulation and a smooth application on the market. 1. Requirements supported by APPLiA: the proposed scope and definitions; the energy and resource efficiency requirements as proposed in Annex II of the Ecodesign; the limits for the energy and noise classes; the application date and the transitioning measures. 2. Request to align the off-mode requirement (Ecodesign Annex II point 4(a)) with the revised horizontal standby regulation. 3. New wording for the exemption for tumble dryers with a rated capacity of lower than 3kg (Ecodesig Article 1 point 3). 4. No further delays in ED and EL adoption due to a possible introduction of a repairability index for tumble dryers (Energy Labelling Article 8). 5. Editorial remark for the programme duration unit (Energy Label Annex VI tables 4 and 5) and on prohibited names (Ecodesign: Annex II: 6 (2) 2nd (a)). 6. Proposal to include the calculation of the final moisture content (Ecodesign Annex III). 7. Suggestion to improve the wording for the verification procedure (Ecodesign Annex IV & Energy Label Annex IX). 8. Considerations on the new structure regarding Software updates (Ecodesign Article 7(1)).
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Response to Ecodesign requirements for household tumble dryers (review)

29 Mar 2023

APPLiA welcomes the new ecodesign and energy labelling rules for household tumble dryers. These appliances unveil a true potential in terms of energy savings and will highly contribute to the objective set by the European Union through the Green Deal. Nevertheless, we recommend policymakers to consider our set of recommendations below to ensure the correctness of the regulation and a smooth application on the market. 1. Requirements supported by APPLiA: the proposed scope and definitions; the energy and resource efficiency requirements as proposed in Annex II of the Ecodesign; the limits for the energy and noise classes; the application date and the transitioning measures. 2. Request to align the off-mode requirement (Ecodesign Annex II point 4(a)) with the revised horizontal standby regulation. 3. New wording for the exemption for tumble dryers with a rated capacity of lower than 3kg (Ecodesig Article 1 point 3). 4. No further delays in ED and EL adoption due to a possible introduction of a repairability index for tumble dryers (Energy Labelling Article 8). 5. Editorial remark for the programme duration unit (Energy Label Annex VI tables 4 and 5) and on prohibited names (Ecodesign: Annex II: 6 (2) 2nd (a)). 6. Proposal to include the calculation of the final moisture content (Ecodesign Annex III). 7. Suggestion to improve the wording for the verification procedure (Ecodesign Annex IV & Energy Label Annex IX). 8. Considerations on the new structure regarding Software updates (Ecodesign Article 7(1)).
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APPLiA demands harmonised packaging rules and digital labelling options

3 Mar 2023
Topic — The EU is reviewing rules to reduce waste and improve packaging design and recycling.
Message — APPLiA seeks a harmonised approach to keep markets open and trade flowing. They request a five-year implementation time and preference for digital labels over paper versions. Reusable targets should only apply when reasonable from a technical and environmental perspective.123
Why — Extended transition periods and digital labels would reduce manufacturing costs and administrative burdens.4
Impact — Member States lose autonomy to enforce specific national labelling and waste sorting requirements.56
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

APPLiA demands unified cybersecurity rules and extended reporting deadlines

23 Jan 2023
Topic — The consultation addresses mandatory cybersecurity requirements for all products with digital elements.
Message — APPLiA advocates for the Act to be the "one stop shop" for all cybersecurity requirements to prevent regulatory overlap. They suggest extending the incident notification window from 24 to 120 hours. They also recommend a consistent 24-month implementation period for the entire regulation.123
Why — Harmonized rules and longer deadlines would lower administrative burdens and prevent supply chain delays.45
Impact — Enforcement agencies would experience slower response times to cyber threats due to delayed notifications.6
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Response to Extension of the transition period for medical devices

17 Jan 2023

There is an oversight within the proposal for transitional arrangements in respect of Annex XVI products that have now been brought within scope of the Medical Regulation. Whilst new Common Specifications have recently been established for such products, they do not benefit from existing conformity certificates under the former Medical Devices Directive. They are more likely to have been subject to national legislative provisions. These products (such as hair removal devices) now need to be subject to a conformity assessment by a notified body. In a similar fashion to medical devices more generally, there currently exist constraints vis-à-vis the availability of suitably qualified notified bodies to conduct the necessary conformity assessments. As such, similar provisions are needed to provide a suitable buffer to ensure continued market success for existing products lawfully placed on the market prior to 22 June 2023. Such provisions could reflect the criteria for medical devices more generally i.e., no significant changes to design or intended purpose, continued safe use, conformity with applicable national/EU rules, evidence of efforts to contract with a notified body etc.
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Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

10 Jan 2023 · Artificial Intelligence Act

APPLiA warns AI liability directive targets a moving mark

28 Nov 2022
Topic — The consultation concerns new liability rules for damage caused by artificial intelligence.
Message — APPLiA recommends turning the proposal into a Regulation to avoid national differences. They worry the directive depends on the AI Act, which remains unstable.12
Why — Uniform EU rules would reduce the burden of complying with different national laws.3
Impact — The Single Market suffers when member states implement different versions of the rules.4
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

APPLiA - Home Appliance Europe welcomes the evaluation of the WEEE legislation which will provide an opportunity to assess fully if the current WEEE Directive remains fit for purpose. We are one of the sectors with most experience of the WEEE Directive. Please find below our initial comments in response to the Commission's evidence call - summary below and a PDF document attached providing further elaboration of our recommendations. We look forward to working with the Commission in the months to come, as the evaluation work progresses. Key Challenges of WEEE Extended Producer Responsibility (EPR) concept is outdated Other actors outside EPR channels, driven by commercial considerations, handle significant volumes of waste. These volumes do not enter formal EPR systems. Not all WEEE is being recovered and recycled properly. While producers have taken an active role in fulfilling their legal obligations, other WEEE actors in the value chain also have responsibilities to ensure all WEEE is accounted for and treated properly. Much WEEE is not reported or accounted for While producers and producer schemes are asked to report the WEEE flows collected and treated, other actors handling WEEE can easily by-pass such reporting obligations, even if the WEEE they handle is properly collected and treated. Unrealistic WEEE collection targets Difficulties experienced by almost all Member states in reaching the collection targets opens up the debate about how realistic and fit for purpose the collection targets as defined in the Directive actually are. Raising the bar on treatment of WEEE across the EU There is still not a harmonised approach across the EU on the quality of WEEE treatment. Not all actors handling WEEE are recycling according to the EN treatment standards. Our Recommendation - Bring WEEE legislation in line with market realities and the current situation with WEEE management today "WEEE Are All Responsible" WEEE legislation should target all actors dealing with WEEE and give them the same obligations as producers under the extended producer responsibility principle. The Commission should develop requirements for all actors under the future WEEE legislation. Better monitor WEEE flows and ensure all WEEE is reported All treated WEEE, in line with the quality treatment standards, should be reported and registered as being recycled so that these volumes are reflected in the total collection and recycling results in a given jurisdiction. A shared responsibility between all WEEE actors can only be effective if there is an organised, coordinated system/body in place that is monitoring WEEE management. Review the EU target setting methods In addition to the establishment of a shared responsibility system to support in achieving collection rates, where all actors should contribute to the attainment of the target, the way the collection target is set and calculated should be reevaluated. We would recommend that the Commission investigate the possibility to continue to use a collection target based on the EEE 65% POM based on the average lifespan of the individual WEEE category rather than a blanket 65% based on the average of the previous 3 years POM. Recycling of WEEE according to EN treatment standards To ensure uniform conditions for the implementation of the WEEE Directive, the Commission should ensure that EN 50625 / EN 50614 standards are the reference for WEEE treatment. Enforcement of recycling treatment in line with these standards would help ensure market dynamics are not diverting flows from the formal system towards illegal activities. Empower the role of consumers The role of consumer behaviour is an important aspect to consider in the drive to increase material recovery from WEEE. Engaging consumers in adopting sustainable choices, particularly in the ways they dispose of their electrical products can help in increasing collection and recovery rates.
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Meeting with Alessandra Moretti (Member of the European Parliament, Rapporteur)

27 Oct 2022 · Framework for setting eco-design requirements for sustainable products

Meeting with Nicola Danti (Member of the European Parliament)

25 Oct 2022 · Ecodesign Directive

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and UNIFE

20 Oct 2022 · Data Act

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

17 Oct 2022 · US-EU Task Force Convening: energy efficiency and energy savings. The California Energy Commission, ACEEE, ASE, Advanced Energy Economy, Arcadia, ComEd, Octopus Energy, OhmConnect, OPower, Uplight and the Covenant of Mayors also participated.

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur)

17 Oct 2022 · Data

Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

5 Oct 2022 · Ecodesign for Sustainable Products Regulation

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

5 Oct 2022 · Data Act

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur for opinion) and Microsoft Corporation

5 Oct 2022 · Data Act

APPLiA urges EU to scrap shipping consortia exemption

3 Oct 2022
Topic — Evaluation of competition rules allowing cooperation between liner shipping operators.
Message — APPLiA argues that special rules for shipping lines should be removed as pandemic justifications have vanished. They want a new policy to address high costs and supply chain issues.12
Why — Ending the exemption could lower transport costs and increase competition among shipping lines.3
Impact — Large shipping lines would lose the legal right to coordinate services and capacity.4
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Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur)

21 Sept 2022 · Empowering consumers for the green transition

Response to Energy labelling requirements for local space heaters (review)

5 Aug 2022

APPLiA - Home Appliance Europe would like to provide its view on the energy labelling revision for local space eaters. In this paper, we would like to provide a simple and clear explanation of why electric local space heaters (ELSH) should not be compared to other products in one single labelling scheme. There are very important differences between ELSH and the other appliances that are now being considered in the working document circulated by the Commission in view of the EEL Consultation Forum scheduled on 24 June. For this reason, a separate labelling scheme for electric local space heaters is needed in order to provide clear and simple information to consumers.
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Response to Review of EU rules on fluorinated greenhouse gases

28 Jun 2022

APPLiA, the EU trade Association representing manufacturers of home appliances, including, ventilating and air conditioning and heat pump equipment, would like to share with the European policy-makers its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014 published on 5 April 2022. Please find our position paper attached.
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Response to Sustainable Products Initiative

15 Jun 2022

APPLiA is a Brussels-based trade association representing home appliance manufacturers in Europe. Our membership includes 24 Direct Members who are leading global companies in the sector, and 26 National Associations across Europe. The sector is an economic powerhouse, with an annual turnover of EUR 67 billion, over EUR 1.4 billion invested in R&D activities and nearly 1 million people involved. https://www.applia-europe.eu In light of the EU’s proposed Ecodesign for Sustainable Products Regulation (ESPR), APPLiA has put together a number of recommendations towards an effective enactment of the inherent measures. If correctly implemented, the ESPR has the potential to establish a win-win scenario for both the environment and European manufacturers. Designed as a kind of catch-all legislation, it is imperative for the proposal to be fully harmonised with all existing/upcoming EU legislation, with an eye to avoid double or cascading product requirements. This is the case for the proposed requirements related to “substances of concern”, among others, where chemicals legislation is already in place. Another example is provided by the proposed Digital Product Passport. Its introduction should ensure bringing an added value to users, avoiding unnecessary and burdensome replications of information in databases already existing, i.e. EPREL and SCIP. In this context, the successful experience of the Ecodesign Directive comes into play, providing a good precedent towards the implementation of legislation on a product group-specific basis by means of a clear methodology assessing relevant, individual aspects across the product’s lifecycle. Future regulations within the ESPR establishing ecodesign requirements should identify the most appropriate variables to improve environmental sustainability, while considering that product parameters can be interdependent and affect each other (e.g. repairability can affect reliability etc.). We recommend considering the possibility to assess these parameters not individually, but in combination to ensure optimum contribution to the EU Green Deal objectives. Building on this, a bankable ESPR must ensure the well-functioning of the EU Single Market, in keeping markets open and cross-border trade for products flowing. Here, harmonisation of both requirements and standards is key, given that sufficient lead-time is granted to the industry for process adaptation, between the publication of legislation and the ultimate application of requirements. Please find attached our full paper outlining the recommendations from the home appliance industry on the Commission's proposal.
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Response to Empowering the consumer for the green transition

29 May 2022

Pre-contractual information is key to ensure consumers make informed purchasing decisions. The Commission proposal on empowering consumers in the green transition aims to provide those consumers with an additional set of information and protect them from “greenwashing”. To that extent, we appreciate the connection with the other parts of the Sustainable Product Initiative and, in particular the Ecodesign for Sustainable Products Regulation (ESPR). We also look forward to seeing the linkages between this proposal and the one to come on substantiating green claims. With regards to the proposed addition to the list of unfair commercial practices, we would caution against making generic statements legal obligations that would be subject to heterogeneous interpretation and thus application by both authorities and market players. See attached APPLiA’s more specific views on the proposed amendments.
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Response to Cyber Resilience Act

25 May 2022

APPLiA represents Home Appliance Industry in Europe. We provide more details in the attached file. The brief summary can be outlined here: Whilst the NIS and NIS2 Directives properly address organisations with a set of consistent requirements, there is a risk that our products are regulated by different, disconnected pieces of legislation. For this reason, APPLiA has long been calling for a horizontal cybersecurity on products. With this regard, the sector welcomes the underlying objectives set by the Cyber Resilience Act but considers that a number of elements are missing in order to square the circle of security and legal certainty while ensuring the well functioning of the EU Single Market. First, the introduction of a central legal reference point for products’ regulation on cybersecurity through the Cyber Resilience Act. Ensured legal certainty would eventually cut the costs for businesses, lower prices for consumers, and make EU industries more competitive on the global market, this way promulgating European cybersecurity standards worldwide. Besides, it is key to make cybersecurity work on a systemic level. Self-assessment based on clear, verifiable technical details must remain an option for the majority of consumer goods to avoid bottlenecks in the system and EU market. In a rapidly changing security environment, a dependence on third-party certification would endanger prompt reactions. Finally, high cybersecurity standards are essential to creating a resilient EU cybersecurity system for all economic operators, offering EU citizens safe products. While legislation provides the essential requirements, technical specifications should be determined by EN Standards. This should also lie at the very heart of the Cyber Resilience Act.
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Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

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

4 May 2022

APPLiA welcomes the possibility to answer the call for evidence on external power supplies (EPS) and also the recent presentation of Commission and Fraunhofer on the EPS preparatory study during the 31 March Consultation Forum meeting. We would like to provide some initial recommendations and comments, in the hopes that they will be taken into consideration for the further development of the final regulation. Thank you.
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

7 Apr 2022

APPLiA represents household appliance industry in Europe. We appreciate that Commission regards standardisation as crucial for Europe. We appreciate that Commission proposes an amendment to Regulation 1025/2012 as we believe that this Regulation has the potential to improve the governance of effective standardisation in Europe. However, we while we are agnostic vis-à-vis the proposed amendment, we believe that further amendments are necessary to meet the objectives of the Strategy on Standardisation, to streamline the governance. In the Strategy of Standardisation, the Commission announces that it aims amongst others explicitly for • Inclusiveness • Speed • Transparency Therefore, we propose amendments that essentially aim to meet these very objectives • Speed up the process of the development of harmonised standards and the publishing thereof in the Official Journal of the EU by setting time limits for standardisation following a Standardisation Request (Art 10) and a formal Objection (Art 11) • Ensuring the inclusiveness of all relevant stakeholders by involving the relevant Committee together with all stakeholders (Art23) • Transparency about activity and progress of standardisation and about the decisions of the Commission by rules for notification and by use of Commission websites (Art 10.5 and10.9) The concrete proposals for amendments as well as their justification are attached.
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Response to Promoting sustainability in consumer after-sales

5 Apr 2022

APPLiA welcomes the Commission’s initiative on sustainable consumption of goods – promoting repair and reuse. It fits with the circular culture our industry is promoting and allows considering together aspects such as consumer rights, consumer and product safety, waste, sustainable behaviours and the creation of skilled jobs. In addition to our response to the public consultation, we would like to provide further remarks and ask for clarification on some questions in the following paper. The public consultation indeed raises several questions. The concept, the scope and the related boundaries e.g. the type of incentives mentioned in the questionnaire, to what defects this Right to Repair would apply, and who could claim such a Right against whom, remain obscure.
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Response to Ecodesign requirements for vacuum cleaners (review)

5 Apr 2022

APPLiA, representing the home appliance industry in Europe, welcomes the revision of the ecodesign and the possibility to provide feedback on the establishment of a new energy label for vacuum cleaners. The Association would like to provide feedback to consider in the impact assessment. Please see attached our Position Paper.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

APPLiA, representing home appliance manufacturers in Europe would like to share its first impressions on the proposed text with the attached document and look forward to the next legislative steps.
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Response to Procedures for the designation of Union testing facilities

30 Mar 2022

APPLiA Feedback to Consultation on Draft Regulation of Testing facilities: APPLiA recalls that in accordance with Article 21.1 of Regulation (EU) 2019/1020 the objective of the Union Testing Facilities is to “contribute to enhancing laboratory capacity”. Currently, testing capacity with 3rd party test houses is under pressure not only for market surveillance authorities but also for economic operators who seek certification of notified bodies. In case, part of this capacity is transferred to or reserved up front for market surveillance testing, the remaining capacity might get even less. As such, this designation of testing capacity by the Commission for market surveillance testing shall not go at the cost of capacity for the economic operators. Therefore APPLiA suggests an amendment to the proposed regulation to safeguard the respective condition of Art 21.1. We propose to make this requirement part of Art 3 (review of the designation), see below. Proposal for an Amendment Article 2 Review of the designation 1. The Commission, in consultation with the Network, shall review the designation of Union testing facilities on a regular basis in order to ascertain that Union testing facilities: (a) ensure a consistently high level of products testing; (b) provide technical and scientific advice of high quality. 2. The Commission shall in the course of the review of paragraph 1 and in accordance with Article 21.1 of Regulation (EU) 2019/1020 verify that the designation has led to an increase of the laboratory capacity and in case that increase has been compromised reconsider the designation.
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Response to Ecodesign requirements for water heaters and tanks (review)

30 Mar 2022

APPLiA supports the decarbonisation objectives of the Green Deal and therefore appreciates the need for an ambitious package of policy measures. Nevertheless, the proposals presented so far by the Commission will not solve the issues with the existing framework and hamper the deployment and installation of more efficient technologies. In particular, due to the lack of differentiation and granularity that the future schemes will introduce. A solution to address this important drawback is to offer sufficient information on the label to point consumers to the most efficient product that suits their needs. The attached paper details why the proposals presented so far by the Commission will not be able to deliver and possible alternative options.
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Response to Review: Restriction of the use of hazardous substances in electronics

9 Mar 2022

APPLiA, representing the home appliance industry, welcomes the launch of the call for evidence on the RoHS Directive revision. We see an opportunity that a further revision of the RoHS Directive can address some of the ongoing challenges related to the implementation of the legislation towards more coherence with other key EU legislations and further improvements in terms of exemption and restriction processes. Please find attached our comments on the proposed policy options listed in the call-for-evidence. Thank you.
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Response to Ecodesign requirements for local space heaters (review)

18 Feb 2022

We would like thank the Commission for sharing the call for evidence on local space heaters offering stakeholders the possibility to provide feedback on the options proposed. We support the Commission’s intention to update the existing label, in addition to removing the least efficient products from the market and promoting reparability; nevertheless, we are against the introduction of modularity requirements and the inclusion of electric local heaters in the rescaled energy label. More details on our position can be found in the attached paper. Thank you.
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Response to Energy labelling requirements for household tumble dryers [review]

18 Feb 2022

APPLiA welcomes the launch of the call for evidence on ecodesign and energy labelling for tumble dryers. The revision of the current ecodesign and energy labelling measures is not only needed to ensure a better distribution of appliances on the energy label, but also to contribute to reaching the ambitious targets set by the European Green Deal. APPLiA has contributed greatly to the revision study that was launched in 2017-2018 and remains now open to further contribute with both expertise and useful data to ensure fair and effective legislation. In the paper attached, APPLiA provides recommendations to the objectives and the policy options presented in the call for evidence.
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Response to Energy labelling requirements for air-to-air conditioners, air-to-air heat pumps and comfort fans [review]

17 Feb 2022

We would like thank the Commission for sharing the call for evidence on airco, comfort fans and local heaters and for providing us with the opportunity to comment on it. While we support the Commission’s intention to update the labels, some of the energy efficiency calculations and the option of removing the least efficient products from the market, we would like to see it done without harming manufacturers, including their possibility to differentiate products and to innovate. Our main recommendation related to air conditioners, comfort fans and local heaters were presented in the positions we shared with the Commission on 15 September 2021 and uploaded on the Commission’s Website. Some of the key messages are reported in the attached document. Thank you for considering our input.
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Response to Common Specifications on products without an intended medical purpose listed in Annex XVI (Medical Devices Regulation)

10 Feb 2022

APPLiA's comments on the safety of Home Use Intense Pulsed Light (IPL) Hair Removal Devices The Commission has opened a public consultation regarding the ‘Common Specifications’ for MDR Annex XVI Products (‘List of groups of products without an intended medical purpose referred to in article 1 (2)’). Annex VI of the proposed draft Implementing Regulation applies to “high intensity electromagnetic radiation (for example infrared, visible light and ultra-violet) emitting equipment intended for use on the human body”. APPLIA, representing household appliance industry in Europe (www.applia-europe.eu), would like to comment on the draft provisions below proposed by the Commission: • 5.2. Devices for home use shall not emit radiation outside the wavelength range between 180 nm and 1 200 nm. • 5.3. Devices for home use may only be used for the purpose of hair removal. Considering certain limit in the number of characters allowed here, we attached all details in word document here below. Thanks in advance for considering our proposals.
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Response to Review of ecodesign requirements for standby and off mode electric power consumption

3 Feb 2022

Please find attached APPLiA’s comments to draft regulation on ecodesign standby and off mode requirements. Thank you for taking our recommendations into consideration.
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Meeting with Salvatore De Meo (Member of the European Parliament)

26 Jan 2022 · CBAM

Response to Measures to reduce microplastic pollution

18 Jan 2022

APPLiA welcomes the European initiative on microplastics pollution as this global issue shall be discussed at the European level with a holistic approach. This paper reflects the Home Appliance contribution to the Call for evidence for an impact assessment on the microplastics pollution initiative, launched by the European Commission on November 30th, 2021. In particular, APPLiA would like to raise a few important considerations on the proposal to introduce microplastics filters for washing machines, washer-dryers and tumble dryers. The home appliance sector is fully committed to contributing to solving the issue of microplastics release into the environment. Nevertheless, we believe that the impact assessment shall evaluate important specifications to ensure that the objectives of the initiative are fulfilled. Furthermore, the impact assessment shall carry out an environmental evaluation outlining the balance between health risk, environmental hazard and climate impacts. We have divided the paper into four sections. Part I will provide a general overview of the issue; while Parts II and III will focus on product-specific considerations; finally, Part IV will summarize our main conclusions and recommendations. The paper also contains an Annex that reports a qualitative analysis of the mass flow done by APPLiA. Washer-dryers currently on the market work based on a technology that can be either the one used for the washing machines or for the tumble dryers.
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Meeting with Thierry Breton (Commissioner) and

1 Dec 2021 · Discussion on ecodesign, semiconductors, standardisation and internal market

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Renewable Energy Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Energy Efficiency Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.
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APPLiA warns CBAM risks European home appliance manufacturing jobs

17 Nov 2021
Topic — An EU regulation placing a carbon price on imported goods to prevent leakage.
Message — APPLiA requests the inclusion of finished goods to avoid penalizing European manufacturers. They propose a binding requirement to legislate on complex goods before removing free allowances.12
Why — This would prevent domestic factories from being undercut by cheaper, high-emission foreign appliances.3
Impact — Non-EU manufacturers would lose their competitive price advantage from using unregulated raw materials.4
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Response to Revision of the Energy Tax Directive

16 Nov 2021

This paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the Fit for 55 package proposals. It provides an analysis and the first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission. Amendments would be cast as part of the legislative process with the European Parliament and the Council. As a general remark to the full package, APPLiA welcomes the initiative as a key enabler to reach the objectives set by the European Green Deal. At the same time, we recommend caution as the content of some initiatives might lead to challenges and potential dangers for end-users and businesses competition. We believe that climate policies should be inclusive for low-income families to avoid increasing energy poverty and enough freedom should be granted to businesses to contribute to achieving the targets. APPLiA set of comments to the Energy Taxation Directive begins on the next page.
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Response to Proposal for a Regulation on establishing a Climate Action Social Facility

4 Nov 2021

The paper attached is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on two of the Fit for 55 package proposals: The review of the Emission Trading Scheme and the Social Climate Fund. This paper is a subset of a larger one, in which APPLiA will comment on other dossiers of the package, such as the Renewable Energy Directive, the Energy Efficiency Directive or the Energy Taxation Directive, among others. It provides an analysis and a first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission. Amendments would be cast as part of the legislative process with the European Parliament and the Council. As a general remark to the full package, APPLiA welcomes the initiative as a key enabler to reach the objectives set by the European Green Deal. At the same time, we recommend caution as the content of some initiatives might lead to challenges and potential dangers for end-users and businesses competition. We believe that climate policies should be inclusive for low-income families to avoid increasing energy poverty and enough freedom should be granted to businesses to contribute to achieve the targets.
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Response to Updating the EU Emissions Trading System

4 Nov 2021

The paper attached is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on two of the Fit for 55 package proposals: The review of the Emission Trading Scheme and the Social Climate Fund. This paper is a subset of a larger one, in which APPLiA will comment on other dossiers of the package, such as the Renewable Energy Directive, the Energy Efficiency Directive or the Energy Taxation Directive, among others. It provides an analysis and a first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission. Amendments would be cast as part of the legislative process with the European Parliament and the Council. As a general remark to the full package, APPLiA welcomes the initiative as a key enabler to reach the objectives set by the European Green Deal. At the same time, we recommend caution as the content of some initiatives might lead to challenges and potential dangers for end-users and businesses competition. We believe that climate policies should be inclusive for low-income families to avoid increasing energy poverty and enough freedom should be granted to businesses to contribute to achieve the targets.
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Response to Review of the general product safety directive

4 Oct 2021

This document is focusing only on key aspects. APPLiA is happy to contribute to the legislative process with further details at a later stage. 1 - Improved coherence with New Legislative Framework The GPSR is thought as a “safety net” to Union harmonised legislation, therefore coherence with the New Legislative Framework (NLF) is of utmost importance. While we appreciate that the draft apparently aims to create a direct relation to the NLF, three main aspects need to be clarified: i) Standardisation Firstly, it is unclear whether “standards” mentioned in Art 6 are EU harmonised standards according to Regulation 1025/2012. Further clarification is needed. Secondly, Art 6.2 stipulates that the Commission shall adopt implementing acts determining specific safety requirements. This risks to undermine the NLF principle that EU standardisation is best suited to formulate technical details. Deviating from this principle is only pertinent when used exceptionally and under strict and clear criteria. The article needs to be formulated accordingly. Finally, we are afraid that Art 6.1b - providing “presumption of safety” through national provisions -fosters national fragmentation rather than a uniform Single Market. We propose to delete 6.1b. ii) Conformity Assessment In addition to the further clarification on the role of harmonised standards, reference to the conformity assessment modules according to Decision 768/2008 would improve the coherence. iii) Market Surveillance The GPSR should refrain from formulating provisions on market surveillance that are overlapping with Regulation 2019/1020. For instance, most of Article 14 appears unnecessary as it is only reformulating provisions of Art 4 and 7 of Regulation 2019/1020. 2 - The concept of “safety” to be adopted to product regulation The concept of recital 12 to expand the notion of “health” also mental and social wellbeing is reasonable in a public health policy context but leads to confusion when it comes to product safety. The relation between mental health and the product as such is undefined and not precise enough for any conformity assessment. We propose to delete that recital. 3 - More clarity of provisions on cybersecurity, artificial intelligence (AI) and data protection While for the above issues horizontal legislation is underway and vertical arrangements exist the GPSR again introduces these concepts. It is unclear how “taking onto account” (Art 7) of cybersecurity and artificial intelligence can be addressed in conformity assessment. We believe that IoT/AI products should remain safe even if their cybersecurity is compromised or AI has led to a SW evolvement. Within the GPSR it is therefore sufficient to properly relate to the respective horizontal legislation and to mention that breached cybersecurity and AI have to be reflected in the manufacturer’s risk assessment. We are happy to provide respective amendments. 4 – Over-reporting on not-specified “accidents” The provision of “any accident” to be notified to authorities within two working days (Art. 19, see also, Art 8.2) is very critical. It would be very relevant that only severe accidents demonstrably caused by a product are notified. Otherwise there will be an information overload and an unproportioned burden to manufacturers especially in the short time frame of 48h. Further, most of the harmonised regulations (e.g. medical devices or low voltage) have already reporting provisions. As a consequence we propose rephrase the article accordingly. 5 - A longer transitional time indispensable The Transitional period (Art 47) is too short. It is crucial for legal certainty in the member states that these have time to adopt and bring to coherence their existing national provisions based on the current safety regulations. As the transposition time is normally 18 months, we believe this is the minimum period here too. Given the complexity we propose 24 months.
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Response to Revision of the Machinery Directive

30 Jul 2021

APPLiA would like to use the opportunity given and comment in couple of points on the key elements in the draft Machinery Regulation. This set of comments does not exclude the possibility to deliver additional input in the future as well as improving/modifying certain statements provided here. APPLiA is available for further, especially verbal and bilateral explanation of its comments in more details. Detailed comments in the attached word file "Machinery Regulation - comments from APPLiA_210730.docx"
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APPLiA seeks narrower high-risk AI definition for appliances

27 Jul 2021
Topic — The consultation addresses a new legal framework for developing trustworthy artificial intelligence.
Message — The association requests that products are only labeled high-risk if their basic safety depends solely on AI. They also demand transparent criteria for when the Commission can bypass standard industry processes.12
Why — Narrowing high-risk classifications would reduce regulatory burdens and compliance costs for manufacturers.3
Impact — Public safety oversight could be weakened for AI tools that perform secondary functions.4
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Response to Standardisation Strategy

26 Jul 2021

APPLiA’s Summary Input to the Roadmap for the Strategy for Standardisation APPLiA agrees with the Commission that a well-functioning EU standardisation system is of highest importance for the European Union and especially for the Single Market. Here is the a brief summary of our input. More details in the attached file “APPLiA_Feedback-Roadmap-Strategy-for-Standardisation-final_for delivery_210726” The Strategy for Standardisation should pave the way to: • Secure consumer protection • Secure environmental protection • Ensure compliance of products and enforcement by authorities • Ensure that standards develop in the right direction by an early and continuous involvement of all stakeholders, including and very importantly the EU Commission. If there are controversial, unclear items, bring the external, recognised, impartial experts in the relevant area The EU single market is the motor of the EU economy and our global success. Requirements and technical details and methods need to be specified somewhere. If that is not the case the main objectives are at risk. A smart and flexible combination of EU legislation and standards as the tool to fulfil all the EU objectives is in APPLiA’s view the favourable solution.
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Response to Ecodesign and energy labelling working plan 2020-2024

1 Jun 2021

Please refer to the attached Position Paper.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

28 May 2021

APPLiA, representing EU manufacturers of home-appliances, including large domestic appliances, small domestic appliances and heating, ventilation, and air conditioning (HVAC) equipment, would like to provide the European Commission with the views of the sector and further recommendations regarding the objectives and policy options as proposed in the IIA called “Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals”. APPLiA would fully support any proposed objective and policy option from the Commission that would commit to harmonise, simplify, and strengthen EU rules on chemicals, as well as how to create and enhance the synergy between existing EU agencies and scientific bodies to effectively work together towards a process where substances are only reviewed by one agency. This would consequently build a coherent framework to risk-manage chemicals in Europe and further clarify some existing grey zones between different pieces of chemical-legislations. Thanks for further reading our contribution, our key messages, as found attached in our position paper.
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Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association des Constructeurs Européens d'Automobiles and

29 Apr 2021 · Steel safeguard review

Response to Revision of the NIS Directive

19 Mar 2021

APPLiA appreciates the opportunity to provide this feedback. While a condensed version of our comments is below, please see the attached document for our full comments. APPLiA understands the need for comprehensive rules for a high level of cybersecurity within the European Union. APPLiA’s first concern lies in the fact that NIS2 is a Directive rather than a regulation. A regulation would provide the legal certainty needed by manufacturers, whereas a directive fragments the legal landscape and threatens the functioning of the single market. APPLiA’s members urge the relevant bodies to reconsider turning NIS2 into a regulation. The proposed Directive greatly enlarges the scope. We are of the belief that important entities, including all kinds of manufacturing, might be too large as a scope, and therefore recommend concentrating on critical areas through addressing the essential entities and their respective supply chains. We would also like to highlight the concern that Article 2 bears the risk of market fragmentation across the European Union, whereby Member States are allowed to decide which entities they put in the scope of the Directive. To appropriately address cybersecurity threats, one should consider the importance of software and its involvement in what becomes the end product. While home appliance manufacturers are included in the scope, software developers have been omitted. Software developers are crucial suppliers and deliver enterprise solutions. As such, we would ask that the scope of affected parties be reconsidered to include software developers. In all cases however, any extension of scope should be risk-based and proportionate. Under the proposed Directive, the obligations for essential and important entities would materially be the same. The conditions for and possible impacts on the operations of essential and important entities are very different. We believe that it is important to highlight the difference between important and essential entities. For example, important entities should have different treatment to essential entities; we question the logic of having the same reporting obligations for important entities under the current definition (e.g. home appliance manufacturers), as for essential entities like nuclear power stations. As per Article 18, while the provision of a 24 hour response time for risks/threats to essential entities is understandable, extending the same obligation to manufacturers provides no benefit to society, and puts significant burden on industry, as well as simply not being feasible for many small- and medium-sized enterprises who currently fall under the scope of the Directive. Article 21 allows Member States to impose rules that require certification of products by the Cybersecurity Act. This could lead to conflicting requirements in different Members States, not only for essential entities. This would fragment the common European market. We urge the Commission to consider this requirement only for critical components, processes and services of essential entities, and also consider alternative approaches to demonstrate compliance with Article 18. When it comes to important entities, in light of the above issues, we believe the cybersecurity obligations for manufacturers should not be addressed in this Directive but rather in a horizontal NLF product regulation which would put equal obligations on all participants in a given sub-market. We also wish to highlight our concerns that cybersecurity obligations are increasingly being included in (European) sectoral regulations. It must be prevented that an accumulation of obligations and/or conflicting requirements arise for companies on the basis of the NIS2 and other EU regulations; regulatory overlap should be avoided at all costs. For points on the need for clarity on when to report, underestimation of costs, governance and financial support, please see our attached comments.
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

APPLiA, the European association representing home appliances manufacturers, welcomes this proposal for a Regulation on batteries for a more coherent battery legislative framework while preserving the single market competition and innovation. Please find attached the industry's reaction with complementary comments.
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Response to EU strategy for sustainable textiles

1 Feb 2021

APPLiA welcomes the initiative on a strategy towards a sustainable textile launched by the European Commission. In particular, we would like to provide detailed comments on microplastics released from textile during washing as it is mentioned in the initiative. Please find enclosed APPLiA's view and recommendation on this issue.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

APPLiA, representing EU manufacturers of home-appliances, including large domestic appliances, small domestic appliances and heating, ventilation, and air conditioning (HVAC) equipment, would like to provide the European Commission with the views of the sector and further recommendations regarding its Inception Impact Assessment (IIA) document Ref. Ares (2020)7731375 as published on the 18th December 2020. First of all, APPLiA members companies assure that the health and safety of their customers is the paramount concern. All of the materials found in household products have been carefully designed and evaluated in order to guarantee their high performance, reliability, and safety. Materials may differ from one home appliance to another, nevertheless, APPLiA would like to reassure the authorities on that all parts intended to be in contact with food, fully comply with the FCM Framework Regulation (EC) No 1935/2004, and its related EU-applicable requirements. Our member-companies have a long-standing expertise regarding risk-assessing and risk-managing (final) complex products covered by the Framework Regulation. As such, the focus of home appliance manufacturers is to ensure the safety and compliance of final articles, i.e. appliances for food preparation, or food processing, intended for consumers’ foreseeable uses. Consequently, we would like to underline that the current Regulation (EC) No 1935/2004 is fit-for-purpose. The principles defined in this latter Regulation, e.g. FCM and articles safety, traceability, labelling, declarations, etc., should remain the primary tool to (i) ensure a homogeneous approach to keep such materials and articles safe to consumers, despite of the lack of specific EU measures on current non-harmonised FCMs, as well as (ii) to facilitate the free movement of goods throughout the EU. As such, and regarding the two fundamental options that will be further evaluated during the IA process by the competent authorities, APPLiA would like to recommend for Option 1 to be identified as the most appropriate way forward with regards to the evaluation and review of the FCM Framework Regulation. Please kindly read our attached position paper to understand our further comments, concerns, views and priorities, regarding the different Commission's objectives and policy options.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

First reflection on the Evaluation Roadmap “Evaluation of certain aspects of the New Legislative Framework (Decision No 768/2008/EC and Regulation (EC) No 765/2008)” General APPLiA comments: 1. APPLiA – Home Appliance Europe - represents household appliance industry in Europe – more info on www.applia-europe.eu 2. Home Appliance Industry believes in the New Legislative Framework principles (i.e. essential requirements in the legislation and technical prescription how to meet those requirements in the European standards) 3. APPLiA believes in the European Standardisation System (i.e. Standardisation Request with reasonable time frame and requirements, standard worked out in an open, transparent, and democratic process without unjustified delay and then listed in the OJEU without unjustified delay, manufacturers enjoying presumption of conformity). 4. However, there is no mention of the role of and the link to standardisation in this roadmap– yet the lack of references to the harminised standrads in the OJEU is in our eyes the key (and possibly the only) issue with the NLF 5. APPLiA would be happy to be active stakeholder in the upcoming consultations Specific APPLiA comments to the Evaluation of certain aspects of the New Legislative Framework (Decision No 768/2008/EC and Regulation (EC) No 765/2008) Roadmap: Quote “They [the product] may also incorporate artificial intelligence that will lead to further changes of the product” Comment When it comes to conformity assessment, the consequences of artificial intelligence should not be overestimated; AI does not necessarily mean a change of the “product”. If a refiguration device “learns” to distinguish Pizza from butter it still stays a refrigeration device a fridge. Quote “in the fight against COVID-19 […] the fast entrance of new products into the market appeared challenging, in particular as regards getting acquainted with the legislation and standards and completing the conformity assessment procedures.” Comment COVID-19 crisis is an unprecedented and hopefully unique situation, even though it did not unveil problems with NLF. COVID-19 did not unveil problems with the NLF as such. The fact that e.g. entry into force of Medical Devices has been postponed is not an issue specific to NLF.
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

APPLiA welcomes the initiative launched by the European Commission to amend legislation in the Ecodesign and Energy Labelling field to correct some technical issues. However, there are several important uncertainties and mistakes remaining that need to be resolved. The enclosed position paper provides the necessary recommendation to improve the legal text and ensure consistency among the ecodesign regulations. We remain at disposal to further discuss the issues identified in the paper.
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

APPLiA welcomes the initiative launched by the European Commission to amend legislation in the Ecodesign and Energy Labelling field to correct some technical issues. However, there are several important uncertainties and mistakes remaining that need to be resolved. The enclosed position paper provides the necessary recommendation to improve the legal text and ensure consistency among the ecodesign regulations. We remain at disposal to further discuss the issues identified in the paper.
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APPLiA urges voluntary approach rather than mandatory AI regulation

10 Sept 2020
Topic — EU consultation on creating a legal framework for trustworthy artificial intelligence.
Message — APPLiA opposes regulating AI because the concept is not well defined. They recommend a voluntary approach or limiting laws to specific categories.12
Why — A voluntary framework allows manufacturers to avoid strict compliance costs.3
Impact — Citizens lose legal protections against risks like remote biometric identification.4
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Response to Review of EU rules on fluorinated greenhouse gases

7 Sept 2020

Please consider the attachment for APPLiA's feedback on the Inception Impact Assessment on F-Gases.
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Response to Review of the general product safety directive

1 Sept 2020

APPLiA (Home Appliance Europe) believes that GPSD has been working reasonably well over those almost 20 years and does not require major revision. However, considering time and efforts already invested in possible review, Option 0 ’Status quo’ is probably not realistic anymore. In order to be constrictive, pragmatic and efficient, we believe that we all should start with Option 1: Improved implementation and enforcement of the existing legal framework. Especially development of guidance on the safety of new technologies and exploring the use of European standards to address new risks would be helpful and could pave a way to a possible revision if that occurs eventually inevitable.
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Response to Empowering the consumer for the green transition

31 Aug 2020

In order for the green transition to fully take place, consumers will have to play a much larger role in shifting to more sustainable consumption patterns, such as opting for repair over product replacement. With reference to the 2019 Sale of Goods Directive, APPLiA has long been a supporter of repair being first in the hierarchy of remedies to which consumers are entitled. Consumers should be entitled to have their products “repaired right”, having access to repair services by professional repairers, with available spare parts. Home appliance engineers’ first thought is people’s safety, ensuring users’ protection and maintain trust. Any work towards establishing a new ‘right to repair’ to empower consumers must respect the consumer’s right to safety. Consumers are also entitled to product conformity , both within the 2 year legal guarantee period, when most repairs are fulfilled by the brand manufacturer, and afterwards when repairs may be subject to extended warranties or supplementary costs, in accordance with the choice of the consumer. APPLiA understands and supports that both spare parts and repair information are provided to professional repair operators for a period of time after the legal guarantee period. Repairing products and using spare parts requires technical skills that all consumers cannot be assumed to have. If an appliance is not properly repaired, safety within the home could be compromised. The repairer could also be an independent body, as long as they demonstrate compliance with the applicable regulations for repairers of electrical equipment, and are covered by relevant insurance, including liabilities resulting from the service. The IIA proposes “a common set of consumer information requirements” on product lifespan, reparability and environmental characteristics. For any new labelling requirements on these issues, APPLiA strongly advocates for a coherent methodology based on standards, that assesses the environmental impact of a product in a holistic way. In order to achieve this goal, many diverse business strategies can be pursued, and manufacturers should have the freedom to adopt the path that best plays to their strengths, enabled by a healthy business environment that respects competition law and encourages innovation. This means any measurement method should be neutral towards companies’ strategies, which can range, for example, from emphasizing light-weight or recycled content, to emphasizing durability or recyclability. APPLiA supports the further development of product-specific standardisation requests to CEN and CENELEC, to produce reliable test methods and material efficiency. Any proposed methodology should be neutral towards companies’ strategies, but constructed and weighted in a manner that encourages differentiation and leads to varied “grades/scores”; a methodology that leads to the same rating for all products would be counter-productive and confusing for the consumer. This initiative should be not just enforceable, but also enforced. While a measurable methodology is crucial, so too is the need for the correct body to ensure all actors on the market obey the new requirements. On this point, APPLiA calls for a more active role by market surveillance authorities in enforcing both a level playing field and consumer protection. In order to reduce waste and have consumers play a more active role in the green and digital transitions, APPLiA advocates for an overdue update of legislation that would allow producers to provide relevant product information digitally rather than on paper. In order to strengthen the fragmenting single market, existing legislation should be fully harmonised at EU level, as well as being better enforced through market surveillance. The Commission should wait to see the effects of the harmonised market surveillance regulation that has entered into force (in 2021) before considering further regulation. Please find our full comments attached.
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Response to A New Consumer Agenda

11 Aug 2020

In order for consumers to play an active role in the green transition and with reference to the 2019 Sale of Goods Directive, APPLiA has long been a supporter of repair being first in the hierarchy of remedies to which consumers are entitled. Consumers should be entitled to have their products “repaired right”, having access to repair services by professional repairers, with available spare parts. Any work towards establishing a new ‘right to repair’ to empower consumers must respect the consumer’s rights to product conformity and product safety both within the 2 year legal guarantee period and afterwards when repairs may be subject to extended warranties or supplementary costs, in accordance with the choice of the consumer. APPLiA understands and supports that both spare parts and repair information are provided to professional repair operators for a period of time after the legal guarantee period. In this respect, APPLiA values the approach of the Commission in setting minimum ecodesign requirements as it creates a level-playing field and obliges all market actors to meet a set of minimum requirements. Repairing products and using spare parts requires technical skills that all consumers cannot be assumed to have. If an appliance is not properly repaired, safety within the home could be compromised. The repairer does not necessarily have to be the one directly employed or contracted by the manufacturer. It could also be an independent body as long as the repairer requesting repair or maintenance information is able to demonstrate s/he complies with the applicable regulations for repairers of electrical equipment and that is covered by relevant insurance, covering liabilities resulting from the service. Through professional repair networks, manufacturers can also ensure the appropriate framework in case of product recalls. DIY repair for simple maintenance of the appliance is already widespread today, as recommended by the manufacturer. In addition, DIY kits are offered by manufacturers for repair tasks that can be carried out safely with minimum cost and little technical skill. For any new labelling requirements on "product lifespan, reparability and environmental characteristics" (IIA), APPLiA strongly advocates for a coherent methodology based on standards, that respects diverse business strategies. This means any measurement method should be neutral towards companies’ strategies, which can range, for example, from emphasizing light weight or recycled content, to emphasizing durability or recyclability. APPLiA supports the further development of product-specific standardisation requests to CEN and CENELEC, to produce reliable test methods and material efficiency. Any proposed methodology should be constructed and weighted in a manner that allows for varied strategies and leads to varied “grades/scores”; a methodology that leads to the same rating for all products would be counter-productive and confusing for the consumer. This initiative should be not just enforceable, but also enforced. While a measurable methodology is crucial, so too is the need for the correct body to ensure all actors on the market obey the new requirements. APPLiA calls for a more active role by market surveillance authorities in enforcing both a level playing field and consumer protection. In order to reduce waste and have consumers play a more active role in the green and digital transitions, APPLiA advocates for an update of legislation that would allow producers to provide relevant product information digitally rather than on paper. In order to strengthen the fragmenting single market, APPLiA insists that market surveillance of existing legislation should be better enforced and fully harmonised at an EU level.The Commission should wait to see the effects of the harmonised market surveillance regulation that has entered into force (2021) before considering further regulation. Please find our full comments attached.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

Please find APPLiA's feedback and further arguments on the Inception Impact Assessment in the document uploaded enclosed.
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Response to Strategy for smart sector integration

12 May 2020

APPLiA supports empowering consumers as part of the energy transition to meet the goals of decarbonization and the European Green Deal. Smart sector integration and the expansion of uptake of energy-smart homes and appliances offers are unique opportunity for consumers to play a more active role in this transition. Through fully integrating the smart home with the energy grid, consumers could choose to be more flexible in their energy consumption patterns, taking pressure off the grid during peak hours and in turn enabling the use of renewable energy over fossil fuels. However, to do this, consumers must be incentivized. A review of the Energy Taxation Directive offers the perfect opportunity to update how consumers are charged for their energy use. An energy bill that reduces flat fees and increases the direct connection between energy use and a consumer’s energy expenses would incentivise users to take a more active and conscious role in their use of electricity. Consumers should become both producers and consumers of electricity; in order to do this, consumers must be empowered to offer their flexibility to aggregators who can sell it to the energy market. Decentralization of the energy system and the creation of a system of micro-plants serving micro-grids would further enable consumer proactivity in the transition.
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APPLiA urges including finished goods in EU carbon border tax

30 Mar 2020
Topic — The EU is designing a mechanism to price carbon on imported industrial products.
Message — APPLiA requests that carbon taxes on raw materials also apply to finished goods. This prevents European products from becoming more expensive than those made abroad. They argue this is necessary to stop manufacturing plants from moving outside Europe.12
Why — This would prevent European appliances from losing their competitive edge against foreign-made products.3
Impact — Non-EU manufacturers would lose the financial benefit of exporting products without carbon charges.4
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Response to Revision of the Energy Tax Directive

25 Mar 2020

a. Demand response One important area that the revision should take into consideration is how demand response instruments could contribute to reducing emissions of net greenhouse gases. Demand response solutions would be able to reduce the pressure on the network by better managing peak demands. To cope with temporary high energy requests, energy suppliers often make use of coal or fossil fuels. Consequently, addressing these irregular fluctuations would have a positive effect on final emissions. Involving all actors, in particular energy users, would be necessary to develop an effective demand response system. Consumers or businesses, including manufacturers, would have the possibility to choose hourly or shorter-term market pricing, reflecting variability on the market and the network through automation or personal choices to save on energy expenses. As far as consumers are concerned, smart appliances and home automation are the most obvious instruments to gradually involve citizens in demand response activities at large scale. The revision should take into consideration these aspects and analyse how the potential of demand response could be exploited through a taxation system that would reward consumers for participating to demand response activities. b. Electricity or fossil fuels gases The Inception Impact Assessment recognises that the vast majority of Member States tax most energy products and, in some cases electricity, considerably above the minimum level identified by the ETD. Electric energy has the potential to promote renewable energy sources, contrary to fossil fuel energy. Households could contribute significantly to exploit electric energy by switching to the use of electricity in space or water heating. Electric water heaters are solutions that enable storing energy that is available when the grid is under limited pressure (in the night) releasing it during the day, when the consumers need it, but also the demand of the network is higher. When consumers have to choose among different heating or water heating solutions, the choice is often based on costs. The price of the appliance and the cost of installation are the main initial factors. Nevertheless, running costs represent more and more a very important element that influences the final decision. The review could be an opportunity to investigate ways to promote the use of electric solutions for high energy demand applications in households, opposed to solutions using fossil fuels. c. Manufacturing in Europe According to the New Industrial Strategy for Europe, Europe has always been the home of industry. If we want Europe to continue being the home of industry, we should pay particular attention to the conditions under which industry will thrive in Europe. The energy cost is one of the primary concerns for taking a decision on where to localise future investments. Reduced taxation regimes for settlements hosting manufacturing facilities would help taking a decision toward further European industrialisation. This revision should be an opportunity to investigate solutions that would make manufacturing in Europe more competitive.
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Response to Evaluation of the Electromagnetic Compatibility Directive

20 Feb 2020

APPLiA’s comments on EMC Directive Roadmap APPLiA is a Brussels-based trade association that provides a single, consensual voice for the home appliance industry in Europe, promoting industry’s mission to advance Europeans' lifestyles. Our members manufacture a wide variety of home appliances. Large appliances such as refrigerators, freezers, ovens, dishwashers, washing machines and dryers; Small appliances such as vacuum cleaners, irons, toasters and toothbrushes; Heating, ventilation and air conditioning appliances such as air conditioners, heat pumps and local space heaters. The home appliance industry is certainly an important European economic player that impacts our daily lives. Home appliance industry believes that: • This directive is fit for purpose and there is no need for modification or revision • This directive should remain technology neutral • There should not be changes in the scope of the Directive, nor should there be any changes in the essential requirements • Any remaining issues concerned with a lack of clarity can be addressed in guidance documents without revising the EMC Directive
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Meeting with Thor-Sten Vertmann (Cabinet of Commissioner Kadri Simson)

17 Feb 2020 · Introduction of the association and the home appliance industry. Implementation of the Energy Labelling Delegated Acts.

APPLiA urges market-based incentives for EU circular economy plan

20 Jan 2020
Topic — The European Commission is seeking feedback on policies to promote a more circular economy.
Message — APPLiA calls for a focus on market-based incentives rather than strict legal mandates. They argue that new product rules must be measurable and based on real-life conditions. Additionally, they highlight a conflict between strict chemical laws and circularity goals.12
Why — This strategy would lower compliance costs and shield manufacturers from unfair global competition.3
Impact — Waste handlers would lose their current regulatory advantages as they face stricter oversight.4
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

23 Oct 2019 · Clean energy transition and energy efficiency

Response to Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems

4 Mar 2019

Full details in the attached paper: • RRS are a specific class of equipment based on SDR (Software Defined Radio) and CR (Cognitive Radio) technologies that are able to change the radio parameters of a device via firmware/software update. The SW installed in the consumer devices under the RED (from connected household appliances to smart cameras, TVs etc..) may affect differently the essential requirements of the RED., The functional SW of an IOT product can be upgraded or fixed in the way in which the manufacturer who is the final responsible for the product placed in the market, will plan to manage this activity. The serviced products such as those updated or upgraded to better versions with respect to the original status will normally be tracked by the manufacturer upon dedicated practices via specific codes that allow the manufacturer to reach every product in the field. When a product will run through a Software upgrade the manufacturer will upfront verify through dedicated analysis that the product is capable to accept and run the over the air updates. Therefore, we believe it is the manufacturer that will have the full responsibility to cover the compliance to the essential requirements via a clear assessment to each of the conditions covered by these essential requirements. This assessment should be part of the technical file of every product and be maintained by the manufacturer for market surveillance purposes.
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Response to Smartwatches and connected toys

4 Mar 2019

DUE TO LIMITED SPACE FULL SET OF COMMENTS IN THE ATTACHED PAPER: The problem the initiative aims to tackle here appears to be the aim to define IoT device as “internet-connected radio equipment, i.e. radio equipment intended to be (i) connected (directly or indirectly) to or (ii) controlled through the internet. “ Whilst we agree with the concept given by this definition, we are unclear if this clarification will be part of the future delegated acts that will cover the article 3.3 of EU 53/2014 area. We call the COM to ensure that the respective scopes of the future delegated act and that of the RED are perfectly aligned. Basis for EU intervention (legal basis and subsidiarity check) • We understand that GDPR and ePD / future ePR do not allow withdrawal of products from market when they are found to be non-compliant. And the use of to RAPEX would enable product recalls. In principle we agree with this conclusion, but we think recalls will have an enormous impact for all economic operators. Security by design will be the only way it can be reached to have products complying to GDPR and ePD. We suggest that such level of intervention from authorities has to be set depending on the grade of the risk detected. The registration of a certain product in the RAPEX system can be part of a more wide scenario that the affected product can fall under, such as imposing rules for companies to continually monitor for, identify and rectify security vulnerabilities within products and services they sell, produce, have produced and services they operate as part of the product security lifecycle, report vulnerabilities directly to the affected stakeholders in the first instance and if that is not possible vulnerabilities can be reported to national authorities. We think this approach can secure a proactive approach on dealing with the security of the final users and allow industry to take preventive actions before the incidents or vulnerabilities have been spread already or the process is late in time to fix potential issues. • The certainty of the preservation of the compliance of radio equipment throughout its life-cycle is a key feature to ensure that new technologies, whose safety and security might be impacted by the upload of new software, can be used by consumers with trust. • APPLiA is concerned about extending now the compliance of a product which is not any more the moment of placing on the market but the whole lifecycle of the equipment. The current compliance schemes do not cover the full life cycle of a product and the technical evaluations including those listed under Article 3 (1.a) and Article 3 (1.b). The extension of the compliance and liability for an IoT product needs to be supported with EU harmonized standards. As of now the HAS supporting essential requirements of Article 3 do not include in their scope serviced products in the meaning of updated or upgraded products. Likely impacts on simplification and/or administrative burden • The COM writes in an official document that standardisation is an "industry-driven process"... This statement is not realistic: many other stakeholders are involved in standardization. And the publication of references to harmonised standards in the OJEU is not "an industry-driven process". Industry invests resources in the standardization area to better address the issues for fair competition and free circulation of goods, and this has historically been welcomed by all ESOs and EU COM. It is not in the industry interest to develop standards that are not reflecting the needs of the customers, therefore we do not agree with this conclusion.
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Response to Revision of the Machinery Directive

11 Feb 2019

APPLiA's opinion on the presented Options in the attached file.
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Response to Regulatory measure on the review of energy labelling for household washing machines and washer-driers

23 Nov 2018

APPLiA, the Association representing the home appliance in Europe, would like to welcome the Commission proposal for the review of the ecodesign and energy labelling requirements for Washing Machines and Washer-Dryers, and would like to thank the Commission for the possibility to provide comments through this platform. APPLiA supports the vision of the Commission to improve energy efficiency and more sustainable ecodesign requirements for Washing Machines and Washer-Dryers. However, we would like to provide comments regarding a few key points included in the drafts here available. Please find our comments on the proposal in the file attached.
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Response to Ecodesign requirements for (other) electric motors

21 Nov 2018

APPLiA wishes to provide some input to the draft ecodesign measure for motors. We appreciate the work completed by the Commission. However, we are particularly concerned about the possible double/cascade regulation of motors integrated into products that are already covered by ecodesign regulations. We would like to highlight that increasing the efficiency of the motor has almost no impact on the overall efficiency of the appliance. Notwithstanding, it will oblige manufacturers to invest in components (in this case a different type of motor), instead of investing in other components that for the same or lower price would deliver real saving. We would also like to highlight that Article 15.2.c of the Framework Ecodesign Directive states that the legislator should address products presenting significant potential for improvement in terms of environmental impact “without entailing excessive costs, taking into account…(i) the absence of other relevant Community legislation or failure of market forces to address the issue properly”. We are convinced that motors in equipment already covered by ecodesign measures do not fall in this category. From the material efficiency point of view, increasing the efficiency of the motor could even mean using heavier or more materials or materials with a higher environmental impact, including rare earth or copper – against the principle of resource efficiency. APPLiA proposes to exempt bespoke motors form the draft regulation. As bespoke motors we mean motors designed and manufactured to meet a detailed specification supplied by, or developed in conjunction with, a particular end-product manufacturer – including motors designed and manufactured by end-product manufacturers themselves for their own products. A bespoke part is not placed on the market for being available to all, in shops or online. Components available to all, sold in shops or online, should not be exempted. The possibility to regulate motors in products covered by ecodesign should be studies during the ecodesign product preparatory studies. In order to avoid loopholes we propose the following: 1.bespoke motor should be indelibly and unequivocally marked for their purpose. 2.manufacturers of final products shall describe, in their technical documentation file, that they have used a bespoke motor together with information on the motor’s manufacturer and their product identifier. 3.manufacturers of bespoke motors that are designed for a final product shall state, in their technical documentation file, for which final product (manufacturer and model identifier) their bespoke motor has been designed for. In addition, also in the frame of the resource efficiency, durability and reparability discussion there should not be limitation in selling motors sold as spare parts, in line with the repair as produced principle. Finally there is a clarification required. It should be clarified, that motors have to be tested on a test bench (and not in the machine in which they are integrated) at an ambient temperature of 25°C. We take for granted that motors have to be dismounted from the appliance in which they are built-in to perform the energy efficiency test and that the test is done on a test bench at an ambient temperature of 25°C. Nevertheless, we would welcome a clarification in the regulation. Thank you for considering our comments. Matteo Rambaldi
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Response to Review of ecodesign requirements for household washing machines and washer-driers

21 Nov 2018

APPLiA, the Association representing the home appliance in Europe, would like to welcome the Commission proposal for the review of the ecodesign and energy labelling requirements for Washing Machines and Washer-Dryers and would like to thank the Commission for the possibility to provide comments through this platform. APPLiA supports the vision of the Commission to improve energy efficiency and more sustainable ecodesign requirements for washing machines and washer-dryers. However, we would like to provide comments regarding few key points included in the drafts here available. Please find our considerations in the document attached.
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Response to Ecodesign requirements for external power supplies

13 Nov 2018

APPLiA, the European association representing the home appliance, would like to thank the European Commission for the opportunity to contribute through open feedback to the review of the ecodesign requirements for external power supplies. On this regard, APPLiA would like to remark some of the point of our Position Paper (you can find it attach to this link). Regarding Article 1 point 2, APPLiA proposes the addition of the following scope exemption of the Regulation. APPLiA recommends to add this point: (h) docking stations supplied with equipment that can execute tasks requiring mobility without human intervention (e.g. robot vacuum cleaners). The reason behind this request is the following. Some battery powered products have to move autonomously to be able to execute their intended functions. These products will have to find their way back to the docking station when their battery charge is low, and this is possible only if the docking station continuously sends signals that guide the product to the correct location. Because of this additional feature, these docking stations cannot meet the no-load and active efficiency requirements proposed for external power supplies (EPS), therefore we request their exclusion from the scope of the EPS regulation. Moreover, APPLiA do not support the horizontal 10% efficiency information requirement for external power supplies (EPS). The main concern is that while for some products there might be an use case for 10% load operation, for the majority of the EPS there is no use case at 10% or at best only during a limited timeframe. Instead of a horizontal requirement impacting all EPS, APPLiA proposes to either set a threshold at the EPS output power level (namely 10W and below) - exempting those EPS that are typically used for battery charged devices - or direct the 10% load (information) more specifically to the relevant product groups. The latter might be done via a product specific vertical regulation. APPLiA supports provisions that exempts certain EPS made available by a manufacturer as a service or spare part. Nevertheless, we believe that the ‘repair as produced’ principle shall be respected without limitation to the time (“external power supplies placed on the market no later than 30 June 2025”). To avoid creating wastes and make product last longer, the date proposed is not sufficient. Spare parts should be totally exempted from this regulation or at least we invite the Commission to align with some other regulations that refer to 2029 (draft ecodesign motor regulations). Finally, APPLiA is asking to review the date of application of the External Power Supply regulation. We request to the Commission to allow a period of 18 months between publication of the regulation and the and deadline for the application of the requirements. It would allow manufacturers to have sufficient time to implement necessary changes. According to the expected schedule, the Commission would adopt the measure and publish them in the EU Official Journal likely in September 2019. Considering the timeline as it is established at the moment in the draft regulation, there will be only 6 months between the expected publication of the Regulation and its entry in force. This short time won’t allow manufacturers to have sufficient time to implement the new requirements.
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Response to Review of ecodesign requirements for household cold appliances

13 Nov 2018

APPLiA is glad to comment the draft Ecodesign and Energy Label regulations prepared by the European Commission. Considering the strong link between the two draft regulations, we have prepared one single paper that is valid for both ‘Have your say’ platforms, the Ecodesign and Energy Label one. It will be therefore, uploaded on both websites.
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Response to Review of energy labelling for household cold appliances

13 Nov 2018

APPLiA is glad to comment the draft Ecodesign and Energy Label regulations prepared by the European Commission (see attachment). Considering the strong link between the two draft regulations, we have prepared one single paper that is valid for both ‘Have your say’ platforms, the Ecodesign and Energy Label one. It will be therefore, uploaded on both websites.
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Response to Review of energy labelling for household dishwashers

12 Nov 2018

APPLiA, the Association representing the home appliance in Europe, would like to welcome the Commission proposal for the review of the ecodesign and energy labelling requirements for Dishwashers and would like to thank the Commission for the possibility to provide comments through this platform. APPLiA supports the vision of the Commission to improve energy efficiency and more sustainable ecodesign requirements for dishwashers. However, we would like to provide comments regarding a few key points included in the drafts here available. Please find APPLiA comments in the attachment.
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Response to Review of ecodesign requirements for household dishwashers

12 Nov 2018

APPLiA, the Association representing the home appliance in Europe, would like to welcome the Commission proposal for the review of the ecodesign and energy labelling requirements for Dishwashers and would like to thank the Commission for the possibility to provide comments through this platform. APPLiA supports the vision of the Commission to improve energy efficiency and more sustainable ecodesign requirements for dishwashers. However, we would like to provide comments regarding a few key points included in the drafts here available. Please find APPLiA comments in the attachment.
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Response to Review of ecodesign requirements for lighting products

8 Nov 2018

APPLiA, the European association representing the home appliance, would like to thank the European Commission for the opportunity to contribute through the “open feedback mechanism” to the review of the Ecodesign requirements for lighting products. APPLiA would like to express the request to include under the annex III "exemptions" lamps integrated in refrigerators and flash light 1. Lamps integrated in refrigerators On this regard, APPLiA would like to request to include under “Annex III point 2 – Exemptions”, also lamps integrated in refrigerators. As a general position, we reiterate our recommendation to exclude from the scope of this regulation all products that are already regulated by specific ecodesign and energy labelling regulations. Indeed, the current proposal introduces double regulation which can lead to establish contradicting requirements for manufacturers of refrigerators. On one side, the ecodesign regulation for household refrigerators requests manufacturers to provide spare parts for 7 years (including the light source), on the other side, the ecodesign regulation for lighting products prevents manufacturers from being able to make them available by phasing out lamps that were allowed when the refrigerator was placed on the market. Furthermore, due to the fact that a refrigerator may last longer than 7 years, the lamps used as spare parts should be allowed to be provided by the manufacturer without any time limit. Without light, the fridge would become useless and it would have to be scrapped. This goes against the principle of replaceability and durability pushed forward by the European Commission. For these reasons, APPLiA is asking for an exemption for the lamps that are integrated in refrigerators in order to prolong the life of the appliance. 2. Flash Lights APPLIA wishes to clarify the exemption of light sources in battery-operated devices, stated in Annex IV.2c. Whereas a majority of lights sources are integrated in a battery-operated devices, some are attached to the battery-operated devices. This is typically the case of flash lights, where one can find different types: Type 1: Flash light directly embedded in the camera. Type 2: External flash light including battery that is attached to the camera. Type 3: External flash light not-including battery that is attached to the camera. The camera is a battery-operated device. Therefore, APPLIA suggests the following wording for Annex III 2(d): (d) light sources and separate control gears integrated in or attached to battery-operated products, including but not limited to e.g. torches, flash lights, mobile phones with integrated torch light, toys including light sources, desk lamps operating only on batteries, armband lamps for cyclists, solar-powered garden lamps;
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

APPLiA, representing the home appliance industry, takes this opportunity to give some initial comments from the perspective of our sector in relation to the EU product policy framework contributing to a circular economy. Please find this attached. Thank you.
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Meeting with Silvia Bartolini (Cabinet of Vice-President Miguel Arias Cañete)

20 Apr 2018 · Ecodesign

Meeting with Elżbieta Bieńkowska (Commissioner) and

24 Jan 2018 · Exchange of views on Industrial Policy

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

24 Nov 2017

Dear All, CECED acknowledge receiving the document on “Evaluation of the Low Voltage Directive by European Commission”. At this stage, we would only say that we would like to be fully informed about the whole process and further steps proposed by the European Commission. We also would like to be consulted at all stages, if and when the revision process starts and are ready to deliver our input to the consultations, questionnaires, conferences and interviews that are foreseen. Michał Zakrzewski — Smart Living & Competitiveness Director CECED +32 2 738 78 12 michal.zakrzewski@ceced.eu
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Response to Revision of the Drinking Water Directive

28 Mar 2017

CECED welcomes the Commission work on the revision of the Drinking Water Directive. CECED participates to the European Drinking Water (EDW) inudstry consortium and we fully support the recommendations of this industry group to revise article 10 of the Drinking Water Directive for harmonisation of safety requirements of materials and products in contact with drinking water at EU level. This is crucial to ensure the same level of safety for all EU citizens and consumers, and will significantly reduce the burdens for companies to place their products in any Member State. CECED would like to emphasise and complement the recommendations made by the European Drinking Water consortium as follows: - Lack of harmonisation of rules for materials and products to be in contact with drinking water across EU increases burden on industry. Different legal requirements in Member States (i.e. limit values, list of authorised substances and testing methodologies) increase financial and administrative burdens for industry. Moreover, these different approaches risk to disrupt the European Internal Market and the free circulation of goods, in particular when the Mutual Recognition principle is not applied. - CECED would like to call upon the Commission to work on policy options that will lead to the harmonisation of rules for materials and products pursuant to Article 10 of the Drinking Water Directive. - Moreover, we call for the Commission to pay close attention on how DW requirements would be set to avoid overlaps with existing requirements for materials and articles intended to come into contact with food. CECED thinks that the current point of compliance for products such as home appliances, as established by article 6 of the DWD, should remain unchanged. From our point of view this provision establishes clearly the point until which DWD requirements have to be fulfilled, the tap at consumer’s homes. Hence, appliances such as coffee machines or refrigerators are considered to be out of the scope of DWD and only food contact material requirements should apply, if appropriate. While appliances such as water heaters, which are located between the public water supply and the tap are only under the scope of the DWD. - CECED would like to remark that any future requirement to be established for materials or products in contact with drinking water should be measurable, enforceable and reproducible. Moreover, we very much support the development of standards that will facilitate that obligations set out in law would be enforceable by all operators.
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Response to Ecodesign requirements for electronic displays

18 Jan 2017

The home appliance industry provides consumers with the choice of a wide range of products designed for multiple needs, convenience, performance, energy efficiency, design, robustness, after-sales service, affordability. Product legislation should encourage opportunities for innovation and competition. Manufacturers should have the freedom to choose how to design their products to better meet consumer needs. Standardisation is pre-requisite to set requirements on material/resource efficiency. It establishes a robust basis for measurement and verification. Standards must be built on a solid foundation to ensure they reflect the technical reality (state of the art). Solid evidence for feasibility, proper measurability and environmental benefit should be taken into account before developing standards. CECED and its members are already involved in the CEN/CENELEC Joint Working Group 10. Enforceability is a key aspect. Only requirements that can be measured on the product with reasonable efforts, both in terms of cost and time, should be considered. A requirement that will need excessive resources for verification will not be enforced, even if theoretically measurable. Ecodesign is a success story as requirements are based on enforceable parameters. There should be no shift in focus from energy to resource efficiency requirements without robust impact assessment, showing demonstrable environmental benefits. The Ecodesign Framework Directive 2009/125/EC Art.15.4b requires that all requirements should be backed up by data with prior assessment of the “impact on the environment, consumers and manufacturers (…) innovation, market access and costs and benefits”. In the absence of data, methodologies and widely recognised standards, any shift from resources in use (energy) towards material efficiency should not be pursued. It is also crucial to take into account what is already addressed by other pieces of EU legislation, such as those related to chemicals and end-of-life treatment. Careful attention should be dedicated to coherence among legislations, while overlapping or contradiction with other regulations, such as the WEEE Directive and the Ecodesign Framework Directive, should be avoided. We note a possible overlapping with requirements in WEEE II Directive 2012/95/EU, Article 15.1 information for treatment facilities. Multiple requirements create legal uncertainty and incoherence for EU industry as manufacturers are already giving information about materials to recyclers in order to ensure proper end‐of-life treatment. Specifying technical solutions on disassembly does not correlate with the actual recovery and recycling technology applied at the end-of-life of products. However, the provision of information on dismantability (even if not useful according to current practices) should only be addressed to recyclers and should not be kept in public domain. Liability issues need to be considered when granting access for market surveillance purposes. Therefore, setting such requirements must be cross-checked with other technical regulations. We also point out that restrictions on fixings in order to facilitate disassembly/recycling should be carefully weighed against the potential of improving durability, reliability, safety and the energy efficiency of products, which are usually dependent on the type and quality of the fixings used throughout the appliance. Furthermore, non-dismantlable fixings of components should be differentiated and assessed on a case-by-case basis. Such fixings may be used to integrate functionalities, thus contributing to waste prevention by reducing the quantity of material used in the creation of products. Requiring manufacturers not to use welding or gluing techniques other than the use of double-sided adhesive tape is very intrusive and can negatively affect the functionality of the product and industry’s competitiveness and innovation.
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Meeting with Frans Timmermans (First Vice-President)

10 Jan 2017 · Ecodesign and energy

Meeting with Frans Timmermans (First Vice-President)

10 Jan 2017 · Circular Economy/Ecodesign criteria

Response to Methodology for the calculation of the weight of EEE placed on the market and of WEEE generated

3 Jan 2017

CECED and the WEEE Forum welcome the opportunity of the public online consultation to provide comments on the new version of the draft implementing regulation and annexes. CECED and the WEEE Forum already provided DG Environment with some comments and amendment proposals in June 2015 and would like to reiterate some of them. DEFINITION OF WEIGHT OF EEE (ARTICLE 2). We believe that the Commission Implementing Regulation should clarify that the definitions provided in Article 2 apply to both household and professional EEE. CALCULATION OF THE WEIGHT OF EEE PLACED ON THE MARKET OF A MEMBER STATE (ARTICLE 3). We welcome the changes made by the Commission compared to the 2015 draft version. It is important that quantities are counted based on real, accurate and sound data as reported by EEE manufacturers to national registers. Only in case available data is not considered accurate enough, should Member States have the option to estimate the quantities of EEE placed on the national market using the methodology set out in Annex I. Ideally, Member States should notify the European Commission about their choice of calculation methodology, i.e. based on national registered data or estimates in accordance with the methodology set out in Annex I. When a Member State opts to use “the methodology”, appropriate justification should be provided to the Commission in the form of surveys, audit results or consultation with relevant stakeholders. Regardless of the method used to calculate the weight of EEE placed on the market at national level, Member States should make their choice publicly available, together with the collection targets in case Member States opt to calculate them based on the quantities of EEE put on the market (POM). CALCULATION OF THE TOTAL QUANTITY OF WEEE GENERATED IN A MEMBER STATE (ARTICLE 4 AND ANNEX II). We very much appreciate the changes brought into the wording of the discard-based lifespan profile for the batch of EEE placed on the market in year ( ). The use of the wording “discard rate” is more suitable than the 2015 wording proposal. Making both the electronic tool and the lifespan data sitting in the electronic tool available to relevant stakeholders is key to ensuring accuracy of the data and alignment with estimated calculations. CECED and the WEEE Forum would welcome the feasibility of setting a period or a demonstration for stakeholders and experts to test and evaluate the electronic tool. It is key that lifespan data at national level are frequently revised to ensure that lifespan profiles embedded within the electronic tool reflect the real technology and socio-economic developments within the Member State. We find it positive that the European Commission added point 5 in Annex II (methodology for the calculation of the total quantity of WEEE Generated in a Member State): “Before proceeding with such updates, Member States shall inform the Commission thereof and shall provide relevant evidence for such updates, including official market surveys, audit results or analysed and substantiated data resulting from consultation of relevant stakeholders”. It is a clear improvement and gives a clear message for transparency of the process at Member State level and the need for evidence backing the changes prior to the update. This could be further improved by making the lifespan data and profiles publicly available. We appreciate that the collaboration of national authorities and relevant stakeholders at national level is crucial on this dossier, as this can only improve data quality. In addition, Annex II of the draft Implementing Regulation says: “In the tool, data of EEE placed on the market from 1980 up to 2012 and product lifespan for the period 1980-2030 have already been provided.” To ensure transparency, data should be made publicly available.
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

18 Oct 2016 · harmonised standards

Meeting with Anne Bucher (Chair of the Regulatory Scrutiny Board Regulatory Scrutiny Board)

9 Sept 2016 · Better Regulation practices

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete) and Asociación Española de Fabricantes e Importadores de Electrodomésticos

19 Jan 2016 · EU Energy Label

Meeting with Elżbieta Bieńkowska (Commissioner) and

21 Oct 2015 · Development of sector & challenges

Meeting with Günther Oettinger (Commissioner)

19 Oct 2015 · Smart Home Appliances

Meeting with Andrus Ansip (Vice-President) and

2 Jun 2015 · Industry, internet of things, standardisation

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Apr 2015 · CECED vision project: Promoting Jobs, Growth, Skills, Innovation and Sustainability, European home appliance industry and DG Growth

Meeting with Markus Schulte (Digital Economy)

15 Apr 2015 · DSM

Meeting with Maria Da Graca Carvalho (Cabinet of Commissioner Carlos Moedas)

26 Mar 2015 · Meeting with M. Falcioni

Meeting with Věra Jourová (Commissioner)

23 Mar 2015 · Consumer product safety and long-term planning

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

10 Mar 2015 · Circular Economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

10 Mar 2015 · Circular Economy

Meeting with Dominique Ristori (Director-General Energy)

9 Mar 2015 · European Energy Policy priorities

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

6 Mar 2015 · Digital Single Market - interoperability

Meeting with Ruth Paserman (Cabinet of Commissioner Marianne Thyssen)

2 Mar 2015 · Emplyment Policy: Skills

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

16 Jan 2015 · 1. Presentation of the CECED vision project and High Level event (31st March)

Meeting with Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)

8 Jan 2015 · Vision of the household appliances sector for 2025, including challenges and opportunities for EU energy and climate legislation