AQUA - Association Européenne des Fabricants de Compteurs d’Eau et d’Energie Thermique
AQUA
The purpose of AQUA is as follows: a) the evaluation and resolution among its Members of problems of common interests of a scientific, technical, economical or legal nature relating to the manufacturing of Water Meters and/or Heat Meters and the application of technical standards and regulation. b) encouraging the application of an international regulation with an aim to ensure a high quality for the Water Meters and/or Thermal Energy Meters to be manufactured and sold, c) the exchange of information and experiences of a general nature among its Members with a view to optimise the technical and economical progress of the water and heat metering business as a whole, d) the advancement of interests of its Members as a whole in front of competent national or international authorities whether public or private, including the right to act in court to defend the interests of the Association and of its Members as a whole; e) the collaboration to the elimination of all restra (...)
ID: 66027272133-77
Lobbying Activity
Response to Evaluation of the Measuring Instruments Directive
7 Oct 2025
Note on Evaluation of MID AQUA Contribution On 6 October 2025, AQUA presented its position on the revision of the Measuring Instruments Directive (MID 2014/32/EU). Key messages: AQUA welcomes the targeted amendment to integrate cooling meters into the scope of MID. However, AQUA raises concerns about extending Article 10.6 to smart metering systems. Legal metrology should remain limited to the generation, storage, and display of measurement results. The repetition and communication of results (e.g. remote reading, data transfer) should remain outside its scope. Enlarging MID to smart metering would create major challenges: unclear responsibility for metrological control, difficulties with software updates on consumer devices, and uncertainty on how to finance such updates. AQUA proposes to explicitly define in MID: - Generation of measurement results in scope of legal metrology - Repetition of measurement results outside scope Requirements for smart metering systems are already covered by other EU legislation (Energy Efficiency Directive, Radio Equipment Directive, Cyber Resilience Act). AQUA supports digitalisation to reduce administrative burden, including electronic declarations of conformity, digital contacts on products, and electronic instructions for consumers. About AQUA AQUA Metering is the European trade association representing all manufacturers of water and smart meters. Based in Paris, AQUA unites the industry to ensure the highest standards of quality, compliance, and innovation in metering technologies. Its mission is to: Represent the interests of European manufacturers towards EU institutions and standardisation bodies. Provide technical expertise and policy input for fair regulation and a harmonised single market. Promote sustainable and digital solutions that support energy efficiency and environmental protection. AQUA acts as the collective voice of the European metering industry, fostering trust, reliability, and innovation in measurement systems.
Read full responseResponse to Omnibus Regulation Aligning product legislation with the digital age
20 Aug 2025
Dear European Commission Metrology Team, On behalf of Aqua Metering, the European trade organization representing water meter and thermal energy manufacturers, we would like to thank the Commission for the opportunity to comment on the proposed Omnibus Regulation aligning product legislation with the digital age. We welcome the initiatives overarching objectives to reduce administrative burden, avoid duplication, and facilitate the digital transformation of product compliance across the Single Market. As manufacturers of regulated measuring instrumentsspecifically within the scope of the Measuring Instruments Directive (MID)we would like to provide the following feedback: General Support We strongly support the move toward digital declarations of conformity and electronic product instructions, as these have the potential to streamline compliance efforts and reduce unnecessary paper use. The proposed digital contact point system between economic operators and authorities is a positive development that could improve traceability and communication efficiency. Points for Consideration 1. Accessibility and Practical Implementation Ensuring that digital declarations and instructions are easily accessible to all end-users, including those with limited internet access, will be criticalparticularly in public procurement and infrastructure settings. The free of charge requirement, while well intentioned, could create practical and financial difficulties for manufacturers. The regulation does not clearly address how this obligation should be implemented in a feasible and non-discriminatory way. We therefore suggest that: o the paper version free of charge should be provided only upon request, especially in cases of accessibility needs. o the manufacturers should be allowed to recover reasonable costs, strictly to cover expenses, not for profit. o an opt-in. system should be introduced at the time of purchase, to avoid unnecessary paper waste and streamline planning. Like when you pay with a card and the store clerk asks if you need a paper slip. 2. Long-Term Document Availability Maintaining digital instructions online for at least 10 years is understandable from a consumer protection standpoint. However, clarity is needed on: o The specific responsibilities of manufacturers versus distributors. o What constitutes "expected lifetime" for metering products, which often exceed 10 years in the field. 3. Paper Instructions for Safety Information While we agree that safety-critical information should be provided on paper or on the product, we request clearer guidance on what qualifies as such, to ensure consistent application across Member States. 4. Digital Product Passport Alignment Should water meters fall under future digital product passport requirements, we support the proposed inclusion of declaration and instruction data to avoid duplication. However, we encourage the Commission to ensure: o Technical specifications are realistic for small and medium-sized enterprises (SMEs). o Adequate transition periods are built into the regulation. 5. Harmonisation Across Directives It will be important to ensure full consistency in definitions and obligations across the MID and any future updates to avoid fragmented compliance requirements. Conclusion We appreciate the direction of the proposal and are generally supportive, but we respectfully request further technical guidance and coordination with industry to ensure proportionality and clarity during implementation. Aqua Metering remains available to support this process and represent the views of European water meter manufacturers. Thank you again for the opportunity to contribute.
Read full responseResponse to Omnibus Directive Aligning product legislation with the digital age
6 Aug 2025
Consumer Right to a Paper Version Article 7, Pages 3031 While we support the principle of ensuring accessibility of product information to all consumers, the requirement to provide a paper version free of charge raises significant concerns from a practical and financial standpoint. The cost of producing and distributing paper instructions on an individual, on-demand basisrather than in bulkcan be substantial, especially for manufacturers who have already transitioned to digital formats. Moreover, the current provision lacks clarity on how this obligation should be implemented in a fair, non-discriminatory, and economically sustainable way. To avoid undue burden on manufacturers and potential misuse of this right, we recommend the following adjustments: Paper versions should be made available upon request, rather than by default. Manufacturers should be allowed to recover reasonable costs associated with printing and delivery, provided this is done transparently and without profit. Specific exemptions or support should be considered for consumers with accessibility needs or limited digital access, to ensure inclusivity. We believe this approach strikes a more appropriate balance between consumer rights and practical feasibility.
Read full responseResponse to Targeted technical update of EU rules on measuring instruments
25 Feb 2025
AQUA Metering welcomes the integration of cooling meter to the scope of MI-004 Thermal Energy Meters. This will be beneficial for the industry by reducing double certification efforts and beneficital for consumers by reducing unnecessary cost. AQUA Metering rises concerns regarding the extension of the scope of legal metrology from as of today the generation of measurement values to the repetition of measurement values. Legal metrology and therefore the Measurement Instruments Directive shall also in the future concentrate on the measurement instrument (measure, store and indicate measurement results). The secure and consistent transmission of measurement values are already covered from other existing and upcoming regulations e.g. Energy Efficiency Directive, Radio Equipment Directive, Cyber Resilience Act).
Read full responseResponse to Exemptions under RoHS for lead as an alloying element in steel, aluminium and copper
7 Feb 2025
AQUA www.aqua-metering.org is the Association of European Manufacturers in the Smart Water and Thermal Energy meters field. AQUA members like Kamstrup, Honeywell, Diehl, Landis + Gyr are operating in all EU countries and Switzerland and constantly investing in new technologies to meet industry needs for more frequent and accurate measurement information. AQUA members support the EU's aim to limit the lead content in the flow sensor of these devices, especially in water meters. However, although low-lead and lead-free alternatives are available on the market, there are some technical challenges and in some cases substitute alloys do not have the required properties such as the known lead-containing alloys. This is particularly advantageous for fittings and valves that must withstand high pressures, so lead does improve the density and impermeability of the flow sensor as well. Lead increases the corrosion resistance of brass, especially when it comes into contact with chlorine water or other aggressive media. This has also a positive impact on the lifetime of the devices as our meters are designed to last for 10 years or more. Also lead improves the flow behaviour of the melt, which facilitates the production of complicated casting moulds, and it reduces the risk of hot cracks during the solidification process. It is difficult to find a full replacement meeting all requirements and which does not greatly increase development costs and time, and leads, among other things, to design changes which in turn leads to new metrological approvals. The brass manufacturers are working urgently on the proposition to our business, but for this moment, the reasonable solutions till this moment are only two materials, which are not fitting the needs well. This also leads to limit the competitiveness of European products outside the EU. In addition, there are other European legal provisions regarding lead. Based on Directive (EU) 2020/2184 on the quality of water intended for human consumption and Implementing Decision (EU) 2024/367, only brass alloys listed in the ECHA positive list may be used. These alloys typically have a lead content of <=0.2%. This requirement will be implemented with a transitional period until 2032. It would be very helpful if the exemption for requirements of RoHS (2011/65/EU) and Directive (EU) 2020/2184 were aligned. For this reason, a further extension of the exemptions would be highly desirable in order to have more time to have alloys that we can use as substitutes and to switch production to these alloys. Thank you for taking these arguments into account.
Read full responseResponse to Exemptions under RoHS for lead in glass or ceramic of electrical and electronic components
7 Feb 2025
AQUA is the Association of European Manufacturers in the Smart Water and Thermal Energy meters field. AQUA members like Kamstrup, Honeywell, Diehl, Landis + Gyr are operating in all EU countries and Switzerland and constantly investing in new technologies to meet industry needs for more frequent and accurate measurement information. For reliable and precise flow measurement with ultrasonic technology our members use piezoceramic components namely ultrasonic transducers in their flow meters. The flow meters are designed to last 10 and more years, to support temperatures up to 130 °C and to withstand high pressure up to 16 bar, with very wide range of flows to be measured. We are aware of that there are several lead-free alternatives on the market, however they still do not meet requirements to fit the mentioned specifications above. Lead-free alternatives are still under development by most manufacturers. This can lead to poor competitiveness and gives us a weak basis to work with a necessary change in our products. Due to this situation, it is impossible to change our products in the given timeframe which would lead to massive economic losses and probably to a lack of certified measuring devices e.g. for water and heat measuring on the market. It is also important to now, that the measuring devices fall into MID scope, and such change will force us to preform additional certification processes, and our industry still needs a time to work on approving the products after development stage. For this reason, a further extension of the exemptions would be highly appreciated Thank you for taking these arguments into account.
Read full responseResponse to Targeted technical update of EU rules on measuring instruments
15 Oct 2024
AQUA is the Association of European Manufacturers of smart water and thermal energy meters. AQUAs 16 members are constantly investing in new technologies to meet industry needs for more frequent and accurate measurement information. Ten countries are represented in AQUA, out of 27 EU members. A harmonized legal metrology legislation is the basis for the EU single market for the benefit of all market players from companies to citizens. To adapt the MID to actual and upcoming innovations and requirements we see following topics. 1. Integration of cooling meters to the scope of MID, Annex MI-004 2. Enable Digital Product Information (sharing documentation by electronic means, e.g. digital product pass) 3. Keep scope of legal metrology (clear separation of creation and repetition of measurements, e.g. communication interfaces) You can find the extended elaboration of our position in uploaded pdf: AQUA MID Revision Comment to EC.pdf We would like to also highlight that the proposed timeline will be not realistic from our experience and the transposition timeline should be elongated. We hope that our proposal will be revised positively and taken into consideration. Thank you in advance,
Read full responseMeeting with Virginie Joron (Member of the European Parliament, Shadow rapporteur for opinion)
11 Dec 2023 · standard essential patents
Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and Avanci, LLC and
30 Nov 2023 · Standard Essential Patents Regulation (staff level)
Response to Standard Essential Patents
8 Aug 2023
AQUA and FARECOGAZ POSITION PAPER on the EC Proposal for a Regulation on Standard Essential Patents (SEPs) EU2023/0133 SEP licensing: a major challenge for the gas, water and energy metering industry Executive summary Smart meters are key enablers of the EU clean energy and digitalization priorities. European smart meter manufacturers are currently facing challenges due to the licensing practices of some holders of standard-essential-patents (SEPs). The behavior of some SEP holders may unintendedly slow down the development of the EU digital and energy infrastructure by preventing the roll out of smart meters to more households, undertakings, and Member States. AQUA and FARECOGAZ are calling on the EU institutions to ensure a fair and balanced outcome in the upcoming intellectual property reform to implement the principle of Fair, Reasonable and Non-Discriminatory licensing. Under such principle, patent owners should not be allowed to deny licenses to companies willing to negotiate and sign a FRAND license, and the royalty should only be set based on the value of the technology that relates to the standard. AQUA and FARECOGAZ would welcome clear guidelines and more transparency to level out the power imbalance between SEP holders and implementers. A well-designed independent FRAND determination process may break critical deadlocks between SEP holders and implementers. Holders and implementers alike would benefit from balanced rules and a predictable ecosystem, which would avoid high litigation costs, ensure access to standardized technology thus enabling all parties to continuing investing in their respective technology field. Introduction The European Union has recently published a proposal for a regulation of the legal framework for Standard Essential Patents (SEPs) (the Proposal). The SEP framework will have a profound impact on smart meter manufacturers, an industry which employs thousands of workers and represents a very large turnover. This position paper represents the opinion of the European Association of European water and thermal energy meter manufacturers, AQUA, and of the European association of manufacturers of gas meters, FARECOGAZ. AQUA and FARECOGAZ represent, to a large extent, family-owned small and medium sized companies providing products and projects for critical infrastructure and energy efficiency in Europe. Why smart meters are vital to Europes energy transition. Climate action is at the heart of the European Green Deal with the aim for Europe to become the worlds first climate-neutral continent by 2050. The dual green and digital transformation is a key element of the European strategy for competitiveness and a key element to achieving the NextGenerationEU plan. The objective is to place Europe as a global leader in clean energy technology, driving sustainability and creating new business opportunities stemming from the growing demand for more smart and green solutions. Smart meters are an important element on the road to a CO2 neutral society and in the reduction of energy use. Smart meters measure the consumption of thermal energy, gas, water, or electricity and typically transmit the measured values via a wireless communication system to a billing or building management system. This allows efficient management and control of critical resources like energy, water and gas, an increased consumer awareness and optimization and digitalization of the related processes. Smart metering systems are a key enabler for further innovation and digitalization in the supply and energy sector. The deployment of this technology and the benefits it provides are essential in achieving a cost-efficient, energy saving and consumer-centric energy transition, making the energy system smarter, demand driven, flexible and greener. This will ensure a successful green and digital energy transformation while simultaneously strengthening the EU economy. This was also strategically laid out by the European C
Read full response13 Jun 2023
AQUA, the European Association for Water Meters and Thermal Energy meters, welcomes the opportunity to provide feedback to the European Commissions consultation on the RED Delegated Regulation 2022/30 on cybersecurity aspects. The postponement of the RED Delegated Act application date until August 1, 2025, is crucial for Water Meters and Thermal Energy meters manufacturers to redesign and adapt their products in accordance with the available harmonized standards, while allowing them to complete the appropriate conformity assessment procedure before the Delegated Act becomes applicable. In line with the formal request of the European Standardization Organizations (ESOs), we believe the delay of the initial schedule for the delivery of harmonized standards should go hand in hand with the proposed amendment to the application timeframe. Manufacturers would not otherwise be able to place radio products on the EU market due to the lack of standards and the lack of sufficient availability of notified bodies under this Delegated Act. We support the updated timeline proposed by the European Commission and highly appreciate the efforts made to launch this initiative.
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