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Asociación multisectorial de empresas de la electrónica, las tecnologías de la información y la comunicación de las telecomunicaciones y de los contenidos digitales

AMETIC

Los principales objetivos de AMETIC son la promoción y el desarrollo de los sectores citados, con una atención especial a la generación de valor añadido y la actividad industrial y de servicios en España.

Lobbying Activity

Response to Sequential recording of data into qualified electronic ledgers

3 Oct 2025

You can find our comments in the attached file.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

AMETIC welcomes the harmonization efforts in the Proposal Regulation for packaging and packaging waste and a more circular economy. However, some measures in the PPWR proposal raise concerns regarding their technical feasibility and practicality. A well-designed regulation is key to support the transition to a circular economy. On this basis, the following suggestion of amendments, in the document attached, should be taken into account by policymakers.
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Response to Digital Levy

11 Feb 2021

AMETIC has fervently defended that the fiscal challenges derived from the globalization of the economy should be debated and agreed upon at the international level, within the Organization for Economic Cooperation and Development (OECD), avoiding unilateral solutions that place Europe in a position of clear competitive disadvantage, reducing the interest to attract investment and penalize innovation and business growth. In this regard, AMETIC has argued that, although it is alleged that this kind of tax would only affect large multinationals, it is more than likely that the tax will be transferred along the value chain, with a higher cost for all users of services including SMEs and, ultimately, consumers. In order to avoid this situation, it is important to back up the efforts made in the OECD and wait for an agreement to be reached in this organization. The OECD process is designed to reform the rules governing taxing rights between countries and to prevent the spread of unilateral measures. Different proposals approved in some Members States could hinder the consensus to reach an agreement at the OECD. This proposal for a EU’s digital levy is exactly the type of tax the negotiation is designed to prevent. Each of the policies outlined would violate the spirit of what pillar 1 intends to accomplish. For these reasons, we are concerned that this kind of proposal may make it more difficult the achievement of consensus in the ongoing work at OECD and could lead to trade tensions with other countries . The US has already pursued Section 301 trade investigations against the EU and a number of EU countries, and the new US administration has stated it would look to respond if countries continue to move forward with unilateral digital levies. Besides, it is important to consider in the Assessment the numerous changes resulting from previous BEPS reforms and US tax reform, etc. On the Inception Impact Assessment, the Commission continues to assert that technology companies are undertaxed, when, in fact, are paying similar rates of corporate income tax than traditional companies. For example, the study, published in February 2018 by the European Center for International Political Economy (ECIPE), Digital companies and their fair share of taxes: myths and misconceptions, concludes, based on an analysis of companies operating in Europe, that there is no evidence that companies that carry out their activity through digital channels pay less taxes than their peers in traditional channels. In similar terms, the well-known study by Copenhagen Economics, from March 2018, is pronounced. The digitization of the economy has proven to be the most dynamic and fastest growing part of recent years that will drive future prosperity in Europe, especially during the pandemic. A digital levy would have a negative impact on the global economy when it is in a fragile state and the COVID pandemic is far from over. It has been shown through independent research that SMEs and other parties in the supply chain are negatively impacted by digital tax measures, which act as an effective tax on digitalisation and innovation. With the current COVID restrictions, digital channels are an enabler for business to continue their economic activities and this will drive the economic recovery ahead. For all the reasons above, we fervently request to focus on streamlining the international debate, to achieve a global solution that avoids situations that harm economic growth.
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Response to Legislative framework for the governance of common European data spaces

5 Feb 2021

First of all, we welcome European Commission’s removal of an explicit data localisation requirement for sensitive personal data and sensitive commercial information and the fact that the Regulation no longer has explicit data localisation rules. We applaud an initiative that will allow the re-use of the information and data in the hands of the public and private sectors, provided with sufficient legal guarantees, aligned with the personal data protection regulations, regardless of the different Data Sharing models that are outlined in the European Data Strategy (G2G, G2B, B2G and B2B). Second, we appreciate that such overarching framework encompasses horizontal measures relevant for all common European data spaces, as framed by the GDPR/e-privacy texts and that it does not compete nor challenge data protection EU rules. On the contrary, full coordination and coherence is sought in the applicable regulations in this area. Nevertheless, the draft goes beyond the GDPR and aims at providing protections for both personal and non-personal data. For instance, the Explanatory memorandum of the Data Governance Act mentions the “personal data sharing intermediary” that would be “designed to help individuals exercise their rights under the General Data Protection Regulation (GDPR)”. Recital 22 on “providers of data sharing services (data intermediaries) stresses that those will “facilitate the aggregation and exchange of substantial amounts of relevant data” but does not define who such stakeholders will be. And recital 23 mentions that “a specific category of data intermediaries includes providers of data sharing services that offer their services to data subjects in the sense of Regulation (EU) 2016/679”. We are concerned that such a distinction is not clear enough and the DGA should clearly distinguish non personal data obligations from the set of new obligations going beyond GDPR with regard to personal data sharing. It is important to define properly, in conceptual terms, the different actors included in the scope of the proposal and, in the same way, aligned it with the goals of Regulation (EU) 2018/1807 on a framework for the free flow of non-personal data in the European Union. At the same time, It is also important to take into account the regulation on Artificial Intelligence (AI) since access to data and information in this area will be crucial in order not to stop the definitive take-off of these technologies in the EU. Third, we understand that, since the “Schrems II” ruling created additional obligations for entities exporting data outside of EU (to non-adequate countries), new requirements are included in this Regulation. We consider that the fact that companies handling sensitive data are asked to provide “adequate measures” that will prevent the data from being accessed by authorities in third countries contrary to EU laws aligns with the GDPR risk-based-approach. As accountable companies already put such risk-assessment procedures & documentation in place, we consider it fully fits GDPR and does not create any over-burdening documentation obligation. Fourth, it is very important to delve into the so-called recommended technologies to promote the protection of personal data and that, ultimately, can help improve the processes of releasing personal data with the appropriate risk approach and enhancing the application of the principles of privacy by design and by default contained in article 25 of the GDPR. Likewise, a greater specification of possible standards or parameters associated with interoperability referred to in article 11.4 may help the development of data exchange services. More specific comments on the file attached.
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Response to Requirements for Artificial Intelligence

8 Sept 2020

Scope ○ We caution the Commission on considering to significantly expand the scope of the future AI regulation to the open ended category of “automated decision making” This would go against the initial, thoughtful direction proposed in the AI whitepaper that proposes to focus on the risk-based, double-criterion for sectorial and application/use-based AI technologies. If AI were defined as “automated decision making” for the purpose of the future AI regulation, it would create unproportional, unjustified regulatory obligations that would not only deter development and deployment of AI-based applications in Europe, but also automated systems that do not pose any risk nor harms. ○ Definition of immaterial harm: We reiterate the concerns around introducing the open-ended concept of “immaterial harm” into the future AI legislation. We propose as an alternative to refer to “significantly restricting the exercise of fundamental rights”. Policy options ○ Option 0 (baseline): We do believe that there is merit in ensuring that the existing EU regulation is properly implemented with regards to AI before putting in place any new prescriptive AI-specific rules. ○ Option 1 (industry-led intervention): No matter what policy options are pursued, lending support to the industry in establishing and implementing norms of responsible practices and sharing best practices is worthwhile. ○ Option 2 (legislation on voluntary labelling): We remain skeptical on the impact of a labelling scheme on the uptake of trustworthy AI in Europe. An administrative burden on SMEs to comply with the onerous labelling obligations -- if drafted on the basis of the update Assessment List for Trustworthy AI from the EU AI HLEG-- could significantly outweigh the benefits of such a scheme. ○ Option 3 (legislation with mandatory requirements): Overall, the opportunity cost of not using AI should be part of the assessment when considering any future legislation aiming to reduce risk and harms from the use of AI applications. Legislation should ensure legal certainty, be proportionate and increase trust in AI without unduly hindering AI-driven innovation. - Remote biometric identification systems may be a good example of an application to which mandatory requirements could be applied in a risk-based framework. - We support a well-defined risk-based approach to the AI regulation that takes into account both the severity and likelihood of harm. A sector and use/application base criteria -- as proposed by the EC’s whitepaper -- at large seem to be a good starting point. - We strongly caution against an EU legislative act for all AI applications, that would make no distinction between the AI applications that can pose significant risk/harm and those with no or lower risk profile. Such a legislative instrument would be significantly unproportional to the problems so far identified by the European Commission, create significant barriers for AI adoption (additional costs, delay, administrative burden) in Europe, result in opportunity costs in some applications due to lack of AI implementation, and risk lowering the bar for those AI applications that are very likely to raise significant risks. Enforcement ○ We support the ex post enforcement for when problems arise as the most appropriate and proportionate mechanism, except in fields where ex-ante assessments are already established practice. In those situations, we recommend aligning any ex-ante assessment with existing procedures. ○ If the Commission insists on the ex-ante enforcement, we strongly caution against a third party ex-ante assessment and recommend instead self-assessment procedures based on clear “due diligence” guidance from the regulators. A practical approach would be for regulators to provide detailed templates and guidance on how to carry out and document the risk assessment, but delegate responsibility to those using and most familiar with the AI system to conduct an accurate assessment.
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Response to Fairness in platform-to-business relations

21 Jun 2018

La propuesta que nos ocupa tiene un importante efecto en las empresas que representamos, afectando a una gran variedad de plataformas, pymes, startups, desarrolladores de aplicaciones, sin olvidar a compañías que están inmersas en un proceso de transformación de su modelo de negocio hacia el modelo de plataforma. Sin embargo, la propuesta apuesta por una aproximación única que no tiene en cuenta particularidades de los servicios que ofrecen los proveedores de servicios de intermediación y que pueden resultar en un detrimento de la economía digital. Por esta razón, nos gustaría realizar una serie de comentarios que pueden servir para entender los retos a los que nos enfrentamos y que incluimos en el documento adjunto.
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Response to Measures to further improve the effectiveness of the fight against illegal content online

27 Mar 2018

Please, find attached AMETIC's comments. Kind regards.
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Response to Fairness in platform-to-business relations

22 Nov 2017

Dear Sirs, Please find enclose the position of AMETIC on the Inception Impact Assessment on Fairness Platforms to Business relations. Kind regards
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Meeting with Günther Oettinger (Commissioner) and Google and

20 Nov 2015 · Digital transformation of the European industry