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Asociatia Principia

Asociatia Principia is a Romanian organization protecting the legal rights of citizens and consumers.

Lobbying Activity

Response to New EU Agenda for Preventing and Countering Terrorism and Violent Extremism

19 Jul 2025

In our opinion, we believe that you should pay greater attention to respecting the rule of law. We consider it extremely important to respect the rule of law in all Member States so that terrorist organizations cannot be financed or thrive (by establishing terrorist cells on the territory of Member States). However, we would like to draw your attention to some of the mechanisms you have put in place to fight corruption, which we think aren't working. On July 13, 2022, you stated the following (https://romania.representation.ec.europa.eu/news/eurobarometrul-privind-coruptia-evidentiaza-o-preocupare -serioasa-randul-cetatenilor-si-al-2022-07-13_ro?prefLang=en&etrans=en): "Corruption remains a serious problem for EU citizens: 68% of them believe that corruption is still widespread in their country. For 63% of EU companies, corruption is also a widespread problem in their country and only 37% of respondents believe that anti-corruption measures are applied impartially and without hidden purposes." With regard to Romania, you state the following in this Eurobarometer: "72% of respondents believe that corruption is widespread in Romania. 39% responded that the level of corruption in the country has remained the same, and 36% considered that it has increased in the last three years." And on 22 November 2022, you also stated the following (https://romania.representation.ec.europa.eu/news/romania-obiectivele-de-referinta-din-cadrul-mecanismului-de-cooperare-si-de-verificare-sunt-2022-11-22_ro): "The Commission concludes that Romania has made sufficient progress in fulfilling the commitments it made under the CVM at the time of its accession to the EU and that all benchmarks can be satisfactorily closed. The assessment also takes into account developments in the rule of law in the EU and, in particular, Romania's full engagement in the rule of law reporting cycle. Going forward, the Commission will no longer monitor and report on Romania under the CVM, but monitoring will continue under the annual rule of law cycle." In this regard, we compared the reports prepared by the Group of States against Corruption (GRECO) for Romania for the period 20172024 with the data provided by Transparency International on the Corruption Perceptions Index for the same period (20172024), and our conclusion is that the mechanism presented by you (GRECO) is not an effective tool in combating corruption. The Corruption Perceptions Index for Romania has stabilised between 24th and 27th place out of the 27 member states (contrary to your statements here: https://europa.eu/eurobarometer/surveys/detail/3361). The closer the number is to the total number (27) of member states, the higher the Corruption Perceptions Index is. When it comes to hate speech, we believe that institutions such as the Ombudsman play an important role. These institutions should meet the requirements of a court, as mentioned in both the case law of the European Court of Human Rights and the case law of the European Court of Justice.
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Response to Revision of the 'New Legislative Framework'

15 Jul 2025

In our opinion, we disagree with this legislative initiative proposal (point b.3 of the roadmap you presented). You are making a real legislative mess over here. You are presenting several normative acts related to different areas, so that everyone can understand what they want. Your digital passport (a QR code) is nothing more than a digital medium for communicating information that accompanies a product. Thus, we will no longer have an impressive weight of documents accompanying the product we have purchased, but we will see a specific QR code from which this information will be communicated to us. This digital passport will not provide greater protection, nor will it diminish the protection that currently exists for natural or legal persons. Therefore, your references to the declaration of conformity, product traceability, or notified bodies strictly concern products that fall under the Machinery Directive (this does not apply to consumers). We continue to believe that the information accompanying the product should be made available to the buyer (user manual in the language of the country concerned, declaration of conformity, service manual, etc. depending on the legislation applicable to each area) and on a durable medium. We would have liked you to focus more on the development of new projects/technologies that would bring more investment to the EU. Simply presenting various statements on the Union's wishes for the development of quantum technology (European Declaration on Quantum Technologies & Quantum Europe Strategy: Quantum Europe in a Changing World) will not bring investors to the Union's table. In the case of Centre for Legal Resource on Behalf of Valentin Campeanu v. Romania, in the dissenting opinion of the distinguished judge Pinto De Albuquerque, the following was stated: "What does 'salus populi suprema lex esto' mean, which translates as 'the salvation of the people is the supreme law'? This means that public welfare and safety should be the main priority in political and legal decision-making. In essence, this maxim emphasizes the importance of considering the general welfare of society when drafting and applying laws." The European Union should be the cradle of fundamental human rights and freedoms as well as the epicenter of technological innovation, and not just a market (as you constantly like to remind us). You are postponing research projects due to a lack of vision and not due to a lack of necessary technology or adequate funding.
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

11 Jul 2025

In our opinion, with this act, you are doing nothing but violating the very treaties under which the European Union operates (the Treaty on the Functioning of the EU and the Charter of Fundamental Rights). The so-called durability guarantee that you are trying to legislate is in reality an under guarantee, which will further encourage consumers in the EU single market to buy products from outside the EU. We note that you continue to refuse to apply the provisions of the Machinery Directive to consumers and it is not clear to us why you are doing so. Consequently, as long as you refuse to ensure a high level of protection of consumers' rights within the Union (as set out in the provisions mentioned in the two pieces of legislation mentioned above) and we will refuse to accept your so-called legislation in this area.
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Response to Supplementary pensions – review of the regulatory framework and other measures to strengthen the sector

10 Jul 2025

With regard to your legislative initiative, we can say that we have not been able to understand why Draghi used pension funds as an example in his report. Draghi pointed out that the money accumulated by these investment funds is invested in low-risk, low-yield financial products. For example, why invest in government bonds and bank deposits rather than in publicly traded companies (where there is risk but also higher returns)? Draghi laments the situation of people who are about to retire (the elderly) and who cannot enjoy a higher pension because they have not invested in stock market products. When we talk about the elderly, these people are considered by ECHR case law to be vulnerable persons (very young people and elderly people_ JUDGMENT of 17 July 2014, Legal Resource Centre on behalf of Valentin Câmpeanu v. Romania (Application No. 47848/08), dissenting opinion, para. 11). We must also draw your attention to the fact that when we talk about elderly people, these individuals are the preferred victims of various criminal organizations, who seek to mislead them into investing in fictitious products. In our opinion, Draghi used the wrong example in his attempt to attract new investors to stock market products. In the context of creating a single capital market, these investments in stock market products will come naturally. However, with the creation of this single capital market, other problems arise, such as the creation of a supervisory authority and the lack of financial education among some EU citizens. In this regard, why should we stop here and not also consider the possibility that a consumer could directly purchase the entire range of public services (natural gas, electricity, drinking and domestic water, etc.) from a single market in any EU Member State they wish? We would also like to see your progress on the BRAIN INITIATIVE and predictive programs.
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Asociatia Principia demands real funding and protection for NGOs

10 Jul 2025
Topic — The EU seeks to strengthen civil society engagement and protect civic space.
Message — The association demands adequate funding and protection instead of symbolic dialogue initiatives. They call for reforms to prevent political actors from creating fraudulent front organizations. The strategy must address national authorities' refusal to follow international court rulings.123
Why — Direct financial support would help small human rights organizations sustain their operations.4
Impact — Politically-controlled organizations would lose access to funding intended for independent civil society.5
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Response to EU Fusion Strategy

12 Jun 2025

We appreciate the fact that you are trying to solve the problems mentioned by Draghi in his EU Competitiveness Report, but nevertheless, we draw your attention to the fact that the EU, in order to be competitive, should not be satisfied with the problems identified in the above-mentioned report. Draghi had no way of foreseeing the technological advance in certain key areas (from our point of view extremely important) that some States were going to achieve, so references in this regard were not indicated/specified. Your "competitiveness" should not be limited to catching up with someone, but you should present strategies that go further/exceed what you mention: ,, United Kingdom: Towards fusion energy in 2021 and its update in 2023; Japan: Fusion energy innovation strategy (2023); USA: Department of Energy Fusion Energy Strategy for 2024. And we here, would like to know from you what is the EU strategy regarding the exploitation/study/use of cosmic phenomena such as black holes. Such a laboratory experiment, through which the possibility of using the energy created by a black hole was demonstrated, was carried out in the USA (,,Physicists create 'black hole bomb' for first time on Earth, validating decades-old theory). Both the USA through its government agencies (NASA & DARPA) and India are presenting ambitious initiatives in the study/exploitation of black holes. A black holes energy density dwarfs nuclear fusion (even that of a sun), and you, by exploiting this new source of energy, could surpass the technology of the artificial sun. The President of the European Research Council, Professor Maria Leptin, in her speech in 2022, before the ITRE Parliamentary Committee, said the following:,,In my view, any organisation that wishes to represent excellence must be permanently self-critical and must continuously evolve'' and ,,My message to policy makers is: trust researchers and give them the means to pursue their best ideas! Thats the best investment we can make in our future''.
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Asociatia Principia Urges EU to Strengthen Consumer Warranty Protections

1 Jun 2025
Topic — A consultation on the EU’s new consumer policy strategy for 2025-2030.
Message — The association requests extending mandatory warranties to five years for durable goods. They argue for reversing the burden of proof and ensuring better manufacturer traceability.123
Why — This would reduce financial burdens on consumers by forcing manufacturers to cover premature product failures.4
Impact — Dishonest retailers and manufacturers lose by being held accountable for selling low-quality or counterfeit goods.56
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Asociatia Principia demands transparency on EU energy grid benefits

21 May 2025
Topic — Measures to modernize European energy grids to ensure affordable and secure power.
Message — The organization demands transparency regarding replacement energy sources and clear economic benefits for citizens. They also urge the EU to avoid security risks by prioritizing domestic technology over foreign alternatives.123
Why — This would ensure public funds translate into tangible jobs and savings for consumers.4
Impact — Global technology and energy firms may lose lucrative contracts to European companies.5
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Response to Anti-racism Strategy

18 May 2025

Hello, It is not clear to us what your strategy presupposes, and you do not elaborate on this. Member States are parties to the International Convention on the Elimination of All Forms of Racial Discrimination, and you receive annual reports on how the national public anti-discrimination authorities function. You present the recommendations of the European Commission against Racism and Intolerance, a case law of the courts, at the UN level (Committee on the Elimination of Racial Discrimination), at the European Court of Human Rights and the Court of Justice of the European Union, is as clear as possible regarding the phenomenon of racism. However, as long as you consider that there is a problem with this phenomenon of racism, in our opinion, we consider that the public anti-discrimination authorities at the level of the Member States are dysfunctional. For the period 2019-2023, we monitored the functioning of the anti-discrimination authority in Romania and obtained the following results: A. (number of investigations carried out) -year 2019: 994 Decisions issued vs. 495 actions (challenges) opened against its decisions, only 40 (4%) investigations and within 763 files opened in national courts, this authority was called as an expert to formulate points of view; -year 2020: 893 Decisions issued vs. 523 actions (challenges) opened against its decisions, only 29 (3%) investigations and within 1533 files opened in national courts, this authority was called as an expert to formulate points of view; -year 2021: 880 Decisions issued vs. 475 actions (challenges) opened against its decisions, only 46 (5%) investigations and within 3019 files opened in national courts, this authority was called as an expert to formulate some points of view; -year 2022: 686 Decisions pronounced vs. 595 actions (challenges) opened against its decisions, only 42 (6%) investigations and within 4392 files opened in national courts, this authority was called as an expert to formulate some points of view. From these statistics it can be seen that every year the number of decisions issued by the anti-discrimination authority decreases and the number of cases filed directly with the court by citizens whose rights have been violated, increases. This phenomenon can be justified by the fact that this body is transforming from an active body into a passive body, a simple observer. B. Time when the decisions of the anti-discrimination authority were issued (year 2023): - 9% Decisions rendered within 90 days (28 Decisions). 79% are covered by Decisions regarding the filing of cases and the invocation of the incompetence of the anti-discrimination authority; - 91% Decisions rendered after the 90-day deadline (282 Decisions); Decisions rendered after the 90-day deadline are presented as follows: - 16.67% Decisions rendered within 6 months; - 26.60% Decisions rendered within 12 months; - 27.66% Decisions rendered within 18; - 20.92% Decisions rendered within 24 months; - 3.55% Decisions rendered within 29 months; - 2.13% Decisions rendered within 35 months; - 0.35% Decisions rendered within 40 months; - 1.42% Decisions rendered within 44 months. The decisions issued by the anti-discrimination authority in the period 2019-2022 are based on a tiny percentage of only 5% of the investigations carried out. In 2023, the percentage of investigations carried out is even lower, at only 1.6%. Most of the decisions issued by the anti-discrimination authority are in the time interval of 12 24 months in 2023. This authority carries out simple (imprecise) administrative investigations and does not carry out precise investigations, such as technical-administrative ones. Our conclusions are also confirmed by the report (on non-discrimination in the period 1.01.2022 01.01.2023, pg. 12) of the country communicated to you (the European Commission) in 2023:,,the disappearance of effective remedies in favor of recommendations devoid of any legal force; the decreasing quality of l
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Response to Quantum Strategy of the EU

11 May 2025

We appreciate what you intend to do, but as the European Court of Auditors stated in its report Microchips: EU off the pace in a global race https://www.eca.europa.eu/en/news/NEWS-SR-2025-12 and M. Draghi in his report The future of European competitiveness_ https://commission.europa.eu/topics/eu-competitiveness/draghi-report_en , you must be aware of the harsh reality and start from there, with the way you plan your strategy. In this sense, we could say that you are using the term quantum/quantum incorrectly. This term may currently mean in your understanding as the most advanced technology that exists. Both normal computers (in certain situations) and photonic computers have managed to surpass computers that used this technology. You you need an extremely long time for legislation (approximately 2 years according to M. Draghi's report), so, assuming that a normative act will be finalized by the end of 2027, in our opinion, the technology you mentioned will be outdated. And until you achieve something concrete, which will create a certain difference, we believe that the effort you have made will not succeed in achieving its supposed effect. For example, in the case of AI, in the EU there are such systems (phase I), but they cannot be compared with those that exist in other competing states. What we want to say here is that when you will implement what you have legislated, the other states will obtain AI systems much superior to yours. In our opinion, we believe that you should purchase the advanced technology that you want to use (from design, production, to completion) new electrical networks as well as new energy sources, so that the influence that the EU will want to play in this regard will ultimately matter. You take over a problem from the report prepared by M. Draghi, which in our opinion is a completely wrong strategy. Your problem (quantum technology) is related to other problems mentioned in the same report. In this sense, we could say with electrical networks and energy units. The electricity networks that exist in the EU are extremely old, approximately 40 years old, and a large data center can use the electricity used by approximately 9 million people (International Electricity Agency report _ https://www.iea.org/topics/artificial-intelligence ). You should have had a strategic plan by now to solve all the problems mentioned in the Draghi report (in coexistence with each other). You want to use these energy-intensive technologies, but at the same time you want to give up energy that you consider polluting. This will ultimately lead to too much pressure on the price of electricity. You say that "future quantum computers will break current encryption methods, posing a risk to sensitive data and communications". But your ReArm Europe program refers more to the past than to the future (the INCAS project from DARPA https://www.darpa.mil/research/programs/influence-campaign-awareness-and-sensemaking ). Kind regards,
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Response to Implementing Regulation setting out the template for the collection of data under Regulation (EU) 2023/1230

4 May 2024

Hello, Regarding the document presented by you for our consultation, we have several concerns: 1. You say that an expert was consulted in this sense and we do not understand why the Commission did not consult the three European Standardization Organizations (CEN, CENELEC AND ETSI) as well as the consumer protection bodies of the member states. Specifically, you are talking (Regulation 2023/1230 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of June 14, 2023 regarding machines) about the security and health of users of certain machinery, and the entities listed by us above, we consider that they are able to clarify many aspects regarding Regulation 2023/1230; 2. In Annex I you present a table with information to be completed by the member states. In this case, it is not clear to us how this will be achieved concretely. For example, you request to complete information regarding: "Number of accidents at work (fatal/serious/other) per year''. In this case, what does "Number of accidents at work (serious) per year" mean for you and what does "Number of accidents at work (other) per year''. We understand in this way that the same interpretation should exist in all member states to be able to reach a definite conclusion regarding the defects of the machinery in question. Next, who will collect this data (who is responsible from the member state in question) and how this data collection will be carried out. From the above examples, assuming that we are talking about accidents during work and a worker suffered a health impairment (an injury), we can assume that this information will be collected based on a document regulated at national level by the labor inspectorates from that state (if this is the regulation). So, the information that will be presented in this regard will be strictly based on the perception of the person who carries out the investigation of the injury of the worker in question. And this perception of the injury will be realized without a check of the machinery in question at a testing laboratory, so that a concrete analysis of the standards that this car is supposed to respect, will not be realized. What about the situation where the decision to register injuries caused to a worker by a machine is contested in court by the manufacturer/importer of this machine?. A trial in court can be extended over a period of several years. Here we can talk about affecting the health of a single person (individual process) or affecting the health of several people (collective processes). This injury will be registered in the table presented by you or it will be registered only after the judicial process is completed and a decision on this (if a person was injured by a machine breakdown) will be pronounced by the court of judgment? When you decide to withdraw a product from the market, you should base your decision on a set of clear and concrete data (laboratory tests as long as we are talking about machines/equipment) and not assumptions of some people, so that your decision to be able to sit in the case of a trial in front of a court. Next, what should be added to your requests regarding: "Explanations" as well as "Additional relevant information"? As long as you, together with the chosen expert, want to present a table with requests for information, you should specify for each requested information what exactly you want to know. And here we are talking from the concrete description of the damage caused by the malfunction of a machine to national regulations violated, with reference to certain relevant documents (laboratory tests, medical diagnosis etc.). What are the measures you take to avoid multiple recordings of the same situation? In conclusion, we ask you to consult at least the bodies mentioned in point 1 as well as other bodies covered by your table.
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Principia Association demands direct citizen access to platform data

30 May 2023
Topic — This regulation establishes procedures for researchers to access data from online platforms.
Message — The association argues that citizens, not just researchers, should access platform data. They want platform activities to be transparent to civil society rather than states.12
Why — Direct access would allow the association to bypass state-controlled accreditation processes.3
Impact — Member states lose the ability to restrict data access to government-vetted researchers.4
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Asociatia Principia demands stricter cybersecurity standards and EU alerts

14 Dec 2022
Topic — This initiative sets cybersecurity requirements for manufacturers and vendors of connected digital products.
Message — The organization opposes the regulation until quality standards are approved. They request an alert system at the EU level for cyber attacks.12
Why — Strict sanctions would protect the interests of consumers against malicious software.3
Impact — Manufacturers lose the convenience of having their product compliance automatically presumed.4
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Response to Final evaluation of the ‘Active and Assisted Living Joint Research and Development Programme’

23 Jul 2022

According to the data contained in the report "Third edition of the AAL Program impact assessment_Final summary report December 13.2021 (see attachment)", the impact of this program was at the level of 1122 adults (we think that here we are talking about people over 65 ). The population of the EU is 448 million, of which 91 million are people over 65 (according to the data communicated by Eurostat). In your roadmap you state:,,The Active and assisted living joint research and development program (AAL program) aims to create a better quality of life for older people and to strengthen industrial opportunities in the field of healthy aging (...)'' and recently in the case of two regulations/directives regarding the lead exposure limit and the handling of asbestos, you, the Commission, refused the decrease limit of exposure to lead and asbestos, you refused to consider this product as toxic, in contradiction with all the documents and reports submitted for these two legislative initiatives. In this way, we were wondering what kind of "healthy aging" these workers can hope for, when you, the Commission, denied them the right to security and health at work, because simple reason that the financial interests of employers are much more important? When will you start to respect the same art. from the TFEU that you also invoke in this AAL program and to stop treating Union workers as spare parts, which employers can get rid of as they please. In the document "Opinion of the European Committee of the Regions - EU strategic framework on health and safety at work 2021-2027" (2022/C 270/02)'' you say that:,,OSH and a culture of prevention 11. points out that the number of accidents at work has decreased over the last forty years as a result of three factors: scientific and technological improvements, OSH legislation and OSH management systems.''. This is false. Your legislation (mostly) is made up of directives, directives that states avoid implementing because that they do not want to burden their employers with expenses regarding the safety and health of workers. So we end up in the absurd situation where the Directives in this field are implemented at the level of a state more than 10 years after its adoption at the EU level. The only way for an employer to comply with occupational health and safety legislation is through the courts of law. According to the data communicated by Eurostat:,,There were 3 408 fatal accidents at work in the EU during 2019, an increase of 76 deaths compared with the year before'' unlike the United States of America, where 4,764 fatal work injuries were registered in 2020.
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Response to The Aarhus Convention and State Aid measures: analysis and assessment of options

15 Jul 2022

We agree with the Commission's initiative: "The initiative aims to map the implications of the ACCC findings and identify possibilities for improving access to administrative or judicial review for members of the public on Commission State aid decisions that allegedly contravene EU environmental law." We want the Commission to extend the possibility for EU citizens to challenge the Commission's decisions on State aid that contravenes EU law and in other areas, not just the environment. State aid is granted from EU citizens' money, they should have more control / decision-making power over its distribution. This would lead to an increase in citizens' trust in their leaders. We want to see a greater decision-making power of the citizens of the Union regarding the use of the taxes paid by them.
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Response to EU strategic Framework for Global Health

13 Jul 2022

What a beautiful idea, it's like a dream come true. That all 27 EU states have a common health policy. That poor states pay the same price for therapies as richer states, that poorer states no longer face drug shortages, and that poor states have access to revolutionary therapies at the same time as rich EU states (see attachment). beautiful idea. But with this single voice at EU level, it means that entities like EMA and ECDC will gain more power. In this sense, we want sufficient guarantees from the Commission, that these entities (EMA & ECDC) will present sufficient guarantees of impartiality and transparency of the decisions taken (How can you have such big differences between the number of adverse effects in the USA and those in the EU to the covid 19 vaccine. From our personal experience, the adverse effects reported with the covid vaccine 19 have not even been considered by medical staff). In this regard, we would like the Commission to review the following documents: 1. DIRECTIVE 2001/83 / EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 6 November 2001 on the Community code relating to medicinal products for human use; 2. DIRECTIVE 2001/20 / EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 4 April 2001 on the approximation of the laws, regulations and administrative provisions of the Member States relating to the implementation of good clinical practice in the conduct of clinical trials on medicinal products for human use; 3. COMMISSION DIRECTIVE 2003/94 / EC of 8 October 2003 laying down the principles and guidelines of good manufacturing practice in respect of medicinal products for human use and investigational medicinal products for human use; 4. REGULATION (EU) No 658/2014 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 May 2014 on fees payable to the European Medicines Agency for the conduct of pharmacovigilance activities in respect of medicinal products for human use; 5. COMMISSION IMPLEMENTING REGULATION (EU) No 520/2012 of 19 June 2012 on the performance of pharmacovigilance activities provided for in Regulation (EC) No 726/2004 of the European Parliament and of the Council and Directive 2001/83 / EC of the European Parliament and of the Council; 6. REGULATION COMMISSION (EC) No 540/95 of 10 March 1995 laying down the arrangements for reporting suspected unexpected adverse reactions which are not serious, whether arising in the Community or in a third country, to medicinal products for human or veterinary use authorized in accordance with the provisions of Council Regulation (EEC) No 2309/93; 7. REGULATION (EC) No 726/2004 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 31 March 2004 laying down Community procedures for the authorization and supervision of medicinal products for human and veterinary use and establishing a European Medicines Agency. How can you say NO to the 17 goals of the UN? We applaud the Commission's decision for such an initiative, but you need to work much better on the way you present it. You cannot go so far as to reject such an important initiative simply because EU citizens have not understood the aims of the initiative.
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Response to Evaluation of the procedural rules for the implementation of Articles 101 and 102 TFEU

6 Jul 2022

REGULATION (EC) NO. 1/2003 OF THE COUNCIL of 16 December 2002 on the implementation of the rules on competition laid down in Art. 81 and 82 of the Treaty: “(1) In order to establish a system to ensure that conc urgency in the common market ''. And what is this system that does not distort competition? The sanctioning system put in place? When you take out of the market a big mobile phone manufacturer on the grounds that through these devices it carries out espionage activities, what happens to this market? The other competitors in the same market end up making huge profits on the backs of consumers. Consumers become prisoners in this market for the simple reason that they are deprived of their freedom of choice. What was the effectiveness of the sanctions given to the companies? Did they change their behavior and did the consumers prosper or did the other players in the market prosper? Are these regulations for the prosperity of consumers or for the prosperity of other market players? Every time you sanction an enterprise, this sanction is turned against consumers. In a certain period of time you sanctioned several banks for cartel-type agreements, to understand that now such agreements no longer exist? The losses recorded by these banks through these sanctions have turned into abusive clauses in credit agreements with consumers. That is, the losses recorded from the fines applied by you, were recovered through new abuses against consumers. ,, The European Commission today fined, in four separate decisions, consumer electronics manufacturers Asus, Denon & Marantz, Philips and Pioneer for imposing fixed or minimum resale prices on their online retailers in breach of EU competition rules. In particular, Asus, headquartered in Taiwan, monitored the resale price of retailers for certain computer hardware and electronics products such as notebooks and displays. The conduct of Asus related to two Member States (Germany and France) and took place between 2011 and 2014. Asus intervened with retailers selling those products below the resale prices recommended by Asus and requested price increases. (https://ec.europa.eu/commission/presscorner/detail/en/IP_18_4601) '' What about the other 25 Union markets? Or in the other 25 EU markets, does this manufacturer comply with antitrust rules? Who won from the Asus sanction? Consumers or other large producers in the market? Who is the real beneficiary of this legislation? How come none of these notebook manufacturers offer a fair balance between the technical features of the product and the price they ask for? The consumer is obliged to pay a lot on configurations of the product you do not need, because not all manufacturers offer other fair alternatives between these features and price. The consumer is forced to pay a lot of money on configurations of the product that he does not need, for the simple reason that these large manufacturers do not offer other alternatives.
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Asociatia Principia slams high costs of European green transition

6 Jul 2022
Topic — This report evaluates Member State progress toward reaching 2025 and 2035 waste targets.
Message — The association argues taxpayers are unfairly blamed for waste problems created by EU laws. They challenge the polluter-pays principle regarding fossil fuels and high green energy costs.123
Why — This would protect consumers from the financial burden of new environmental taxes and mandates.4
Impact — Environmental interests are harmed if the transition to sustainable energy is delayed or abandoned.5
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Response to Brain drain communication

9 Apr 2022

We are extremely pleased with your document: "COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS (for a young mind that do not know your consultations), such a document would be useful for propaganda. Why do you say that you need better legislation in this document? You remember the protection of workers from exposure to asbestos, but what about the exposure of workers to lead? Or have you forgotten about this legislation? What about the Precautionary Principle? In order to have a chance of starting a family, as Professor Samuel Norman (Morgan Freeman) said in the movie Lucy (2014), the habitat (EU) must meet 2 simple conditions: 1. Security; 2. Abundant food. Do you think that at this present time, the EU is a good habitat for starting a family? In Romania, there are more than 200,000 phd degrees, we do not know how many are in the Union, but according to your recommendation, "COMMISSION RECOMMENDATION of 11 March 2005 on the European Charter for Researchers and on a Code of Conduct for the Recruitment of Researchers '', these phd degrees should bring about an increase in the living standards of the citizens of this Union. How many phd degrees can you name that have raised your standard of living? We all pay for these phd. We consider your predictions regarding the brain drain in Romania to be optimistic. A patient in Romania has to wait more than 900 days for a new medicine (https://efpia.eu/media/636821/efpia-patients-wait-indicator-final.pdf), compared to another EU citizen, who waits about 130 days. Medicine is the only discipline (to our knowledge) where the EU Court of Justice accepts the existence of the expression "not knowing". Why is such an expression acceptable when we talk about a person's life? The Precautionary Principle says that we must put the life of a human being above financial interests (what other legislation do you need !!!!!, this principle it is not clear enough for you). We have contact lenses that use augmented reality, but we are not able to prevent and treat a stroke. Why? Isn't it financially viable for pharmaceutical companies? Several car manufacturers have been sanctioned for not wanting to advance technologically (dieselgate), how come such a problem does not arise in the case of pharmaceutical companies? In China, there is an explosion of the Covid 19 pandemic, in the EU this pandemic is not seen. If several EU countries have found that a 4-day work week of 8 hours (not 10 hours) is good for workers' health, why not impose this work schedule at EU level? Do you know how many billion of euros an EU member state allocates to the mental health problems of its citizens? About 7 billion euros. In what kind of financial reasoning does such an expense not affect the financial interests of a company (as we see this is the only thing that will concern you)?
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Response to European Media Freedom Act

22 Mar 2022

And what are this concrete steps that will EU take to ensure the protection of journalists? It is not clear what these measures are that you are going to applied to ensure the safety of these persons. In the Commission Recommendation from 16.9.2021 on ensuring the protection, safety and capacity of journalists, and a to the other media professionals in the EU '' you speak about the cases of several journalists who are killed as a result of their investigations, you recommend compliance with EU law and the involvement of police authorities. But these attacks took place on these journalists during the existence of these investigative authorities and during the existence of EU legislation, and these things failed to save their lives. So in the end your recommendation is that everyone is responsible for. his life, and you, the Commission, have the single role of observer in this whole situation. But these attacks took place on these journalists during the existence of these investigative authorities and during the existence of EU legislation, and these things failed to save their lives. You continue talking in this "Recommendation" about the phenomenon of corruption, but without taking concrete measures to fight it. What about magistrates, anti-corruption prosecutors, anti-corruption NGOs? What do you recommend to them? To complain to other corrupt institutions? In Romania, whenever an anti-corruption institution appeared, it was quickly abolished by the political factor. Why are you still pumping European funds into these deeply corrupt states? Don't you understand that with these European funds, will support the corruption in those states? We have participate in your public consultations since 2018, and till today, we have not seen a strategy by the Commission to seriously fight corruption in the EU. You continue to condemn misinformation and manipulation in the media. These two elements appear in the absence of information and certainty. Many television stations present their political analysis in english, so their message reaches a much larger audience than local television. We also see on these televisions that delicate topics are being discussed, which the EU refuses to discuss on his television. Why do you refuse to discuss such delicate topics (the Ukrainian war and the Covid19 Pandemic)? Are you afraid of the answers that would be heard on Union television? While in several EU states there have been demonstrations against anti-COVID19 restrictions, a happy Europe is on Union television. In the case of a hybrid war, the minds of the citizens are seen as valuable elements, why don't you do these things? On these foreign television stations, we find out that the claims of the president of the Russian federation are true, and a well-known political analyst from a well-known Western state, manages to find positive effects of the war. We are still amazed that on that television, a representative of an authoritarian state ends up invoking fundamental human rights and freedoms and condemning any form of war. Is this the EU? An EU too scared to discuss delicate issues and fight corruption?
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Response to Protection of workers health from risks related to exposure to lead and di-isocyanates

13 Mar 2022

We do not agree with this statement, it is an unfounded one: “Member States are allowed to establish themselves own limit values, in compliance with these minimum conditions of protection ''. We do not understand why states should set their own lead exposure limits. Have states found that they have workers who are more resilient to lead? No, in reality we run into some economic interests of some companies. This freedom to set one's own exposure limits will, in some cases, lead to abuse and ill-treatment of workers. Why shouldn't workers set these exposure limits, because in the end, their health is at stake? Do you see this legislative chaos in US regulations as well (https://www.osha.gov/laws-regs/preambles#lead)? The Commission should set the lowest exposure limits for all Member States and not leave it to their discretion. In the evaluation documents for COVID19 vaccines, PRAC did not find any difference between the citizens of the Member States. Then why are you doing this?
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Response to Protection of workers from risks related to exposure to asbestos at work

11 Mar 2022

How hard is it for you to read your own documents? In the Report of 30.01.2013 on asbestos related occupational health threats and prospects for abolishing all existing asbestos (2012/2065 (INI) https://www.europarl.europa.eu/doceo/document/A-7-2013-0025_EN.html), rapporteur mr. Stephen Hughes, identifies as well as possible all (approximately) the problems that workers face. As recommended in this report, as you are proposing to lower the exposure limit value, we consider it is good idea, but not a solution to the problem. At the heart of your strategy are small and medium-sized enterprises that carry out a predominant activity in the field of construction. How do you think these companies will find this exposure limit value? Do you see the owners of these companies walking around with devices that measure this exposure limit value? You have to understand that these companies mainly use unregistered cross-border labor, which is not professionally trained to know in detail how they should work with asbestos. For these small companies, in order to carry out a proper professional training of these cross-border workers, they should pay thousands of euros only for the translation of occupational safety and health documents, in the native language of these workers. In addition to these costs, the costs of personal protective equipment must also be taken into account. The COVID19 pandemic has shown us that this personal protective equipment can also be easily counterfeited, so it is necessary for this small company to use qualified personnel in the field of occupational safety and health, who can distinguish a false PPE from a compliant one. These small businesses, in order to reduce costs and obtain those orders, mainly use untrained workers in the field of occupational health and security, same PPE which is used by many people, and the way of disposing of asbestos-containing products, pollutes even more the environment. Our proposal is that asbestos be considered a hazardous waste (as suggested in the above Report) and that its handling, disposal, be performed only by professional services established in this regard (as is done in the case of mercury ). In this way you will be able to really reduce the number of people who get cancer. It is extremely important that workers working with asbestos-containing materials be professionally trained in this regard, and have the appropriate professional experience to properly treat this hazardous waste. In the old Directive as well as in the new proposal for a directive, use two different expressions: work equipment and personal protective equipment. You think that these 2 expressions are similar, but in reality they are completely different. In the Directive you should only use the term disposable PPE. Directive 89/391 / EEC uses the expression "adaptation to technological progress" (Article 6, paragraph 2 letter e), an expression which many employers do not want to translate into reality, so that it is better protect workers in the activities they carry out. Asbestos is also present in old electrical circuits. We hope that this new Directive will not have the same fate as the Seveso I and Seveso II Directives (understand through Seveso III Directive that Seveso I and Seveso II were wrong).
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Asociatia Principia urges impact studies and focus on domestic fuels

20 Feb 2022
Topic — This consultation examines how green and digital transitions can mutually reinforce each other.
Message — The association requests impact assessments for all Green Deal initiatives and regulations instead of directives. They advocate for domestic resources and alternative fuels like biodiesel to maintain affordability and jobs.123
Why — Domestic biofuels would prevent price hikes for citizens and preserve European transport jobs.45
Impact — Foreign manufacturers and electric vehicle proponents lose out to traditional internal combustion and domestic biofuels.67
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Asociatia Principia urges forest conservation over Green Deal costs

16 Feb 2022
Topic — This consultation addresses a regulatory framework for certifying sustainable carbon removals.
Message — The organization calls for stopping deforestation and planting trees instead of costly regulations. They argue that the Green Deal imposes unrealistic financial burdens on young entrepreneurs.12
Why — Small businesses would avoid bankruptcy and the high costs of mandated technology.3
Impact — Consumers are harmed by higher prices as entrepreneurs pass on regulatory costs.4
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Asociatia Principia calls for draft regulation on electronics chemicals

15 Feb 2022
Topic — This consultation reviews EU rules on hazardous substances in electrical and electronic equipment.
Message — The association requests a draft regulation to review the Commission's specific solutions. They want to see concrete terms for addressing the identified environmental and health issues.12
Why — Accessing the draft allows the organization to better advocate for citizen and consumer rights.3
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Asociatia Principia urges support for biofuels and engine recycling

14 Feb 2022
Topic — The Commission is reviewing CO2 standards for heavy-duty vehicles to support climate neutrality goals.
Message — The association calls for alternative fuel development and converting polluting engines into non-polluting ones. They seek clarity on economic impacts and costs borne by carriers and consumers.123
Why — This would protect the industry and citizens from the burden of rising fuel prices.4
Impact — Carriers and consumers suffer from higher costs that could lead to business closures.5
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Asociatia Principia demands carbon footprint and chemical safety labels

23 Jan 2022
Topic — EU review of energy labelling and ecodesign requirements for household tumble dryers.
Message — The group calls for labels to include CO2 footprints and hazardous substance details. They want the entire production process evaluated for durability and high recyclability.1234
Why — This would help the association ensure products are healthy for consumers and environment.5
Impact — Manufacturers would lose the ability to hide information about the chemicals they use.6
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Response to EU Competition law – revision of the market definition notice

21 Jan 2022

In your evaluation document ,,The supporting study that accompanies the Communication from the Commission on evaluation defining the relevant market for the purposes of Community competition law Competition '' you do not talk about 2 basic questions/problems: 1. how will you ensure greater consumer protection against cartel-type anti-competitive agreements? and 2. how will you ensure better protection for small businesses against dumping prices managed by companies outside of the Union?
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Asociatia Principia warns against EU solar reliance on China

20 Jan 2022
Topic — This consultation seeks views on accelerating solar energy deployment and competitiveness.
Message — The association asks the Union to find a strategy using its own resources. They claim the current strategy creates jobs in countries outside the Union.12
Why — Prioritizing European resources would ensure industrial benefits and jobs remain within the Union.3
Impact — Chinese manufacturers would lose the market dominance they currently enjoy in Europe.4
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Asociatia Principia warns Green Pact destroys Romanian jobs and economy

20 Jan 2022
Topic — EU guidance for accelerating renewable energy permitting and power purchase agreements.
Message — The association demands that the Union prioritize job security and sustainable internal resources. They urge immediate action to stop the ongoing deterioration of the European economy.12
Why — Preventing further industrial closures would protect citizens from unemployment and massive energy bills.34
Impact — Environmental groups lose as the transition away from polluting coal mines is halted.5
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Response to Personal data protection by Union institutions, bodies, offices and agencies–report on EU data protection Regulation

13 Jan 2022

We welcome the Commission's decision to evaluate the provisions of Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. We would like to make the following remarks on this subject: I. We do not agree with the prohibition of the access to a court of law of an NGO that does not carry out an obvious activity in the field regulated by the present Regulation 679/2016. This provision is found both in par. 142 and in art. 80 of this Regulation. ,,(142) Where a data subject considers that his or her rights under this Regulation are infringed, he or she should have the right to mandate a not-for-profit body, organization or association which is constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest and is active in the field of the protection of personal data (...) .; Article 80 Representation of data subjects 1.The data subject shall have the right to mandate a not-for-profit body, organization or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects' rights and freedoms with regard to the protection of their personal data (....) ''. We do not understand the purpose of this limitation of access to a court. How can an NGO prove to be relevant in the field of data protection? What is the significance of this provision "active in the field of data protection"? These provisions are unclear and leave room for interpretation, limiting the right of access of NGO to court of law (Article 81, letter E of the EU Treaty and the European Convention on Human Rights). II. We note that an extremely important food safety alert system is being set up in the Union: the Rapid Alert System for Food and Feed. This program provides continuous 24/7 information to all Member States on issues identified in an EU Member State. We have many situations in which the Union authorities sanction an IT giant for breaching the provisions of Regulation 679/2016 in one Member State, but not for the same breaches in the other states of the Union. It is not clear to us why the breaches of this IT giant are not sanctioned in the other Member States as soon as possible. In the end we are talking about the data stored/collected by cookies (for ex.), a situation that requires nothing more than the use of special computer programs to prove these violations. Of course, these violations are made public, but the national authorities refuse to sanction these IT giants for the same violations sanctioned in another EU member state. This means that the citizens of the Union have an unjustified burden to address in the first phase, the national authorities, and then with their own financial resources to open a lawsuit against these IT giants. A completely disarming process for the citizens of the Union. They do not have the necessary financial resources to support such extremely costly and time-consuming legal proceedings. What is the meaning of a decision in the courts after a period of 10 years (where we have several levels of justice)? Doesn't it matter if the court rules in favor of the citizens of the Union after 10 years (where we have several levels of justice and we are talking about class actions)? This method of delaying the judicial process is well known by these giants, so as to invalidate the effects of Regulation 679/2016. For Regulation 679/2016 to produce the same effects for all citizens of the Union at the same time, we consider that it is of real interest to implement an alert system as in this case Rapid Alert System for Food and Feed.
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Response to Promoting sustainability in consumer after-sales

12 Jan 2022

We welcome the idea of Commission to promote sustainable products, otherwise we consider that the ideas of the Commission are contradictory. It is not clear why we have an idea of Commission in which we want to have durable products, in this sense it means that they rarely reach the repair and ideas in which the consumer is entitled to replace the defective product with a new one with the idea of repair his. Why would a consumer choose this path or why this idea would be in the interest of the consumer? In case the smartphone breaks down, it makes the consumer wait for a no. weeks until this product is repaired? What should the consumer do all this time? The consumer will be obliged in this case to adopt a behavior contrary to the Commission's objectives to ensure a sustainable consumption, by purchasing a new smartphone. What should a consumer do if a refrigerator or washing machine fails? Does the Commission provide a new washing machine for washing? Does the Commission compensate him if all the food in his fridge spoils? A sustainable product will cost a consumer more, and his choice will depend on the price charged by the manufacturer. What is stopping consumers from buying more sustainable products today? Why don't all consumers use smartphones from a particular manufacturer that offer security updates for several years? Why don't all consumers buy a certain brand of cars that have a high degree of durability or for washing machines? How does the Commission intend to make these products accessible to all consumers? Why in some Member States of the Union where the minimum wage is high, some producers practice low prices for sustainable products and in other Member States where the minimum wage is so low, these products have such high prices? If we talk about a circular economy, we can say that Romania is the champion of such a thing. An ordinary Romanian cannot afford to buy a new durable car, so the car fleet of this country is made up of 90% of used cars. Some smartphone manufacturers offer in the same member states of the union, where their citizens have a high minimum wage, attractive prices for trade-in or buy-back situations, again in Romania these services do not exist, and if they exist, their offers are completely discouraging. We have many situations in which consumers complain about the poor quality of the products offered to them. And in the event that they revolt through the courts of law or national bodies, the justice due to these consumers is denied by these Union authorities. What is the point of creating an entire legislature on sustainable products, as long as these rights remain as fundamental rights and freedoms of citizens, strictly illusions. Any task that the Commission will place on producers will turn into a new cost that consumers will have to bear. Most consumers cannot afford sustainable products because they are too expensive for their income. The Union market should have been self-regulating by harassing these producers, who have repeatedly misled consumers' confidence in their products. And when these Union authorities impose sanctions against their producers, other entities of the same Union take measures to rescue their producers. That is why we have poor quality products, because this contempt for consumer rights is not sanctioned by the Union authorities. Any loss, a new cost incurred by their producers, is automatically moved behind the consumers. And these consumers are obliged (according to the legislation - in case their rights are violated) to address the producer, then the Union authority and then the court of law. Who compensates this consumer for all this lost time, accumulated stress, unrealized benefit, etc.? Consumer rights are negligible and the measures against them are dissuasive, to make them pay out from their own pocket the damage inflicted.
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Response to Extension of scope of procedures for determination of CO2 emissions of heavy-duty vehicles

16 Oct 2021

We do not agree with the Commission's view on reducing CO2 emissions. Whether we are talking about heavy vehicles or passenger vehicles. The Commission stipulates that the only way to reduce CO2 emissions will be achieved strictly by using hybrid and electric vehicles, while disregarding biodiesel fuel. On the one hand, this vision of the Commission is in direct conflict with, on the other hand, the other regulation by which the Commission itself wants to focus on the recycling of car parts (here we are talking about hybrid cars that involve more parts) and for a longer period and long use. It is not clear how both hybrid and electric vehicles can fit into this vision. Whether we are talking about hybrid or electric vehicles, both are costs that will also move in the pockets of citizens, instead biodiesel will do nothing but recycle old engines, old kitchen oil as it will turn these polluted vehicles into green vehicles at no additional cost for both buyers and passengers / users of their services. Everything the Commission needs to turn old polluted vehicles into unpolluted vehicles is already in the Member States of the Union. Through this measure the Union will create new jobs and reduce pollution in a way that is profitable for all citizens of the Union. To return to a very real example from everyday life, we ask ourselves in this way how well the Commission's CO2 reduction policy works so far? In poorer states, hybrid and electric vehicles are extremely expensive and if they are bought (electric) there is no infrastructure for them (charging stations). In reality, the Commission's policy of reducing CO2 emissions has had the exact opposite effect. Car manufacturers have been forced to invest in far too expensive technologies that are accessible only to certain citizens of the Union (as if pollution were in one state as in a glass dome), and other citizens have been forced to continue to use polluting vehicles. So instead of having more Euro 6 vehicles, we have increased the number of Euro 4 and Euro 5 vehicles (for the sake of hybrid and electric ones) and the biodiesel producers complain that they have nowhere to sell it. According to statistical data from Romania, in this country 98% of small vehicles are with internal combustion engines (About 80% of these are older than 10 years of use) and in trucks, 90% are with diesel (at early 2021). A relevant document in this regard is the one made by the European Federation for Transport and Environment AISBL on how polluted hybrid vehicles really are: ,, https: //www.transportenvironment.org/wp-content/uploads/2021/07 /2020_11_Plug-in_hybrids_report_final.pdf '' Regarding electric vehicles and what their emissions are, we can say that it is another false vision. The Commission sees strictly from the perspective of the car's fuel / electric battery and does not see how this electricity is produced. How can it be said that these vehicles are non-polluting as long as the production of electricity they use is polluting. In an article in The Wall Street Journal, Akio Toyoda says converting entirely to EVs could cost hundreds of billions of dollars and make cars unaffordable for average people. (https://www.wsj.com/articles/toyotas-chief-says-electric-vehicles-are-overhyped-11608196665)
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