OpenLobby.EU
Explore

Brussels Consulting Kft.

Strategic consulting and client representation activities, provision of legal and economic analysis concerning EU and neighbouring markets.

Lobbying Activity

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders) and Lutron Electronics Co., Inc.

23 Jan 2023 · Right to repair, Artificial intelligence

Response to Promoting sustainability in consumer after-sales

4 Apr 2022

Dear Madam/Sir: Brussels Consulting Kft. and its clients believe that the “Sustainable consumption of goods” initiative and the right of consumers to repair are important steps for increasing the circularity of electronics and electronic equipments. We would like to point out that a key concept to bear in mind is that of the “smallest unit of practical repair”. We support that a for example, a luminaire should be repairable by having common failure components like electronic drivers and light source being replaceable, but we would be uncomfortable if those reparability requirements were to be applied also to those small electronic driver and light source units themselves. Restoration of those small devices introduces increased several risk including electrical safety risk as well as jeopardising device performance. It would also be inappropriate that the legal guarantee would start again for an entire product even if only a component in that product had been repaired. The legal guarantee should start again only for the replaced component. If a repair is made by a third party, this should not affect the original manufacturer’s liability and instead imply the liability of the third-party repairer. In addition, guaranteeing to repair products which have been mishandled is neither practical nor feasible business-wise. We seek for clarification about a defect occurring after 2 years. A defect after the guarantee period should be covered by a (paid for) extended warranty. Finally, we ask for coordination with existing regulations on unfair consumer practices and the present proposal, and the coordinated and timely harmonisation between national rules. Thank you.
Read full response

Response to EU strategy for sustainable textiles

2 Feb 2021

Madam/Sir, In the following we focus on - the need for a levelled regulation, - proportionate legislative practice and - a coherent attitude to (and imbedding of) the so-called full-life cycle approach of products and services. Textiles are used in a great variety of different product types and over a broad range of services. Confining an EU sustainable textile strategy to simply all and any kinds of textile products and services may result in excessive regulation, and could be missing otherwise appropriate targets. Double or triple regulation of the same subject matter should be avoided. While Brussels Consulting and its clients are mindful of the environment and hence fully support the Commission’s ambitions of removing hazardous substances from products wherever possible, we also ask that chemical restrictions are introduced in the better targeted and suited legislations. In this case, as part of the existing regulatory means of REACH and RoHS which are traditionally well fit to manage hazardous substance (also in relation to fabrics). Introducing similar concepts under the textiles strategy could result in a disproportionate legislative measure (over-legislation). We support the idea of assessment of life-cycle of products and services (such as under the taxonomy regulation, building sustainability measures and sustainable products initiatives, batteries strategy, etc.). It is of utmost importance that products do not get singled out at their face value, instead a fully substantiated life-cycle approach is taken, analysing the overall contribution that a textile-based product or service may offer to the users, including the natural environment itself. Such appraisals should indeed be streamlined across the different legislative tools (as cited above) in order to maximize user/consumer understanding, applicability, take-up and fertilize the terrain for a long-standing behavioural change of consumers. Without such harmonized approach the effects of the various regulatory tools will be difficult to assess and consequently adjust when and where needed. Finally, we advocate for a much wider dissemination of such ideas at user/consumer-level, for no matter what business entities are required to do, if there is no consumer buy-in and the demand-side is not adjusted, mandatory regulatory measures become soon obsolete. We are available to support the planning process further if needed.
Read full response