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BSH Hausgeräte GmbH

BSH

BSH Hausgeräte GmbH is one of the world’s leading companies in its industry and the largest home appliance manufacturer in Europe (per value).

Lobbying Activity

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and APPLiA (Home Appliance Europe) and Electrolux Home Products Europe

10 Feb 2025 · Circular economy

Response to Single Market Strategy 2025

31 Jan 2025

Key Messages: Product requirements should be set at EU level to protect consumers and the environment in the same way across the Union, rather than creating national regulations or using the leeway provided in EU directives (for examples see also the list mentioned by APPLiA Home Appliances Europe). Effective market surveillance is key for a fair, competitive market. Only clear, simple laws can effectively be enforced, and without enforcement there is no competitiveness. For more details see attachment
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

BSH views on the intention of the EU Commission to adopt a delegated act laying down rules on the operation of DPP service providers BSH actively supports regulations that encourage innovation, sustainability, and fair competition. We recognise the potential of the Digital Product Passport (DPP) to improve product sustainability but stress the need for smart implementation. This means minimising burdens on businesses and ensuring the DPP truly contributes to a circular economy as well as provides added value. We therefore appreciate the possibility to provide our input in the Evaluation Digital product passport rules for service providers. BSH has noted that the requirement for a backup copy was integrated in the legislation framework at a late stage. Consequently, the impact of such a new obligation was not considered sufficiently. It is fair to say that this new aspect creates unjustified burden for economic operators and is not proportional to meet the strategic objectives of the ESPR. We urgently call the EU Commission to re-consider, together with other EU institutions, the need for stipulating a DPP backup copy. It is of high concern that a backup copy would result in a third point of truth besides the registry and original DPP as such. It is of utmost importance for European enterprises, especially SMEs, to avoid double work. On top, a legally compliant market access would depend on the availability of service providers and their pricing system. Especially in current times an increasing time to market and rising cost would intensify the economic crisis of European business. It is justified to repeat and remind the EU Commission that one of the most important duties is to support growth in the European Union and not the opposite. As mentioned, in the political context, the new requirement has the potential to create a new niche market for service providers. But this possibility must be considered as minor in comparison to the high risk for European companies. Furthermore, some other aspects are crucial as well: Service providers will serve for many economic operators. They potentially will be a target for cybercrime and attacks. We remind, this was an argument against a central DPP database and a key aspect for the decentralised data system. It is uncertain whether market surveillance authorities will be able to check and compare the decentralised original DPP data with the content of a backup copy. It must be expected that, if an economic operator goes bankrupt, the service provider will not be paid anymore and stops his service. Or an economic operator will have to pay a multi-year flat rate in advance. This pricing option is questionable. If a service provider potentially goes into insolvency the backup data will not be available anymore. If the need for a backup copy remains mandatory there is the risk that economic operators lose legally compliant market access overnight, depending on third-party companies. The consideration of certification schemes for establishing the proposed DPP backup copy system has been observed with great concern. Such extensive measures would require this certification to be based on accreditation. This could potentially lead to another instance of overregulation within Europe. As a compromise and the only viable way forward, we suggest making the backup copy requirements a voluntary option. This would enable SMEs to store and maintain DPP data without the need to operate their own servers. To clarify, our proposal does not advocate for a decentralized DPP data system with a voluntary backup copy, but rather the option to utilize a DPP data service provider instead of internal data hosting. Ultimately, rules and regulations are only as effective as their enforcement. If the new obligations cannot be adequately monitored, it will result in a decreased competitiveness for businesses that act responsibly. We urge you to reconsider.
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