Der Verband für Medien- und Veranstaltungstechnik
VPLT
The German Entertainment Technology Association – VPLT represents the interests of the players in the field of media and event technology, shapes the future of this creative industry and thereby establishes valuable networks with representatives of the media, politics, culture and educational institutions.
ID: 819880923782-49
Lobbying Activity
Response to Digital Product Passport (DPP) service providers
10 Dec 2024
The German Entertainment Technology Association (VPLT) would like to thank the Commission for the opportunity to give feedback on the rules for DPP service providers storing DPP data for economic operators and/or mandatory backup copies. VPLT represents the interests of different economic players in the event industry such as manufacturers, service providers, operators, dealers, retailers and distributors. We support the introduction of a Digital Product Passport which will provide product transparency and help implement the EU Green Deal. The shift to sustainable business models comes along with new requirements for companies such as corporate sustainability reporting and corporate due diligence duties, as well as the development of environmental footprints and circular economy models. Information provided through DPPs is key in this context, as relevant product information can be shared among the supply chain as well as with public authorities and consumers. VPLT is aware of the potential of the digital product passport in other regulatory contexts such as in customs as the data stored could be accessed by customs services and in this way facilitate cross-border trade for European-based manufacturers, such as proposed in Regulation (EU) 2024/1781 on the EPRS. The following principles seem of importance for us when setting up a functioning Digital Product Passport by service providers: 1. A harmonized and mandatory certification process for service providers is to be set up to guarantee compliance and interoperability of the data between different providers. Self-declarations are not sufficient as the impact of wrongful conduct or unacceptable business practices can lead to huge damages for manufacturers storing confidential data in the DPP. 2. Ownership of the data must remain with the manufacturers using the DPP. At any point, manufacturers should be allowed to change service providers if they deem it necessary. 3. Interoperability of data is key to allow comparability of products. 4. Access to DPP data should remain free of charge for both end-users and those operators and service providers that collect information from DPPs on sustainability criteria for their clients to measure the environmental impact of a product or service. 5. The web portal of the Commission should function as a central entry-point and one stop shop to collect data about all decentralised service providers and allow end-users, other market players and authorities to easily access information stored in the DPPs. 6. Specifically for SMEs it is of high importance to reduce administrative burdens when setting up their DPPs. Costs must remain accessible for SMEs so that they remain competitive on the market. In addition and in line with the Think Small First principle of the Commission, the effect that DPPs have on SMEs must be examined beforehand to mitigate potential financial and administrative impacts. In this context, appropriate financial support is to be put in place by Member States and the Commission to help SMEs to comply with ESPR rules and the setting up of DPPs.
Read full response6 Oct 2023
VPLT · The German Entertainment Technology Association - We strongly support the proposed amendment. The amendment would change the scope of application of the sustainability reporting requirements under the Accounting Directive as amended by Directive (EU) 2022/2464 (CSRD). We also support the initiative of the German Government to increase the threshold from 250 to 500 employees. While we agree in principle with the requirements of the Directive (EU) 2022/2464 (CSRD) and strongly support the objectives of the Green Deal, we also understand the challenges for micro, small and medium-sized undertakings, which make up the great majority of our membership. After the major disruptions due to the pandemic, all companies in our sector need more time to adjust to the many regulations and directives that are a part of the transition to a sustainable economy in the European Union. We are also concerned that many requirements for large undertakings, such as those in the Due Diligence Directive, despite the exemptions therein, will have a "trickle-down" effect on SME's. They simply do not have the resources to be able to comply. In order to generate more acceptance for the transition, our sector also needs more support to be able to discuss and implement the necessary structural changes needed in the market. We support those companies who are currently able to meet the requirements of CSRD and CSDDD. They should certainly move forward as planned and be trailblazers on the urgently necessary path to sustainability. This will in any case become an important part of product and service quality and therefore, an important marketing tool in the future. We repeat our proposition and offer to assist the Commission in establishing PEFCR and OEFSR for our sector as demonstrated in the pilot phase and would strongly support a mandate on the use of the Environmental Footprint methods to measure and communicate the life cycle environmental performance of products and organizations in the entertainment technology sector as laid out in the Commission Recommendation of 16.12.2021.
Read full responseResponse to Environmental claims based on environmental footprint methods
21 Jul 2023
The German Entertainment Technology Association strongly supports European benchmarks and therefore a level playing field in regard to claims of sustainable products, services and organizations. We would greatly appreciate working with the EU Commission on creating valid PEFCR and OEFSR for our sector through the processes described in the methods to measure and communicate the life cycle environmental performance of products and organizations (LCA) for the event and live-performance industries as carried out in the Pilot Phase from 2013 to 2018. We also support the Commission Recommendation of 16.12.2021 and would suggest a mandate to further limit the increasing number of certifications and eco-labels that are disrupting fair competition and prohibiting a viable path to achieving the goals of the Green Deal. We need guidelines and methods that are recognized in all of the Member States. We would be willing to work in a Technical Secretariat with other associations from our sector as described in the LCA Pilot Phase to define these benchmarks for our industry.
Read full responseResponse to European Sustainability Reporting Standards
7 Jul 2023
We generally support the EU Commission in their path to attaining the goals as stated in the "Green Deal". We are however, concerned that the process for implementing ESRS is moving too quickly. There are still many details to define. Almost all of our members are SMEs. It is at the moment not clear that there will be no cascade effects for non-reporting companies, since reporting entities will require information from their business partners. There should be simplified methods and exemptions for SMEs. We support therefore the efforts of EFRAG to establish simplified reporting standards will be developed for SMEs to use on a voluntary basis in order to enable SMEs to meet information demands from large company clients and banks, while facilitating their contribution to and participation in the transition to a sustainable economy. Further complicated bureaucratic requirements for smaller companies will certainly limit their opportunities to enable the transformation to a sustainable economy. We need less bureaucracy and more innovation for efficiency, consistency and sufficiency. We are also concerned about the quality of the standards used to measure sustainability. These are elemental to guarantee fair competition within and outside the EU. We therefore once again urge the Commission to establish a framework as described in the "pilot phase" for European PEFCR and OEFSR that are binding for all EU Member States. (see: COMMISSION RECOMMENDATION of 16.12.2021 on the use of the Environmental Footprint methods to measure and communicate the life cycle environmental performance of products and organisations. We would gladly participate with other European Business Associations in our sector in a Technical Committee to set these standards for our industry.
Read full responseResponse to Single Market Emergency Instrument (SMEI)
10 May 2022
The VPLT, the German Entertainment Technology Association, supports the positions as presented to the Commission in the commentary from PEARLE* - Live Performance Europe. For the event and live performance sectors, a Single Market Emergency Instrument should always ensure the circulation of goods and people, access to vital supplies and services at all times – while respecting the health and safety of all those involved. A more forceful and coordinated approach through EU regulation would have facilitated the containment of the virus, as it neither had knowledge of the 27 different concepts and procedures that were created to curtail it nor did it relate to the borders of the Member States – although many governments acted as though the virus would respect "their" national entities and adhere to "their" specific regulations. For example, the Digital Covid Certificate, although late in its implementation (March 29021), proved to be an effective and important EU-wide coordinated approach to the crisis.
The lack of resilient systems to support the self-employed has created a skilled worker shortage that will have a very negative affect on our sector and its ability to create economic and artistic value for many years to come. Many of the free-lancers who worked in our industry were forced to leave, as there was not sufficient economic support from their governments during the crisis. In Germany, around 63% of the people working in the event and live performance sectors were registered in 2021 as sole proprietorships (see: Zähldazu-study). The state aide offered through the temporary framework – at least in Germany – did not reach these self-employed in our sector.
Read full responseResponse to Review of ecodesign requirements for lighting products
16 Oct 2018
The VPLT, the German Entertainment Technology Association, supports the efforts of the EU-Commission towards making the European economy more climate-friendly and less energy-consuming. As a member of the task force “stage lighting and film/TV production” we were grateful to be able to assist the DG-Energy and DG-Environment towards understanding our concerns and specific sector specifications during the consultation period for the Ecodesign Requirements. Many of our concerns have been resolved, but there are still four very important issues we must address. They can be found in detail in the document attached with this feedback: stage and studio lighting amendments ecodesign proposal_15102018.pdf.
The amendment in regard to the “standby mode and power” is of the greatest importance for our sector. Many of the luminaires used in theatre, studio and live-performance environments will not be able to achieve the 0,5W standby power stated in the regulation. However, since these luminaires are actually never in “standby-mode”, but rather, are either “on” = albeit waiting for high speed control networks to signal them where to put their light, or they are “off”. The power used is only used for a specific purpose in specific productions and for very short periods of time. In our opinion, the definition of “standby mode” {Annex I; (16)} in the Regulation does not take into consideration the specific requirements for luminaires used in our sector, which is why we are petitioning for the exemption. Our position on adding white light sources for specific needs addresses very specific technical issues in our industry. Our proposal in regard to colour-tuneable light sources and the definition of green has been formulated by experts from the research and development departments of major stage-lighting manufacturers and represents a position based on the state of the available technology at the present time.
The additional lamp bases that we propose for exemption reflect our efforts to include all of the stakeholders – including the film industry – in our joint position.
We would like to remind the Commission that the performing arts sector is a growth sector and is the largest employer within the cultural and creative sector in Europe, and that the total turnover of that sector (according to the EY study “Creating Growth”, 2014) equalled EUR 31.9 Billion in 2012. In 2017, the live-music-industry grossed over EUR 7 Billion in Europe. The cultural and creative industries continue to surpass the chemical industries in regard to Gross Domestic Product share in Germany.
The live-music, live-event, corporate-event, television, film, trade show and theatre industries all rely on a large number of specialty luminaires for artistic and economic reasons. Most of these are manufactured to have long product life-cycles. The VPLT will continue to educate our members in regard to the importance of moving towards more climate-friendly products, processes and solutions and we will support the cause for sustainability and energy efficiency by lobbying the German government to supply funding for public performance spaces in order to allow for the replacement of those light sources that no longer comply with the Ecodesign Requirements. As a stakeholder, we look forward to supporting the EU in the future.
The VPLT is the German Entertainment Technology Association. With over 800 members, the VPLT represents manufacturers, technical service providers and SMEs in the Entertainment Technology sector within German-Speaking Europe. The VPLT is a member of the World Entertainment Technology Federation (World-ETF) and an Affiliate Member of the Event Safety Alliance. The VPLT is actively involved in all of the relevant industry standards and norms processes and is represented in the European CEN/TC 433 – Entertainment Technology and is also registered in the EU-Transparency Register (819880923782-49) as well as in the official list of German Lobby Organisations.
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