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DIGITALEUROPE

DIGITALEUROPE represents Europe's digitally transforming industries, advocating for policies that support digital technology companies and their contributions to jobs, innovation and economic growth.

Lobbying Activity

Meeting with Anna Stürgkh (Member of the European Parliament) and RTE Réseau de transport d'électricité

27 Jan 2026 · Electricity Grids

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and European Chemical Industry Council and

27 Jan 2026 · European Competitiveness Fund

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

22 Jan 2026 · Defence and Digital Resilience

Meeting with Thierry Boulange (Acting Head of Unit Communications Networks, Content and Technology)

20 Jan 2026 · Exchange on AI omnibus and the ongoing legislative process, as well as the next steps for the AI Act implementation (upcoming guidance, etc.)

Meeting with Marc Lemaitre (Director-General Research and Innovation)

20 Jan 2026 · Ongoing developments around the EIC and how stronger cooperation could support Europe’s innovation landscape

DIGITALEUROPE urges focus on scale and security preparedness

9 Jan 2026
Topic — Review of the EU framework monitoring 2030 digital transformation targets.
Message — They want the program to focus on technologies serving civilian and security needs. They advocate for reducing market barriers through joint purchasing and cross-border projects. Finally, they propose simpler reporting rules to increase speed and reduce paperwork.12
Why — This would lower the costs of doing business across European borders.3
Impact — Domestic industries sheltered by fragmentation would face tougher competition from larger scale competitors.4
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Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur)

1 Jan 2026 · Omnibus

DIGITALEUROPE Demands Harmonised Rules for Media Interface Prominence

17 Dec 2025
Topic — Evaluation of EU rules on audiovisual media services and digital content prominence.
Message — DIGITALEUROPE requests immediate Commission guidance to prevent fragmented national media prominence rules. They argue Member States should define prominent content but not dictate technical designs.12
Why — Harmonised rules would lower compliance costs and simplify cross-border technical product deployment.3
Impact — National authorities would lose the power to mandate specific technical interface designs.4
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DIGITALEUROPE Urges Massive Funding and Regulatory Restraint

15 Dec 2025
Topic — The EU initiative aims to accelerate industrial deployment of quantum technologies.
Message — The organization calls for streamlined funding and a dedicated Joint Undertaking. They also demand avoiding regulation until technologies reach full maturity.123
Why — This would provide growth capital while preventing innovation-stifling rules.45
Impact — The United States would lose its overwhelming lead in private investment.6
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Meeting with Brando Benifei (Member of the European Parliament) and American Chamber of Commerce to the European Union

12 Dec 2025 · AI and Trade

Meeting with Ana Beramendi (Cabinet of Commissioner Andrius Kubilius)

9 Dec 2025 · Presentation of DIGITALEUROPE’s services focused on fortifying Europe

DIGITALEUROPE seeks simplified EU taxonomy rules for electronics

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to simplify technical criteria.
Message — The organization requests a review of complex reporting requirements and usability challenges within the taxonomy. They argue that specific criteria for electronic equipment are currently impossible to fulfill due to a lack of methodologies. There is also a need to ensure consistency with existing chemical safety legislation.123
Why — Simplifying these rules would allow digital companies to accurately report and align with sustainability standards.4
Impact — Sustainable investors may lose access to rigorous benchmarking data if reporting criteria are weakened.5
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Meeting with Arba Kokalari (Member of the European Parliament) and Technology Industries of Finland (Teknologiateollisuus ry) and Workday

4 Dec 2025 · Employment policy

Response to Delegated Regulation on effective and secure access to On-Board Diagnostic and Repair and Maintenance Information

2 Dec 2025

DIGITALEUROPE is the leading European trade association representing digitally transforming industries. Our membership brings together a broad digital ecosystem contributing to the advancement of autonomous and connected mobility in Europe, including European OEMs, connectivity and infrastructure providers, semiconductor and AI technology companies, and software providers. We support the general objectives of the European Commissions delegated act on effective and secure access to on-board diagnostic and repair and maintenance information, as a necessary step to harmonise access conditions with the EUs strict safety and cybersecurity frameworks. Establishing clear, harmonised and secure access conditions for vehicle data is important for a competitive and innovative autonomous driving environment. However, it is crucial that regulations reflect the difference between driver-assistive technologies (ADAS) and fully Autonomous Driving Systems (ADS) to preserve the integrity of safety-critical operations. We encourage a swift adoption of this text that provides legal certainty and predictability for all actors across the mobility value chain.
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Meeting with Olivér Várhelyi (Commissioner) and

1 Dec 2025 · Digital and AI as an enabler in healthcare

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and European Digital Rights and

20 Nov 2025 · Omnibus IV

DIGITALEUROPE urges €200bn semiconductor investment push

17 Nov 2025
Topic — Revision of the EU Chips Act to strengthen Europe's semiconductor ecosystem.
Message — The organization requests a centralised EU semiconductor budget of at least €20 billion, faster approval times under seven months, expanded scope for FOAK projects, and coordinated tax incentives. They call for industry alliances linking chip makers with key sectors and support for areas where Europe can lead globally.1234
Why — This would enable members to secure faster funding approvals and reduce operational costs through tax incentives.567
Impact — Non-European semiconductor manufacturers lose competitive advantage as EU subsidies favor domestic industry.8
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Meeting with Chiara Riondino (Head of Unit Employment, Social Affairs and Inclusion)

13 Nov 2025 · Exchange of views on AI and AM in the workplace

Tech industry urges AI investment to modernize EU energy grids

5 Nov 2025
Topic — EU consultation on digitalizing energy infrastructure and deploying artificial intelligence in the sector.
Message — The organization calls for standardized energy data frameworks, aligned AI regulations, cross-border pilot funding, and modernized grid investment rules. They want digital assets made fully recoverable through new accounting approaches and faster permitting via automation.123
Why — This would enable their members to sell more digital infrastructure and AI solutions to energy operators.45
Impact — Traditional energy equipment suppliers face displacement by software-driven alternatives and digital competitors.6
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Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

4 Nov 2025 · Collect stakeholders’ input on the Terrible Ten specific challenges

Meeting with Lorena Boix Alonso (Deputy Director-General Health and Food Safety) and

22 Oct 2025 · Digital Europe Health Executive Council. Simplification in the Healthcare sector with a focus on AI and AI deployment.

Digital industry opposes new fairness law, urges enforcement focus

21 Oct 2025
Topic — EU consultation on strengthening consumer protection against dark patterns and unfair digital practices.
Message — DIGITALEUROPE argues that existing consumer protection laws already address problematic digital practices and opposes new legislation. They request the EU focus on enforcing current rules rather than creating duplicative requirements. The organization warns against concepts like 'fairness by design' duties and reversing the burden of proof.123
Why — This would help digital companies avoid additional compliance costs and legal uncertainty from new regulation.45
Impact — Consumers lose stronger protections if enforcement remains weak and problematic practices persist unaddressed.6
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

21 Oct 2025 · Exchange of views on the environmental omnibus, the Packaging and packaging waste regulation (PPWR), the WEEE review and WEEE own resources

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)

16 Oct 2025 · Roadworthiness package

Meeting with Christian Ehler (Member of the European Parliament)

16 Oct 2025 · FP10

Response to Digital package – digital omnibus

14 Oct 2025

Please find DIGITALEUROPE’s contribution to this call for evidence in the attachment.
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Digital industry urges binding electrification targets and grid digitalization

8 Oct 2025
Topic — EU plan to increase electrification from fossil fuels to clean electricity.
Message — DIGITALEUROPE requests a mandatory 32% electrification target by 2030, lower electricity taxes, and grid digitalization incentives. They want clearer connection queues and streamlined permitting for clean energy projects.123
Why — This would reduce compliance costs and accelerate grid connections for their members' energy-intensive digital operations.456
Impact — Fossil fuel industries lose as electricity taxes fall and renewables become more competitive.7
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

8 Oct 2025 · Simplification

Meeting with Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

8 Oct 2025 · - Introduction to DIGITALEUROPE work on standardisation - HLF new mandate - Revision Regulation 1025/201

Tech industry urges EU to prioritize commercialization over research funding

3 Oct 2025
Topic — EU proposal to strengthen innovation ecosystem and help companies access capital.
Message — The organization wants funding to cover the full innovation cycle, with targeted support at technology readiness levels 5-6. They request simplified rules, expanded equity partnerships, and harmonized startup definitions. Funding rules must cover operational costs for cloud and cybersecurity, not just capital expenditure.123
Why — This would reduce compliance costs and allow tech companies to access public funding for their business models.45
Impact — Traditional research institutions lose funding priority as resources shift toward market-ready commercialization.6
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Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

1 Oct 2025 · Regulatory challenges for the driving in Europe

Digital industry urges EU-wide corporate form for startups

30 Sept 2025
Topic — EU proposal for harmonized legal framework to help innovative companies operate across borders.
Message — The organization requests a simplified EU-wide legal form with 48-hour digital incorporation, standardized documents, and no eligibility criteria. They want coordination of tax procedures, harmonized employee stock options, and specialized courts with English-language options.1234
Why — This would reduce legal costs and administrative burden for cross-border operations.567
Impact — National legal and notary services lose business from simplified digital incorporation procedures.89
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Meeting with Bruno Tobback (Member of the European Parliament)

29 Sept 2025 · Digitalization of the Electricity Grid

Meeting with Mary Veronica Tovsak Pleterski (Director Internal Market, Industry, Entrepreneurship and SMEs) and EuroCommerce and SMEunited aisbl

18 Sept 2025 · Meeting with business associations on the way forward of the implementation of the Single Market Strategy/”Terrible Ten”

Meeting with Marina Kaljurand (Member of the European Parliament)

10 Sept 2025 · Digital Europe's recent studies

Meeting with Arba Kokalari (Member of the European Parliament)

10 Sept 2025 · Digital policy

Meeting with Dóra Dávid (Member of the European Parliament)

10 Sept 2025 · Digital simplification, AI policy

Meeting with Dóra Dávid (Member of the European Parliament)

9 Sept 2025 · AI & Tech Declaration Launch Event

Meeting with Eva Maydell (Member of the European Parliament)

9 Sept 2025 · EU Tech Agenda

DIGITALEUROPE urges digital documentation while defending industry technical standards

3 Sept 2025
Topic — The European Union is updating product legislation for the digital age.
Message — The organization demands the withdrawal of common specifications to protect the industry-led standardisation system. They also push for the full digitalisation of product documentation and labels.1234
Why — Moving to digital-only documentation would significantly reduce overhead and operational costs.5
Impact — The European Commission would lose proposed powers to set technical rules unilaterally.67
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DIGITALEUROPE urges digital documentation but rejects common specifications

3 Sept 2025
Topic — This consultation updates product laws to allow digital documentation and specifications.
Message — DIGITALEUROPE requests that the introduction of new technical rules be withdrawn entirely. They advocate for fixing the approval process for technical standards instead. The group also supports replacing paper manuals with digital documentation.123
Why — Cutting paper requirements would lower production costs and reduce administrative burdens.4
Impact — The European Commission would lose the power to bypass standardisation bodies.5
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Meeting with Victor Negrescu (Member of the European Parliament) and Microsoft Corporation and

3 Sept 2025 · LinkedIn/OECD session on skills-first hiring

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

3 Sept 2025 · Digital issues

DIGITALEUROPE Urges Enforcement Instead of New Consumer Laws

12 Aug 2025
Topic — This consultation seeks input on the EU’s consumer policy strategy for 2025-2030.
Message — The group urges prioritizing the enforcement of current laws over creating new regulations. They recommend simplifying consumer information and digitizing product documentation by default. The association wants new transparency rules for third-party funding in legal cases.123
Why — This strategy avoids new regulatory layers and reduces compliance costs for digital businesses.4
Impact — Consumers find it harder to win legal disputes without a reversed burden of proof.5
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DIGITALEUROPE urges digital modernization of European energy grids

4 Aug 2025
Topic — The European Commission is consulting on measures to upgrade and expand energy grid infrastructure.
Message — The group recommends a "Total Expenditure" approach and productivity metrics to encourage digital grid investments. They seek faster permitting and a shift from first-come, first-served connection queues to criteria-based systems.123
Why — Member companies would benefit from new digital investment incentives and more predictable connection timelines.45
Impact — Speculative developers lose their queue priority as the system shifts to favor ready-to-build projects.6
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DIGITALEUROPE urges broader exemptions for destroying unsold products

31 Jul 2025
Topic — This initiative defines exceptions to the ban on destroying unsold products.
Message — The organization proposes expanding exemptions to include products damaged during handling, transport, or storage. They argue destruction should be allowed when repair is not technically feasible or cost-effective.12
Why — This would allow companies to reduce costs by discarding damaged inventory.3
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Response to Revision of the 'New Legislative Framework'

28 Jul 2025

Please find DIGITALEUROPE's reply to the call for evidence attached. Kind regards, Clara
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Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

23 Jul 2025 · Regulatory simplification and technological investments

Response to Revision of the Standardisation Regulation

18 Jul 2025

Please find DIGITALEUROPE's reply to the call for evidence attached. Kind regards, Omar
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DIGITALEUROPE Demands Delay and Voluntary Data Sharing Rules

18 Jul 2025
Topic — Consultation on a strategy to streamline data rules and enhance industrial data sharing.
Message — The group urges a one-year postponement of the Data Act's application. They request that sharing industrial data should be voluntary by default. Trade secrets and cybersecurity should be legitimate reasons to withhold data.123
Why — This would reduce operational burdens and protect sensitive commercial assets from competitors.45
Impact — Public sector bodies and third-party users lose guaranteed access to valuable industrial datasets.67
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Meeting with Thibaut Kleiner (Director Communications Networks, Content and Technology)

16 Jul 2025 · Presentation of Digital Europe and their view of scaling opportunities for European digital tech startups

Meeting with Andreas Glück (Member of the European Parliament)

15 Jul 2025 · Environment Policy / REACH

DIGITALEUROPE urges lighter rules to drive network investment

11 Jul 2025
Topic — Consultation on reform to improve secure, fast, and reliable digital connectivity infrastructure.
Message — The association requests a corrective framework that simplifies rules and reduces regulatory burdens. They call for minimum twenty-year spectrum licenses and clarity on innovative network services.123
Why — Streamlined rules would lower compliance costs and improve certainty for private investors.45
Impact — National governments lose control over spectrum policy and related financial auction proceeds.6
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DIGITALEUROPE calls for clearer unsold product disclosure rules

9 Jul 2025
Topic — EU rules requiring companies to disclose data on discarded unsold consumer products.
Message — Responsibility should rest with the owner at the time of disposal. They also request excluding business-to-business products and using risk-based verification.123
Why — This would lower compliance costs and reduce administrative burdens for digital manufacturers.45
Impact — Environmental monitors lose access to verified data on discarded industrial goods.67
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DIGITALEUROPE urges digital integration to accelerate industrial decarbonisation

7 Jul 2025
Topic — The Industrial Decarbonisation Accelerator Act aims to stimulate investments in energy-intensive sectors.
Message — The association recommends digitalising the energy ecosystem and streamlining permitting for grid infrastructure. They also suggest using AI to simplify complex regulatory documentation processes.12
Why — This would reduce operational energy costs and lower regulatory compliance burdens.34
Impact — Low-cost suppliers may lose out as procurement criteria shift towards digital sustainability.5
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Meeting with Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič)

30 Jun 2025 · Digital industries in the current geopolitical context

Meeting with Niels Flemming Hansen (Member of the European Parliament)

26 Jun 2025 · Digital Europe

Meeting with Anne Fort (Cabinet of Commissioner Andrius Kubilius)

25 Jun 2025 · Defence and digital

DigitalEurope Urges Voluntary Certification and Regulatory Coherence

20 Jun 2025
Topic — Review of the EU Cybersecurity Act to improve resilience and certification frameworks.
Message — DigitalEurope requests keeping certification voluntary except for high-risk cases. They want certificates to prove compliance with multiple laws to avoid repeating assessments. They also suggest giving the EU cybersecurity agency more power to fix security flaws.123
Why — This would lower costs and simplify rules for businesses operating across borders.4
Impact — National governments lose the ability to create their own specific security standards.5
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Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

12 Jun 2025 · Meeting with DIGITALEUROPE members on implementation of European semiconductor policy and Chips Act review.

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

6 Jun 2025 · Digitally transforming industries in the EU

DIGITALEUROPE Urges Simplified AI Rules to Boost Industrial Competitiveness

4 Jun 2025
Topic — A consultation on accelerating AI adoption and simplifying the EU AI Act.
Message — DIGITALEUROPE calls for merging AI requirements into existing sectoral laws to avoid overlapping regulations. They advocate delaying high-risk obligations until one year after common industry standards are published. The group also demands the removal of mandatory registration databases for AI systems.123
Why — These proposals would significantly reduce compliance costs and protect proprietary software from exposure.45
Impact — Surveillance authorities would lose direct oversight tools and easy access to technical code.67
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Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

4 Jun 2025 · Sustainability Omnibus

Response to Quantum Strategy of the EU

2 Jun 2025

Quantum technologies promise to revolutionise Europes economy and security. With quantum sensing, communications and computing set to play a foundational role in next-generation digital ecosystems, the potential contribution to the EU economy could reach 850 billion over the next 15-30 years. Yet, many quantum technologies are still in the early stages, requiring significant and sustained public and private investment to spur innovation, build industrial capacity and bridge the gap to real-world applications. Europes efforts are fragmented across different EU programmes, national strategies and focus areas, risking inefficiencies and reduced competitiveness. The upcoming EU Quantum Strategy must establish a coherent vision for the EU quantum ecosystem and take a coordinated approach across the supply chain from basic research to commercial deployment supporting strategic projects across the full technology stack. To stay ahead, Europe must invest at scale, close the talent gap, fast-track standards and build a truly frictionless Single Market for quantum ventures of all sizes. For now, Europes quantum ecosystem is driven by start-ups, with dozens of young innovative companies trying to establish themselves in different niches along the value chain and technology stack. To help them scale at home while preserving Europes openness, the EU must: Avoid regulating the quantum ecosystem until technologies have matured and regulatory gaps can be clearly identified. Scale up public and private funding to boost demand for innovative quantum solutions. Bridge the quantum skills gap to meet the growing demand for talent. Foster industrial capacity to stay globally competitive and bring innovations to market.
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Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

28 May 2025 · Exchange on AI declaration of DigitalEurope and preparation of VIP roundtable on Digital Omnibus

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

28 May 2025 · Exchange on AI declaration of DigitalEurope

DIGITALEUROPE rejects new EU rules for radio software updates

27 May 2025
Topic — This consultation addresses legal requirements for radio equipment modified through software updates.
Message — The organization argues against new legal requirements because software updates rarely affect core radio compliance. They support maintaining the current framework while providing clearer guidance for manufacturers.123
Why — Maintaining the status quo avoids costly technical overhauls for standard hardware products.4
Impact — Market surveillance authorities may find it harder to monitor niche software-defined radios.5
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Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

26 May 2025 · Meeting with DIGITALEUROPE new Director for the Single Market & Digital Competitiveness - State of play European semiconductor policies and Chips Act review

Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur) and European Composer and Songwriter Alliance

23 May 2025 · KI & Urheberrecht

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

8 May 2025 · GROW H meeting with DigitalEurope on the technical specifications in the context of the 3rd omnibus proposal on mid-caps

Meeting with Rosalinde Van Der Vlies (Director Energy)

7 May 2025 · Digitalisation and Ecodesign

Meeting with Christiane Kirketerp De Viron (Acting Director Communications Networks, Content and Technology)

6 May 2025 · Cybersecurity of hospitals and healthcare providers

Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

5 May 2025 · Exchange of views on the copyright levies system in the European Union

Meeting with Piotr Müller (Member of the European Parliament)

29 Apr 2025 · Legislative challenges for digital markets

Meeting with Piotr Serafin (Commissioner) and

24 Apr 2025 · Exchange of views on access to EU Funding

Meeting with Kristian Vigenin (Member of the European Parliament, Shadow rapporteur)

24 Apr 2025 · GDPR procedural regulation

Meeting with Damian Boeselager (Member of the European Parliament)

23 Apr 2025 · Simplification & Burden Reduction

Response to Technical description of important and critical products with digital elements

18 Apr 2025

Thank you very much for the opportunity to react to this draft implementing act. Whilst we are appreciative of the substantial work already done, we see a need for further improvements to the both the recitals and technical descriptions, predominantly to provide greater legal certainty. To that end, we are glad to provide concrete recommendations directly onto the draft text of the implementing act, accompanied by corresponding justifications. Please find DIGITALEUROPE's suggestions for improvements, in the format of the template provided for by the Commission, attached to this response.
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DIGITALEUROPE urges digital integration in EU life sciences strategy

17 Apr 2025
Topic — A multi-disciplinary strategy aimed at boosting competitiveness in European life sciences.
Message — The group calls for a holistic approach that prioritizes health data. They advocate for harmonized implementation of data laws and innovation hubs. They also request streamlining reporting requirements to ease the business burden.12
Why — Unified rules and streamlined reporting would significantly lower administrative costs for companies.3
Impact — National regulators lose autonomy as the plan targets diverging local interpretations.4
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Meeting with Michael McGrath (Commissioner) and

15 Apr 2025 · Exchange of views on competitiveness, simplification, AI, GDPR, forthcoming 28th regime and Digital Fairness Act

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and European Banking Federation

9 Apr 2025 · Omnibus

Meeting with Ana Carrero (Cabinet of Commissioner Piotr Serafin)

1 Apr 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities.

DigitalEurope urges voluntary EU Taxonomy disclosures to reduce business burdens

26 Mar 2025
Topic — This consultation addresses simplifying EU Taxonomy reporting requirements to reduce administrative costs for companies.
Message — DigitalEurope proposes making all EU Taxonomy disclosures voluntary to allow businesses to develop robust practices. They also advocate for simplified reporting templates and a 10% materiality threshold for eligibility.12
Why — Businesses would avoid high compliance costs and complex reporting requirements that currently outweigh benefits.34
Impact — Investors lose a reliable benchmarking tool for assessing environmental performance and sustainable investments.5
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Meeting with Stéphanie Yon-Courtin (Member of the European Parliament, Shadow rapporteur)

26 Mar 2025 · Online protection of minors

Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)

18 Mar 2025

DIGITALEUROPE welcomes the opportunity to provide feedback to the draft delegated regulations amending Annex I to the Regulation on persistent organic pollutants to amend the limit values for unintentional trace contamination (UTC) for PCBs and PBDEs. The digital industry is strongly dedicated to do its part to guarantee the sound management of chemical substance through their life cycle and committed to ensure the protection from harmful chemicals to avoid harm to human health and the environment. As such, we support the objective of the Stockholm Convention and EU POPs Regulation to eliminate Persistent Organic Pollutants. DIGITALEUROPE's feedback concerns the draft acts' proposal to lower the Unintentional Trace Contaminant (UTC) limits for PCB and PBDEs to 0,2 mg/kg (0,00002% by weight) and 10 mg/kg respectively. Electronic products often contain over a thousand individual components, many of which are complex in nature. Imposing substance restrictions at extremely low levels becomes impractical and unenforceable due to the difficulty of accurately measuring these quantities in complex articles. To prevent any disruptions, we reiterate our recommendation to set an UTC limit of 1000 ppm. This would be fully in line with the goals of the Stockholm Convention, which allows the presence of unintentional trace contaminants to give manufacturer the possibility to manage the threshold in complex objects appropriately.
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Response to Persistent organic pollutants - PBDEs

18 Mar 2025

DIGITALEUROPE welcomes the opportunity to provide feedback to the draft delegated regulations amending Annex I to the Regulation on persistent organic pollutants to amend the limit values for unintentional trace contamination (UTC) for PCBs and PBDEs. The digital industry is strongly dedicated to do its part to guarantee the sound management of chemical substance through their life cycle and committed to ensure the protection from harmful chemicals to avoid harm to human health and the environment. As such, we support the objective of the Stockholm Convention and EU POPs Regulation to eliminate Persistent Organic Pollutants. DIGITALEUROPE's feedback concerns the draft acts' proposal to lower the Unintentional Trace Contaminant (UTC) limits for PCB and PBDEs to 0,2 mg/kg (0,00002% by weight) and 10 mg/kg respectively. Electronic products often contain over a thousand individual components, many of which are complex in nature. Imposing substance restrictions at extremely low levels becomes impractical and unenforceable due to the difficulty of accurately measuring these quantities in complex articles. To prevent any disruptions, we reiterate our recommendation to set an UTC limit of 1000 ppm. This would be fully in line with the goals of the Stockholm Convention, which allows the presence of unintentional trace contaminants to give manufacturer the possibility to manage the threshold in complex objects appropriately.
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Response to EU Start-up and Scale-up Strategy

17 Mar 2025

DIGITALEUROPE is committed to transforming Europes single market into a seamless, unified platform that empowers innovative startups to grow and scale up. Our attached reports outline concrete steps to address the difficulties that startups and scaleups face in accessing capital, markets, services, infrastructure and talent. Key recommendations are: European Business Code: Differing national rules complicate cross-border expansion, increase compliance costs and limit startups potential customer base. DIGITALEUROPE fully supports the creation of an optional 28th regime to harmonise fragmented commercial, e-commerce and company laws. Simplified Reporting Initiative: Fragmented EU reporting requirements impose disproportionate burdens on SMEs. DIGITALEUROPE calls for streamlining reporting obligations on cybersecurity, sustainability and data processing. For example, ENISA could act as a one-stop shop for cybersecurity reporting. Automated reporting, inspired by Estonias real-time data exchange model, would cut compliance costs, making Europe more competitive. Single Digital Gateway: An EU-funded platform for regulatory advice can provide SMEs reassurance of compliance with all applicable EU legislation, especially with the expanded and innovation-critical digital rulebook (AI Act, Cyber Resilience Act, GDPR, etc). Rapid Compliance Pathway: Regulatory complexity and ambiguity disproportionately hurt startups and scaleups. Removing burdensome requirements in critical areas such as the Cyber Resilience Act, AI Act and Data Act will benefit especially SMEs by creating clearer legal expectations. Leverage public procurement: European public authorities are too reluctant to adopt new technologies, making it difficult for startups and scaleups to gain traction in the EU market. As a result, many are forced to prioritise sales outside the EU. Harmonising procurement requirements and processes to create demand for European scaleups, matchmaking programmes, and targeted funds for technology procurement (e.g. cybersecurity of critical infrastructure) would foster innovation and growth in strategic sectors. Simplify funding applications and compliance: Startups and scaleups face significant challenges navigating the complex EU funding environment. The lack of a central portal to identify relevant EU funding disadvantages startups. Reporting requirements need be streamlined to avoid excessive bureaucracy. Flexible cost allocation categories are crucial to accommodate the diverse needs of research and manufacturing projects. Shorter, more agile funding rounds could help scaleups secure capital. Streamline financial support and unlock venture capital: European funding, including private equity, is more risk-averse and fragmented than in other jurisdictions, pushing scaleups to seek capital in foreign markets. The Competitiveness Fund, the EIBs TechEU programme, and the Savings and Investments Union must effectively deliver funding to scaleups to prevent their relocation. Allowing the EIB to invest directly in listings and equity would provide scaleups with additional capital. Harmonise tax requirements: Harmonisation and digitalisation of tax procedures would make the single market easier to access for SMEs. Tax credits for tech investments or an EU-wide R&D tax deduction channelled towards commercialisation activities would significantly boost investment. Attracting and retaining talent: Complex legal processes and high administrative overhead block startups from hiring skilled workers across Member States. More EU funding should go towards upskilling SMEs on digital skills to realise productivity gains. These solutions aim to enhance the single markets efficiency and attractiveness, enabling European businesses to scale and innovate. By reducing red tape, improving regulatory consistency and prioritising investments in digital infrastructure, Europe can reclaim its position as a global tech leader.
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Meeting with Christiane Kirketerp De Viron (Acting Director Communications Networks, Content and Technology)

14 Mar 2025 · EU Business Wallet

Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and Amazon Europe Core SARL and

10 Mar 2025 · Evaluation of the Public Procurement Directives

DIGITALEUROPE Urges Simplified Procurement and Expanded Joint Purchasing

7 Mar 2025
Topic — Evaluation of EU rules governing public contracts for works, supplies, and services.
Message — The group advocates for a targeted revision focused on harmonisation instead of a complex overhaul. They recommend expanding voluntary joint purchasing and standardising digital tools to reduce administrative burdens. They also urge shifting to a regulation to ensure consistent implementation across member states.1234
Why — Standardised rules would lower administrative costs and help digital firms compete cross-border.5
Impact — Domestic-only preference policies would harm users by inflating costs and limiting technological innovation.6
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

6 Mar 2025 · Exchange of views with the Single Market and Competitiveness Group of DigitalEurope.

Meeting with Aurore Lalucq (Member of the European Parliament, Rapporteur)

5 Mar 2025 · Mobilising Finance, SIU

Response to Savings and Investments Union

28 Feb 2025

Whilst attracting foreign investments in Europe, the Savings and Investments Union (SIU) should provide all enterprises, especially SMEs, startups and scaleups, with better access to European capital markets to prevent their relocation to other geographical regions due to insufficient financing opportunities. The SIU should increase the liquidity of European equity capital markets. Today, several factors including complex and costly EU market structures, and excessive regulation and supervision are pushing liquidity outside the EU. To address this issue, the SIU could foster equity trading in lit markets, enhancing transparency and facilitating investors participation. The SIU could also improve access to European investments with a moderate-to-high risk profile, enhance personal savings and provide better pension returns. The SIU should aim to harmonise existing European capital markets. Harmonisation should be pursued in policy areas including insolvency laws, taxation, consumer protection and fixed-income regulations where Member States legislation diverges. To promote consistent implementation of rules across the EU and avoid gold-plating, new measures under the SIU should be introduced as regulations rather than directives. Additionally, Member States should adopt policy measures to reduce excessive regulatory burdens and fiscal incentives to stimulate further integration of European capital markets, whilst avoiding measures leading to price control mechanisms or affecting free competition or innovation. The SIU should also remove barriers to market-led consolidation throughout the whole market infrastructure chain, from pre-trade to post-trade. Capital market financing should complement, not replace, bank financing. The SIU should contribute to an efficient securitisation market, facilitating access to debt financing for businesses, whilst renewing banks capacity to distribute credit to the economy. For example, the SIU could promote a review of the current Basel III framework to reduce banks equity investment constraints in other businesses. Furthermore, advancing the integration of European capital markets should go alongside the completion of the Banking Union, particularly by setting clear milestones for the establishment of the European Deposit Insurance Scheme. Besides harmonising existing capital markets, the SIU should boost the emergence of new initiatives based on innovative technologies, such as distributed ledger technologies. New policy measures under the SIU could include consolidating EU-level trading venues and Multilateral Trade Facilities as well as pan-European initial public offerings. This could be accompanied by the establishment of a pan-European, optional 28th regime to generate scale and overcome fragmentation of European capital markets. To assess the impact on the EUs competitiveness of measures put forward to enhance savings and investment opportunities in Europe, the SIU should be structured around a comprehensive set of key performance indicators. Industry stakeholders should be allowed to participate in this assessment process through technical working groups. The SIU should enhance supervisory coordination between national competent authorities (NCAs) and the European Securities and Markets Authority (ESMA), notably to support businesses operating on a cross-border level. For example, ESMA and NCAs should closely monitor the quality and availability of liquidity in EU shares, ensuring that the future development of the SIU regulatory framework is based on a deep understanding of the market. Finally, the SIU should boost financial literacy to educate investors on the opportunities and risks stemming from their participation in capital markets.
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Meeting with Agnieszka Skonieczna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

27 Feb 2025 · Discussion on the future Multiannual Financial Framework and support for start-ups and scale-ups

Meeting with Thomas Skordas (Deputy Director-General Communications Networks, Content and Technology) and Σύνδεσμος Επιχειρήσεων Πληροφορικής & Επικοινωνιών Ελλάδας

20 Feb 2025 · Exchange of views on fostering a more competitive and innovation-friendly digital environment, including on copyright.

Meeting with Maria-Myrto Kanellopoulou (Head of Unit Justice and Consumers)

12 Feb 2025 · Digital Fairness Act

Meeting with Rita Wezenbeek (Director Communications Networks, Content and Technology) and

11 Feb 2025 · Opening Session: DSA roundtable discussions on online advertising (Article 46 DSA)

DIGITALEUROPE calls for longer lead exemptions in electronic manufacturing

10 Feb 2025
Topic — EU consultation on lead exemptions used in steel, aluminium, and copper manufacturing.
Message — The organization requests extending lead exemption expiry dates to at least two years after publication. They oppose splitting general exemptions into burdensome sub-categories and adding restrictive footnotes that remove existing regulatory protections.12
Why — Extending exemptions would help companies avoid unnecessary compliance costs and maintain market access.3
Impact — Small businesses risk exclusion from the market due to complex reporting requirements.4
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DIGITALEUROPE warns short lead exemption deadlines burden industry

10 Feb 2025
Topic — EU consultation on renewing hazardous substance exemptions for lead in electrical equipment.
Message — The group requests extending the proposed expiry dates to at least two years. They oppose splitting current exemptions into complex sub-categories for technical components. They also reject new footnotes that would restrict lead alloys in consumer products.12
Why — Aligning dates and maintaining general exemptions would reduce compliance costs and administrative burdens.34
Impact — Small businesses and electronic manufacturers face exclusion from the market due to impossible timelines.56
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DIGITALEUROPE warns against short RoHS lead exemption deadlines

10 Feb 2025
Topic — A consultation on extending hazardous substance exemptions for lead in electronic components.
Message — DIGITALEUROPE requests extending exemption deadlines to at least two years after publication. They oppose splitting broad exemptions into sub-categories to avoid supply chain data issues. They also reject adding restrictive chemical regulation footnotes to the current rules.123
Why — Maintaining existing exemptions reduces administrative costs and prevents product exclusion from the market.45
Impact — Small businesses and market authorities face burdens from complex new reporting and testing requirements.67
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Meeting with Thibaut Kleiner (Director Communications Networks, Content and Technology)

29 Jan 2025 · Digital Europe's simplification agenda for the new mandate

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

29 Jan 2025 · Renew Europe Stakeholder Roundtable: “Elevator Pitch for Better Single Market Rules”

Response to Single Market Strategy 2025

28 Jan 2025

DIGITALEUROPE is committed to transforming Europe's single market into a seamless, unified platform that fosters innovation and global competitiveness. Our Winning the tech race report, which we attach to our response, outlines actionable steps to eliminate fragmentation, simplify processes and accelerate digital transformation across the EU. The single market offers Europe unparallelled opportunities, but its full potential remains untapped due to inconsistent rules and practices, regulatory overlaps and administrative burdens. Today, only 8 per cent of European SMEs sell across at least one European border. To address these challenges, we propose the following key actions: 1. Cut market barriers: Establishing a European Business Code to align commercial frameworks and facilitate cross-border trade will create a more integrated business environment. Strengthening public procurement, including at common European level, by standardising processes and criteria will enhance competitiveness, for example, in defence, energy and connectivity. In addition, the EU should address divergent national product requirements by harmonising existing rules on EU level. 2. Simplify reporting and governance: Harmonising fragmented obligations and interpretations across ESG reporting and the voluminous digital acquis (e.g. cyber incidents). This will reduce complexity and compliance costs, especially for SMEs. A Data Union Strategy with a one-stop-shop authority can ensure cohesive data governance and foster data use in the European economy. 3. Ensure harmonisation: Harmonisation and digitalisation of tax reporting and procedures will make the single market easier to access also for SMEs. Where necessary, the Commission should make use of all enforcement tools available to address single market fragmentation. 4. Incentivise digital infrastructure: Accelerating the deployment of secure, scalable networks through a Connectivity Act and investing in critical technologies like AI, connectivity, quantum computing, green tech, additive manufacturing and green energy solutions is essential. Streamlined EU funding programmes should prioritise these areas to build a resilient, future-ready Europe. 5. Foster pan-European scale: Creating an optional 28th regime to harmonise fragmented laws in areas like general commercial law, e-commerce law, company law and securities law will remove barriers to scaling. Unified funding initiatives will unlock new growth opportunities and ensure leadership in global standards. These initiatives aim to enhance the single markets efficiency and attractiveness, enabling European businesses to scale, innovate and lead on the global stage. By reducing red tape, improving regulatory consistency and prioritising investments in digital infrastructure, Europe can reclaim its position as a global tech leader.
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

22 Jan 2025 · Implementation of the Data Act’s provisions on cloud switching, future cloud policy initiatives.

Meeting with Agata Gerba (Head of Unit Trade)

20 Jan 2025 · Exchange of views on digital trade topics

Meeting with Ilhan Kyuchyuk (Member of the European Parliament)

16 Jan 2025 · Europe's digital transition and novel tools

Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur for opinion) and SMEunited aisbl

15 Jan 2025 · AI Liability

Meeting with Markéta Gregorová (Member of the European Parliament, Rapporteur)

14 Jan 2025 · Discussion on GDPR enforcement

Meeting with Birgit Sippel (Member of the European Parliament)

13 Dec 2024 · LIBE digital priorities 2024-2029

Meeting with Stephanie Riso (Director-General Budget)

11 Dec 2024 · Discussing the current state of implementation of the EU budget and the STEP initiative, as well as the publication of the Draghi report.

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · discussions on Green Claims Directive

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Executive summary The Delegated Act on rules for DPP service providers presents a critical opportunity to establish a framework that is both effective and pragmatic. Open and constructive dialogue with industry will key moving forward to shape a framework that meets regulatory goals, reduces administrative burdens for all actors, and guarantees the safety and integrity of the DPP system. As the Commission defines the Delegated Act, we recommend the following: * Ensure key principles like data security, confidentiality, and technological neutrality are embedded in the legal text, with a thorough assessment of economic, competitive, and environmental impacts of mandatory third-party DPP services and infrastructure; * Clarify the definition of "independent" DPP service providers under the ESPR, to ensure legal consistency and secure DPP system continuity for third-party back-up copies; * Clarify that economic operators can authorise one DPP service provider for both primary DPP services and for back-up storage; * Establish a common, EU-wide certification scheme for back-up services by DPP providers to fulfil the requirements of Article 10 (4) of the ESPR. Certification will ensure data security Economic operators that make DPPs available by themselves should be exempted from any certification need. Please find attached further elaboration on these points.
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Meeting with Stine Bosse (Member of the European Parliament, Committee chair) and Central Denmark EU Office and

10 Dec 2024 · European health policy

Meeting with Nikola Minchev (Member of the European Parliament)

21 Nov 2024 · Meeting

Meeting with Andreas Glück (Member of the European Parliament)

21 Nov 2024 · Digital Health

Meeting with András Tivadar Kulja (Member of the European Parliament)

18 Nov 2024 · Digital transformation in Europe

DIGITALEUROPE seeks higher voting thresholds for AI expert panel

15 Nov 2024
Topic — This consultation establishes the rules and operation of the AI Act's scientific panel.
Message — The association proposes raising the voting threshold for systemic risk alerts to a two-thirds majority. They also advocate for increasing the quota of non-EU experts to leverage global knowledge.12
Why — Higher consensus requirements protect providers from sudden or unnecessary regulatory interventions.34
Impact — Public safety oversight is weakened by making it harder to flag systemic risks.56
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Meeting with Dóra Dávid (Member of the European Parliament)

13 Nov 2024 · Breakfast roundtable: AI Act: Navigating the Future of AI in Europe

DIGITALEUROPE Urges Flexible, Harmonised Online Child Protection Guidelines

27 Sept 2024
Topic — EU consultation on guidelines for online platforms to protect minors under the Digital Services Act.
Message — The group calls for a flexible, risk-based approach for platforms to tailor safety measures. They also seek a harmonised EU framework for age verification to ensure legal certainty.12
Why — This would reduce compliance costs and prevent firms from navigating conflicting national safety laws.34
Impact — National governments would lose authority to enforce stricter local laws that diverge from EU standards.56
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Meeting with Jörgen Warborn (Member of the European Parliament)

25 Sept 2024 · Digital Trade

Meeting with Axel Voss (Member of the European Parliament)

25 Sept 2024 · Digital files

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

DIGITALEUROPE calls for higher trace limits on pollutant UV-328

27 Aug 2024
Topic — The EU is proposing to restrict the persistent organic pollutant chemical known as UV-328.
Message — DIGITALEUROPE requests a higher trace limit for UV-328 to avoid supply chain disruptions. They claim the currently proposed limit is impossible for electronic manufacturers to monitor effectively.12
Why — This change would reduce the administrative burden and prevent potential manufacturing delays for electronics.3
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Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit)

25 Jul 2024 · Digital Skills

Meeting with Axel Voss (Member of the European Parliament) and IFPI Representing recording industry worldwide

17 Jul 2024 · Digital files

Meeting with Aura Salla (Member of the European Parliament) and Nokia

16 Jul 2024 · EU competitiveness

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Please find attached DIGITALEUROPE's feedback on the Waste Shipment Regulation e-waste classification.
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DIGITALEUROPE Demands Lighter Rules to Close Connectivity Gap

28 Jun 2024
Topic — The Commission is seeking feedback on scenarios for future European connectivity networks.
Message — The group calls for reducing regulatory burdens on telecom operators to encourage investment. They oppose expanding existing rules to cover cloud and digital services.12
Why — This would decrease compliance costs and facilitate easier market consolidation for major businesses.3
Impact — Consumers could face higher costs if operators are granted unrestricted pricing rights.4
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Meeting with Christian Ehler (Member of the European Parliament)

30 May 2024 · European Framework Programme

Meeting with Martina Krobath (Cabinet of Commissioner Johannes Hahn)

29 May 2024 · Next Multi-Annual Financial Framework

Response to White Paper on Dual-Use Export Controls

30 Apr 2024

DIGITALEUROPE welcomes the opportunity to express its views on the EUs future export control policies, and the European Commissions White Paper on Export Controls specifically. We appreciate the Commissions efforts to protect European know-how and businesses. Any new export control measures should strive towards maintaining the EUs global competitiveness by ensuring a level playing field and a consistent application of controls across the EU. Coordination with the private sector is crucial to maintain European competitiveness globally. In particular: -Multilateral negotiation within frameworks like the Wassenaar Arrangement helps avoid the pitfalls of unilateral controls. The Commission Expert Group should be used for internal alignment and platforms like the EU-US Trade and Technology Council leveraged for external coordination. -When extending export controls, evaluation criteria should look at foreign availability, enforceability, impact on EU competitiveness and likelihood of retaliatory responses. Redundant controls of technologies that are now globally available should be removed when possible. -Economic security initiatives should prevent overlap and complexity, in particular by separating between laws governing sanctions and export controls. Existing tools should be reviewed before creating new regulatory structures. -Human rights impact and misuse potential should be considered when regulating cyber-surveillance items. Certain items may not pose risks for internal repression or rights violations, and commercial tools should be exempted accordingly, reflecting their broadening scope of usage. -The Dual-Use Regulations vague export definition for intangible transfers complicates regulations, increasing costs for EU exporters. Upcoming Commission guidelines should address this, including by clarifying that encrypted technology exports happen only after decryption outside the EU. -A forum for political coordination on export controls should be established, with private sector involvement and technical expertise. Enhanced cooperation between Member States and industry, alongside technical expertise, is also vital in the Council Surveillance Technology Expert Group/Emerging Technology Expert Group. The Commission should improve internal expertise and establish expert groups with industry representation for setting export control criteria. -Updates to the Dual-Use Regulation should include a mechanism for a harmonised EU-wide list of excluded parties/countries as well as clearer definitions, especially regarding export licensing criteria, to accommodate automation and due diligence.
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Meeting with Sergey Lagodinsky (Member of the European Parliament, Shadow rapporteur)

21 Feb 2024 · Artificial Intelligence Act - Breakfast Meeting "Maters of Digital"

Meeting with Daniel Braun (Cabinet of Vice-President Věra Jourová), Wojtek Talko (Cabinet of Vice-President Věra Jourová)

20 Feb 2024 · Artificial intelligence

Meeting with Karolin Braunsberger-Reinhold (Member of the European Parliament)

13 Feb 2024 · Digitaler Euro

DIGITALEUROPE warns against premature reopening of GDPR rules

8 Feb 2024
Topic — The European Commission is reviewing the application of the GDPR six years later.
Message — The group argues that reopening the GDPR is premature before new regulations are implemented. They request practical guidance to reduce compliance burdens.12
Why — Aligning regulations would reduce legal uncertainty and prevent conflicting enforcement for digital businesses.34
Impact — Individuals might face restrictions on their data rights to prevent potential misuse against companies.5
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Meeting with Adrián Vázquez Lázara (Member of the European Parliament, Shadow rapporteur)

30 Jan 2024 · Presentation of the legislative work on the Corporate Sustainability Due Diligence Directive

Meeting with Jorge Buxadé Villalba (Member of the European Parliament)

25 Jan 2024 · Euro Digital

DIGITALEUROPE demands less detailed Digital Services Act transparency reports

22 Jan 2024
Topic — The Commission is establishing mandatory templates for Digital Services Act transparency reports.
Message — The association urges the Commission to align reporting templates with the original law to avoid expanding company requirements. They request a six-month window for preparation and the removal of burdensome monthly data breakdowns.123
Why — Simpler rules would reduce reporting burdens and prevent unnecessary engineering costs for platforms.4
Impact — Researchers and public agencies would lose access to detailed, monthly statistical moderation data.56
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Response to Reporting scheme for data centres in Europe

15 Jan 2024

DIGITALEUROPE welcomes efforts to better understand the energy and sustainability impact of data centres in Europe and supports the European Commissions (Commission) efforts to establish a common Union rating scheme for data centres. Below, we have outlined our key recommendations for the initial phase of this process: a reporting scheme for data centres in the EU.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

12 Dec 2023 · Critical raw materials

Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur)

5 Dec 2023 · Green Claims Directive

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

29 Nov 2023 · EU SME policy

Meeting with Henna Virkkunen (Member of the European Parliament)

22 Nov 2023 · Cyber Resilience Act

Meeting with Alejandro Cainzos (Cabinet of Vice-President Věra Jourová)

22 Nov 2023 · Cyber resilience Act

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

22 Nov 2023 · Cyber Resilience Act

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur)

17 Nov 2023 · Forced Labour ban

Meeting with Jonás Fernández (Member of the European Parliament)

16 Nov 2023 · Digital Euro & PSD3

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

8 Nov 2023 · Digital euro, payments services

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

7 Nov 2023 · Artificial Intelligence

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

6 Nov 2023 · Discuss Commission wind energy targets under the Net-Zero Industry Act (NZIA) and Critical Raw Materials Act (CRMA)

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Siemens AG and

3 Nov 2023 · Support period in CRA

Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

31 Oct 2023

DIGITALEUROPE welcomes the draft Implementing Regulation establishing the European Common Criteria-based (ISO/IEC 15408 and 18045) cybersecurity certification scheme (EUCC) for information and communication technologies (ICT) products under the EU Cybersecurity Act. Aiming to serve as a successor to the existing schemes operating under the SOG-IS MRA, DIGITALEUROPE acknowledges the advantage of the existing practices of this MRA, but also recognises the number of improvements associated with the CSA to ensure the continuity of the certificates and the possibility to certify protections profiles for levels above AVA_VAN.3. For a detailed overview of DIGITALEUROPE's position and recommendations, please see the attached document.
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Response to Revision of the Union Customs Code

31 Oct 2023

DIGITALEUROPE supports the objectives of this ambitious reform and the aim of modernising the Union Customs Code in the wake of structural changes induced by the digitalisation of trade and of business models. We also welcome the proposed improvements for a coherent and uniform interpretation of the Code, as well as reformed mechanisms striving for enhanced trade facilitation for economic operators. This paper serves as the first generic feedback on several aspects of the reform relevant to DIGITALEUROPE members, while the Association will still be collaborating closely with the Institutions and business partners on the details of the proposal during the legislative process ahead to ensure that the new UCC is better adapted to the realities and needs of business, with specific attention to the digital sector. Need for early and continued consultation with business and lead time: The EU Customs reform proposal is ambitious, but many details on how the reform will be operationalised still need to be worked out. To ensure the reform meets its desired results and is adapted to the realities of business and trade, continued consultation with industry is key. This public consultation is a first step, but the EU Commission should consider setting up expert groups to inform the debate already during the legislative process. For example, we would highly recommend setting up an expert group with marketplaces and logistics service providers, focused on the e-commerce-related changes. Timeline: The long timelines foreseen are justified given the scale of the reform and might even need further extension depending on the duration of the legislative process and further implementation work. Businesses can only start preparing and adapting their processes based on final legislation and detailed implementing legislation and guidelines. In addition, learning from the delayed implementation of the 2021 E-commerce VAT package, sufficient lead time is also needed to adapt customs systems and processes. The proposed timeline of 2028 for the e-commerce-related changes might therefore even need further extension, depending on the speed of the legislative process. Please take a look at the attachment for the full feedback.
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Meeting with Jana Toom (Member of the European Parliament, Shadow rapporteur)

30 Oct 2023 · GDPR enforcement

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

26 Oct 2023 · Digital policies

Meeting with Bart Groothuis (Member of the European Parliament, Shadow rapporteur)

24 Oct 2023 · CSA

Meeting with Věra Jourová (Vice-President)

2 Oct 2023 · Artificial intelligence Act, support for Ukraine, cyber-security

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

DIGITALEUROPE welcomes the opportunity to comment on whether current Regulation (EU) 1025/2012 can still sufficiently respond to the new opportunities and challenges of globalisation, ensure the publics safety, and support the green and digital transition. DIGITALEUROPE supports the principles of the existing Regulation, which fosters an European industry-driven standardisation system, including the involvement all stakeholders. This regulation is essential in supporting the EU Standardisation Strategy, EU legislation and policies, particularly where aligned with the NLF. Presumption of conformity based on harmonized standards cited in the Official Journal (OJEU) is key to a well-functioning compliance system. The Regulation has been central to long and respected success through changes: we believe it remains fit for the future. DIGITALEUROPE also considers that the principles of the WTO TBT , as well as the existing cooperation mechanisms between the European standardization organizations and the international standardization bodies, such as the Frankfurt and Vienna agreements are vital, allowing an easy adoption and recognition of international standards . While we have observed degradation in OJEU citation of harmonised standards we consider this not to be attributable to weaknesses in the Regulation itself, but to increased operational complexities introduced consequent to the James Elliott and related cases. DIGITALEUROPE strongly recommends an evaluation of these operational procedures, which we consider over-prescriptive and counterproductive in terms of transparency, inclusiveness, consistency, technology neutrality and consensual approach. We therefore advise against substantially revising Regulation 1025/2012 which would risk introducing uncertainties and instability at a time when a smoothly running EU standardisation and compliance system is key for achieving important EU policy objectives. A more pragmatic interpretation of the existing regulation, and its consequent operating practices, can already help to strengthen the ESS. As to the best use of scarce resources, European experts have had to devote too much time addressing OJEU citation issues instead of developing standards in support of new technologies and to strategic European contributions in the global standardisation arena. The forthcoming studies and consultation should question this and could consider possible targeted amendments of e.g. Article 10 that could support smoother operational procedures. The attachment compares OJEU citations versus standards made available by the ESO for 3 main EU acts (LV-D, EMC-D, RE-D), reflecting the extent to which OJEU citations lag behind state-of-the-art standards published by the ESOs. DIGITALEUROPE will welcome participating in future evaluation stages.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

26 Sept 2023 · How to further reinforce the digitalisation of energy sector

Response to Energy labelling requirements for electronic displays

21 Sept 2023

DIGITALEUROPE welcomes the opportunity to respond to the European Commission's Call for evidence and lend support to the reviewing of Ecodesign Regulation 2019/2021 and Energy labelling Regulation 2019/2013. This position paper elaborates on our perspectives and recommendations concerning the proposed review and potential revision of these regulations. Key recommendations: General Ensure that LOT 5 requirements are not contrary to or overlapping with other legislative requirements (other LOTs, Chemicals legislation) Preserve adaptability of signage displays by avoiding on-mode energy requirements which would result anyway in a very limited energy saving Ecodesign Ensure that any changes to testing methodology is made through standardisation organisations rather than amending regulation Examine the Ecodesign Tier 2 EEI requirements for MicroLED and 8K displays, in order to adjust them in light of the current technology Maintain the EEI calculation methodology to avoid relabelling and retesting Encourage further utilisation and development of ABC technology by increasing the 10% allowance to 15% to reflect actual consumption behaviour Keep the allowances for low-power mode functionality as this encourages user utilisation and reduces energy consumption Ensure a uniform approach across the EU to repairability and minimise fragmentation of the Single Market Avoid unnecessary self-monitoring power/energy consumption requirements for electronic displays which will result in redesigning costs for the manufacturers and the end-user without any sensible energy-saving benefits Energy labelling Examine the possibility of providing an allowance to professional displays in order to reward most energy efficient displays in this category Introduce provision within the Energy labelling regulation for updates/changes to be made to models without necessitating a new model code. Allow display technology to catch up with higher energy classes it will help the end-users differentiate the products on the market and will avoid unnecessary relabelling See more in attached position paper
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Meeting with Gilles Boyer (Member of the European Parliament, Shadow rapporteur)

18 Sept 2023 · Digital euro

Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

DIGITALEUROPE appreciates the opportunity to submit feedback to the European Commission's public consultation on the evaluation of ENISA and the European Cybersecurity Certification Framework. Our elaborate response is hereby attached. We remain available for any clarifications required.
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DIGITALEUROPE Urges Stronger Business Safeguards in GDPR Enforcement Rules

1 Sept 2023
Topic — Proposed EU regulation to streamline cooperation between national authorities in cross-border GDPR cases.
Message — The organization calls for stronger confidentiality protections for trade secrets and more time for companies to respond during investigations. They also advocate for prioritizing internal company complaint mechanisms and amicable settlements at all stages of the process.123
Why — This would reduce legal costs and protect sensitive business data from competitors during investigations.45
Impact — Individuals may face slower case resolutions if private company complaint processes are prioritized over regulatory action.6
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DigitalEurope urges harmonized rules and digital environmental labelling

20 Jul 2023
Topic — EU consultation on rules for companies to substantiate environmental claims and green labels.
Message — The association proposes turning the directive into a regulation to ensure maximum harmonization. They advocate for digital labelling via QR codes to replace physical packaging requirements. They also suggest using alternative standards when specific product footprint rules are unavailable.123
Why — A harmonized approach with digital labels would significantly lower compliance costs for companies.4
Impact — Environmental groups lose assurance if verifiers prioritize desk audits over on-site inspections.5
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DIGITALEUROPE urges flexible sustainability reporting and trade secret protection

6 Jul 2023
Topic — The consultation defines sustainability reporting standards for companies under the Corporate Sustainability Directive.
Message — The organization requests stronger safeguards to protect commercially sensitive data and trade secrets from disclosure. They advocate for longer phase-in periods and making materiality assessments the primary reporting criteria.123
Why — Proposed changes would reduce administrative costs and prevent the exposure of proprietary business information.4
Impact — Transparency advocates lose access to granular data regarding specific pollution sites and infrastructure.5
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Meeting with Sunčana Glavak (Member of the European Parliament, Rapporteur for opinion) and The Restart Project

5 Jul 2023 · Right to repair ENVI Opinion

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

21 Jun 2023

DIGITALEUROPE and its members welcome, and strongly support the proposed new timeline for delivery of standards supporting Commission Delegated Regulation 2022/30, the Commissions assessment and citation of these standards, and the corresponding date of applicability of the Commission Delegated Regulation 2022/30. Even with the proposed new timeline the task is challenging. Therefore DIGITALEUROPE and its members kindly ask the Commission to do whatever is within its power and scope of operation to support the timely availability of clear, concise and high quality harmonised standards.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

21 Jun 2023 · Data Act

Meeting with Nils Torvalds (Member of the European Parliament)

1 Jun 2023 · ecodesign for sustainable products regulation

Meeting with Catharina Rinzema (Member of the European Parliament, Shadow rapporteur) and Vereniging VNO-NCW

30 May 2023 · Right to Repair

Meeting with René Repasi (Member of the European Parliament, Rapporteur) and Back Market

30 May 2023 · Exchange of Views on the Right to Repair Directive/ Recht auf Reparatur Richtlinie (R2R)

Meeting with Valdis Dombrovskis (Executive Vice-President)

26 May 2023 · Clean tech and digital resilience in light of the upcoming Trade & Technology Council meeting, digital trade

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

25 May 2023 · Discussion on the AI Act (held by the Assistant responsible)

Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

16 May 2023

DIGITALEUROPE welcomes the much-anticipated review of the Broadband Cost Reduction Directive (BCRD), and strongly supports the European Commissions proposal for a Gigabit Infrastructure Act (GIA). The GIA will help meet Europes increased connectivity needs, for both consumers and businesses, by supporting faster deployments of very high-capacity networks (VHCNs) with cost-efficient measures on infrastructural access, civil works, permit granting, in-building infrastructure, and single information points. The proposal would have an immediate and material impact on infrastructure providers ability to deploy the latest and best technology quickly and easily in Europe. Importantly, by virtue of being a directly applicable Regulation as opposed to a Directive, it would be enacted uniformly across the entire EU. We urge the Council and the European Parliament to adopt this proposal during the present term. It is an essential building block on the roadmap to achieve our Digital Decade connectivity goals, and as such merits utmost attention from European policymakers. The final text should: - Remain a Regulation, in order not to protract fragmented and minimal implementation by Member States; - Preserve the maximum four-month timeline for permit granting procedures, incentivise even shorter timelines as already seen in some Member State regions, and limit extensions for exceptional circumstances; - Extend the principle of cost limitation beyond permits to include rights of way and other financial burden such as taxation or other charges; - Directly provide for an exemption from any permit granting procedures for upgrades to mobile sites; - Uphold the broad definition of physical infrastructure owned and controlled by public authorities, and the obligation for authorities to clearly identify and duly justify why certain buildings are excluded; - Extend the one-month timeline to dispute settlement for refused access; and - Establish a clear single information point where information can be found, applications made and disputes resolved.
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

16 May 2023 · European Digital Identity Framework (eID)

Response to Promoting sustainability in consumer after-sales

15 May 2023

The proposed Right to Repair Directive creates a positive new framework to enable more European consumers to access high-quality, safe repairs. Our members perform millions of repairs annually. Their repair facilities across Europe help promote sustainable consumption, reduce ICT products environmental impact, deliver real consumer benefits, and create high-skilled jobs. DIGITALEUROPE supports the proposals proportionate drive to encourage even more repairs. We specifically welcome the market-driven approach to repairs outside the legal guarantee, which is the only sustainable way to create a flourishing repair economy in Europe. We also support the focus on consumer purchases, with commercial products covered instead by carefully negotiated business-to-business (B2B) repair agreements which reflect businesses critical operational needs. To create the most effective framework, we support the greatest harmonisation across the EU of these requirements and suggest some small changes: Allowing for the replacement of defective products with refurbished ones. This would capture the sustainability benefits whilst also giving consumers a quicker solution; Creating a single repair information platform per Member State to avoid fragmentation. To ensure consumer safety is protected, only original equipment manufacturers and those repairers who meet the new quality standard should be able to register; and Committing to a clear timeframe for developing the voluntary European quality standard for repair services, and ensuring that consumer safety is at its heart.
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Meeting with Krzysztof Hetman (Member of the European Parliament, Shadow rapporteur)

15 May 2023 · Exchange of views on Forced Labour Regulation (meeting delegated to parliamentary assistant)

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

11 May 2023 · Artificial Intelligence sandboxing

DigitalEurope Urges Recognition of Global Standards in Green Taxonomy

3 May 2023
Topic — New criteria identifying sustainable economic activities for the European Union's circular economy objectives.
Message — DigitalEurope requests the inclusion of international Type I eco-labels and product sustainability standards. They also want product design requirements to align strictly with existing ecodesign legislation.12
Why — This would allow the industry to avoid redundant certification costs and technical design changes.3
Impact — Public health and environmental efforts lose if the taxonomy fails to restrict additional hazardous substances.4
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Meeting with Niels Fuglsang (Member of the European Parliament, Rapporteur)

3 May 2023 · (APA) Energy Efficiency

Meeting with Paul Tang (Member of the European Parliament, Shadow rapporteur) and Meta Platforms Ireland Limited and its various subsidiaries and Bitkom e.V.

27 Apr 2023 · Staff Level: DigitalEurope/Bitkom Roundtable “Combating Child Sexual Abuse Online – finding a way forward"

Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

12 Apr 2023 · Revision of the Product Liability Directive

Response to VAT in the Digital Age

4 Apr 2023

We welcome the opportunity to provide our feedback on the VAT in the Digital Age proposal of the European Commission. We fully support the European Commissions ambition to improve the VAT system through the use of digital tools, reducing VAT-related barriers for cross-border trade in the EU and making the VAT system better for businesses, while also more resilient to fraud. We believe the VAT in the Digital Age proposal is well placed to embrace digitalization, supports a swifter transition towards Real-Time Economy, and effectively address the challenges faced by businesses (and in particular by SMEs) who trade, or have ambitions to trade, across the EU borders. This is well reflected in the proposal through: The expansion of the Union One Stop Shop (UOSS) and the introduction of a transfer module allow businesses to use one single VAT registration to report transfers of their inventory to locations across the EU, as well as the onward sales in those locations. We strongly encourage Member States to reach a consensus on this pillar, as it would be a pivotal tool to reduce the need for costly, time-consuming, and often prohibitive need for businesses wanting to sell products across the EU to maintain multiple VAT registrations. Amendments to the text of the proposal should be in line with the north star goal of reducing the VAT administrative burden for businesses. To achieve this, it is key that there is no (or very limited) negative VAT cash flow impact when businesses opt to report through the UOSS and the transfer module. Any newly introduced obligations for businesses and electronic interfaces facilitating the transfer and/or the sale of goods should be proportional and ensure a level playing field. A shift to real-time digital reporting based on e-invoicing for businesses that operate cross-border in the EU and a more harmonized framework for domestic transactions. We welcome the ambition to harmonize EU digital reporting requirements, as the current fragmentation of digital reporting and e-invoicing standards around the EU is causing an immense burden on businesses and is a threat to the Single Market. However, as the proposal focuses solely on creating a harmonized invoice format, it misses a key opportunity to harness the full business and economic benefits that could come from the harmonization of transmission protocols and technical specifications for digital reporting. The transition to real-time reporting will require considerable investments from businesses in the initial phase, but the ultimate goal should be to reduce administrative costs for businesses. The real-time, transaction-specific, structured data should also be usable by companies. It should be made sure that the company's financial management systems work smoothly with the official reporting systems. Digitization should promote the Real-Time Economy (financial transactions and processes are digital and based on structured data). As technical discussions progress, we encourage the EU Commission and EU countries to consider a pragmatic and phased approach to agreeing and adopting this proposal, as it includes a large number of VAT reforms that may take a long time to agree on all at once. To strengthen the EU Single Market and remove blockers for cross-border trade, the most urgent action is needed to ensure the implementation of the single VAT registration concept, including the introduction of the transfer module and the expansion of the Union One Stop Shop scheme. Please check the rest of the responses in the attachment.
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur)

29 Mar 2023 · Product Liability Directive

Meeting with Vlad-Marius Botoş (Member of the European Parliament, Rapporteur) and Vorwerk SE & Co. KG

27 Mar 2023 · Procult Libility Directive

DIGITALEUROPE Calls for Amicable Settlements in GDPR Enforcement

24 Mar 2023
Topic — The initiative seeks to harmonise how national authorities cooperate when enforcing GDPR across borders.
Message — DIGITALEUROPE advocates for the use of amicable settlements to resolve disputes quickly and reduce administrative burdens. They request mandatory hearings for companies under investigation before enforcement decisions are finalized.12
Why — This would speed up legal proceedings and protect sensitive corporate trade secrets from disclosure.34
Impact — Complainants may see their access to investigative files restricted due to heightened confidentiality rules.5
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DIGITALEUROPE urges harmonised labels and longer implementation timelines

22 Mar 2023
Topic — EU initiative to review packaging rules for waste prevention and better recycling.
Message — The association requests a 36-month transition period and the removal of conflicting national labels. They also advocate for digital QR codes rather than physical printing for material information.12
Why — This would decrease compliance costs and prevent fragmentation within the internal market.3
Impact — Member States lose the ability to mandate specific national sorting instructions.4
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Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

21 Mar 2023 · Packaging and packagingwaste, ecodesign for sustainable products regulation

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas)

15 Mar 2023 · Cybersecurity Skills Academy

Meeting with Paul Tang (Member of the European Parliament) and Google and

26 Feb 2023 · Participant at EIF-GSMA Roundtable discussion: "‘Connecting Europe to its 2030 Digital Decade Targets’"

Response to Measures addressing the environmental impact of imaging equipment including consumables

20 Feb 2023

DIGITALEUROPE, representing the digitally transforming industries in Europe, supports the initiative's objectives of increasing the material and energy efficiency of imaging equipment incl. consumables, and welcomes the opportunity to respond to the European Commission's call for evidence. Please see attached our more detailed position on the initiative. We are at the disposal of the European Commission for any further clarification and are committed to constructively support the development of the regulation and achievement of its goals.
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Meeting with Jan Huitema (Member of the European Parliament, Shadow rapporteur)

13 Feb 2023 · Ecodesign for Sustainable Products Regulation

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Corporate Sustainability Due Diligence

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

DIGITALEUROPE Urges Longer Implementation for EU Cyber Resilience Act

23 Jan 2023
Topic — New EU rules setting mandatory cybersecurity requirements for hardware and software products.
Message — The group requests a 48-month implementation period to develop necessary technical standards. They also propose aligning reporting rules with existing law and excluding components.123
Why — Extended deadlines and self-assessment options would significantly lower immediate technical and financial burdens.45
Impact — Cybersecurity agencies and users lose early warnings about active threats targeting their devices.6
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Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton)

19 Jan 2023 · Presentation of the Commissioner's invitation to Masters of Digital conference

Meeting with Alex Agius Saliba (Member of the European Parliament, Rapporteur) and Google and

12 Jan 2023 · Prep CSA Regulation Stakeholders meeting

Meeting with Heléne Fritzon (Member of the European Parliament, Rapporteur for opinion) and Google and

12 Jan 2023 · Rundabordssamtal

Response to Single Market Emergency Instrument (SMEI)

22 Dec 2022

Please find DIGITALEUROPE's Consultation Response on the SMEI proposal attached.
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Response to Single Market Emergency Instrument (SMEI)

22 Dec 2022

Please find DIGITALEUROPE's Consultation Response on the SMEI proposal attached.
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DIGITALEUROPE warns media rules could aid disinformation and burden tech

22 Dec 2022
Topic — This consultation seeks feedback on the proposed European Media Freedom Act.
Message — The organization calls for alignment with existing laws and technical feasibility for device customization. They specifically warn against allowing media outlets to self-certify on large online platforms.12
Why — These changes would prevent costly technical mandates and protect the proprietary data of manufacturers.34
Impact — Citizens lose protections as rogue actors could more easily spread harmful disinformation online.5
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DIGITALEUROPE urges component-level focus in forced labour product ban

30 Nov 2022
Topic — Proposed EU regulation to prohibit products made with forced labour from the market.
Message — The group requests harmonizing rules with other laws and extending investigation timelines. They also suggest recycling non-compliant components instead of destroying entire products.123
Why — Limiting disposal to specific parts prevents the wasteful destruction of entire devices.4
Impact — Vulnerable workers may suffer if fragmented national rules make corporate compliance less effective.5
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Response to European Critical Raw Materials Act

24 Nov 2022

Critical raw materials (CRMs) are essential to the twin transition. Studies show the CRM demand for 5G network equipment, photonics, edge computing applications and quantum technologies would grow 15-fold in a fast-rollout scenario. The EU can spur public and private initiatives to promote responsible, environmentally friendly and socially sustainable CRM production, processing and recycling. Reliable access to these resources is fundamental to promote sustainability, competitiveness and innovation goals in the EU. DIGITALEUROPEs members are committed to the responsible sourcing and recycling of raw materials, as well as promotion of supply chain identification, traceability, risk assessment, and due diligence. Of the policy options in the Call for Evidence for an EU CRM Act, DIGITALEUROPE supports: 1. strengthening the EUs CRM value chain, such as through diversification of supply sources and facilitated mining projects in Europe; 2. ensuring a sustainable level playing field across the Single Market, through incentives in existing sectoral legislation for the creation of a European secondary CRM market. The CRM Act should point to recycling opportunities in the existing stock of EU laws, and not introduce duplicative requirements. Please find attached our recommendations more detailed.
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Meeting with Damian Boeselager (Member of the European Parliament)

14 Nov 2022 · Data Act

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

3 Nov 2022 · Discussion on the representatives to the Expert Group on Radio Equipment (EG RE)

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

20 Oct 2022 · Corporate Sustainability Due Diligence

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

19 Oct 2022 · Digitising Energy Action Plan

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

17 Oct 2022 · Corporate Sustainability Due Diligence

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur for opinion)

13 Oct 2022 · Chips Act

Meeting with Petra Kammerevert (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

12 Oct 2022 · Implementierung AVMD

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides) and European Cancer Organisation and

10 Oct 2022 · Working group on European Health Data Space

Response to Environmental impact of mobile phones and tablets - Ecodesign

27 Sept 2022

Please find in attachment the DIGITALEUROPE feedback on Lot X draft regulation (Ecodesign & Energy Labelling).
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Response to Improving the provision of digital skills in education and training

16 Sept 2022

As we have pointed out ever since we launched our Manifesto for a Stronger Digital Europe back in 2019, Europe’s goals for new investments and measures on digital will fail to materialise unless workforce and society have appropriate digital competencies.1 Completing the single market on data to fulfil Treaty goals, for instance, requires digitally prepared talents and citizens that take the opportunities policy creates. Accelerating progress on the Digital Decade skills targets and bridging the digital divide have become a matter of unique urgency. The Commission and Member States must, together, move the discussion on digital skills and education to the highest level of government and reap the knowledge-sharing and efficiency benefits that come from coordination. They must also deepen partnerships with industry to take immediate action by leveraging existing, successful initiatives. Time is running out. The EU needs to add 1.2 million ICT specialists to the employment figures every year until 2030 to hit its Digital Decade targets. It similarly needs to make an extra 20% of the EU’s population digitally literate by the same year. These are pressing tasks, especially when today barely more than 50% of EU citizens can conduct basic tasks like downloading an app or purchasing online, and when EU average figures mask substantial differences in technology access among specific groups. The political push on the topic should translate into: - Launching a new ‘’Rapid Training Fund’’ co-financed by the Recovery and Resilience plans of interested countries. It should focus first on cybersecurity upskilling and train immediately 200,000 cyber security experts (the number of experts Europe lacks today). This is key to fulfil labour market demands. - Recognise existing partnerships as eligible entities to apply or re-apply for EU funding on digital upskilling or reskilling. There is no need to reinvent the wheel if successful projects already exist and can be ramped up. - Carving out enough compulsory curricular time for coding and computational thinking in secondary schools, as Denmark has just done, and make algorithmic thinking a compulsory subject in primary schools. - Launching a flagship ‘’Teachers for the Digital Decade’’ initiative to develop a standardised digital competences’ qualification programme for teachers and educators at all levels. - Make women in ICT mentorship a key priority in EU-funding programmes such as ERASMUS+ and the Digital Europe Programme. We offer more background on these and other recommendations in the document attached.
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Response to Enabling factors for digital education

16 Sept 2022

As we have pointed out ever since we launched our Manifesto for a Stronger Digital Europe back in 2019, Europe’s goals for new investments and measures on digital will fail to materialise unless workforce and society have appropriate digital competencies.1 Completing the single market on data to fulfil Treaty goals, for instance, requires digitally prepared talents and citizens that take the opportunities policy creates. Accelerating progress on the Digital Decade skills targets and bridging the digital divide have become a matter of unique urgency. The Commission and Member States must, together, move the discussion on digital skills and education to the highest level of government and reap the knowledge-sharing and efficiency benefits that come from coordination. They must also deepen partnerships with industry to take immediate action by leveraging existing, successful initiatives. Time is running out. The EU needs to add 1.2 million ICT specialists to the employment figures every year until 2030 to hit its Digital Decade targets. It similarly needs to make an extra 20% of the EU’s population digitally literate by the same year. These are pressing tasks, especially when today barely more than 50% of EU citizens can conduct basic tasks like downloading an app or purchasing online, and when EU average figures mask substantial differences in technology access among specific groups. The political push on the topic should translate into: - Launching a new ‘’Rapid Training Fund’’ co-financed by the Recovery and Resilience plans of interested countries. It should focus first on cybersecurity upskilling and train immediately 200,000 cyber security experts (the number of experts Europe lacks today). This is key to fulfil labour market demands. - Recognise existing partnerships as eligible entities to apply or re-apply for EU funding on digital upskilling or reskilling. There is no need to reinvent the wheel if successful projects already exist and can be ramped up. - Carving out enough compulsory curricular time for coding and computational thinking in secondary schools, as Denmark has just done, and make algorithmic thinking a compulsory subject in primary schools. - Launching a flagship ‘’Teachers for the Digital Decade’’ initiative to develop a standardised digital competences’ qualification programme for teachers and educators at all levels. - Make women in ICT mentorship a key priority in EU-funding programmes such as ERASMUS+ and the Digital Europe Programme. We offer more background on these and other recommendations in the document attached.
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Meeting with Antonius Manders (Member of the European Parliament, Rapporteur for opinion)

13 Sept 2022 · Batteries and waste batteries

Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur) and Microsoft Corporation and

7 Sept 2022 · Data Act

DIGITALEUROPE Urges Voluntary Detection in Child Abuse Material Rules

31 Aug 2022
Topic — New EU regulations requiring online services to detect and report child sexual abuse.
Message — The group requests appropriate derogations from the ePrivacy Directive not contingent on detection orders. They advocate for capturing only high risk services, exempting business and infrastructure providers.12
Why — Infrastructure providers would avoid the technical difficulty and liability of monitoring data they cannot control.3
Impact — Law enforcement may lose access to evidence if transparency reports assist criminals in evading detection.4
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DIGITALEUROPE Urges Regulatory Alignment for European Health Data Space

28 Jul 2022
Topic — A consultation on the proposed regulation creating a European Health Data Space.
Message — They request alignment between the health data proposal and laws like GDPR. They demand clearer data holder definitions and protections for intellectual property. Certification should be simplified to avoid duplicative requirements with existing regulations.123
Why — Simplified rules would reduce compliance costs and administrative burdens for companies.4
Impact — Broad intellectual property protections could limit data access for external researchers.5
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Response to The Union Position for the World Radiocommunication Conference 2023

26 Jul 2022

DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission's call for evidence on the establishment a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023. Our views, along with their underlying justifications, are set out in the attached position paper. We remain available for any queries and will be happy to further engage in future discussions around this matter.
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Response to Review of EU rules on payment services

26 Jul 2022

DIGITALEUROPE supports the policy option of limited legislative amendments to the second Payment Services Directive (PSD2) among those outlined in the Call for Evidence. These amendments could primarily clarify existing rules around Open Banking and Strong Customer Authentication (SCA) in order to facilitate their roll-out. The PSD2 is a milestone in achieving an integrated payments market in Europe. It seeks to foster competition and innovation in retail payments, while ensuring a high level of security and consumer protection. Four years after its entry into force, the PSD2 has already reached some of its main objectives. The Introduction of SCA together with continued investment and use of fraud-prevention technologies have contributed to reducing e-commerce fraud rates. However, strict implementation of the SCA mandate still poses some challenges that result in unnecessary friction. Such strictures do not allow to strike the right balance between security and customer’s convenience. Abandonment rates continue to improve but are still relatively high at a time when e-commerce is needed the most. DIGITALEUROPE's membership includes credit card networks, financial institutions, and other emerging actors in the fintech ecosystem. Our recommendations for the revision of the PSD2 include: - Maintaining payment processors and operators of payment systems and schemes out of PSD2’s scope. They are already subject to the Principles of Financial Market Infrastructure (PFMIs) - a robust set of standards for the supervision and oversight of payment processors and system activities; - Introducing a more risk-based approach to Strong Customer Authentication (SCA), focused on limiting re-authentication needs, exempting applications such as remote and connected environments in specific circumstances, and analysing whether a review of the threshold for contactless payments is necessary; - Publishing EU guidance to improve the Open Banking experience and align further the PSD2 with the GDPR. We offer more background on these and other recommendations in the attachment.
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Response to Open finance framework

26 Jul 2022

Of the policy options in the Inception Impact Assessment, DIGITALEUROPE supports the promotion of market-driven standardisation to address the existing technical obstacles to data reuse without introducing any new data access rights. Within an EU voluntary data sharing framework, Open Finance could grow Europe’s digital economy by speeding up the introduction of new digital services on the EU Single Market and engaging new players in the European digital finance ecosystem. The EU has a vital interest in getting it right. It should avoid a repeat of the rocky implementation of Open Banking. That means avoiding a rigid, prescriptive framework and embracing a principles-based one allowing for diverse commercial models that drive innovation and competition in Europe. Such an approach should encourage voluntary data-sharing among companies as a way to expand Europe’s data ecosystem, including through the combination of data from different sectors in a voluntary manner. It should also reaffirm that the individual has rights over their personal data and is consequently entitled to access it. We believe market-driven standardisation can truly enhance new service delivery and improve customer experience, as opposed to the introduction of new mandated third-party data access rights that would disincentivise private investments into digitisation. DIGITALEUROPE strongly believes the success of the EU Open Finance framework will depend on: - Fixing the shortcomings of the EU’s Open Banking - High-quality Application Programming Interfaces (APIs) - Customer trust in data-sharing - Appropriate compensation for data holders - Regulatory coherence with other horizontal EU data-related policies We offer more background on these and other recommendations in the attached file.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

4 Jul 2022 · Sovereignty and participation in expert groups and standardisation work

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

30 Jun 2022 · US-EU Task Force Convening: Energy efficiency and Energy Savings. The American Council for an Energy-Efficient Economy (ACEEE), the Air-Conditioning, Heating, and Refrigeration Institute (AHRI) and Tado also participated.

Meeting with Bart Groothuis (Member of the European Parliament, Shadow rapporteur)

30 Jun 2022 · Chips Act

Meeting with Bart Groothuis (Member of the European Parliament, Shadow rapporteur)

28 Jun 2022 · APA meeting on Chips Act

Response to Sustainable Products Initiative

22 Jun 2022

As an organisation representing over 35,000 businesses in the digital sector, DIGITALEUROPE and its members have been at the forefront of the transition of the digital industry towards more responsible and sustainable models for some years now. We have collectively been involved in the making of sustainable corporate and public policies at company, national, European, and worldwide level, especially in the ICT industry, allowing us to share our experience. Ecodesign has historically been a very successful framework in improving the sustainability of energy related products. With the scope extended to non-energy related products, DIGITALEUROPE understands and recognizes the need to further expand the breath of requirements covered by the framework. At the same time, we wish to highlight a few aspects that require further consideration. Please find our attached paper for more detailed and concrete recommendations.
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DIGITALEUROPE Urges Risk-Based Approach to Forced Labour Ban

20 Jun 2022
Topic — The EU is consulting on a proposal to ban products made using forced labour.
Message — DIGITALEUROPE requests a risk-based approach aligned with international standards and existing sustainability laws. They suggest a transparent process with clear evidence thresholds and a gradual ramp-up for enforcement. The group also wants recognition for existing industry-led due diligence schemes.123
Why — This would lower compliance costs by allowing companies to use existing industry standards.45
Impact — Victims of forced labour may face delayed justice due to proposed enforcement ramp-up periods.67
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Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

20 Jun 2022 · AI Act

DIGITALEUROPE urges enforcement of existing rules over new regulations

14 Jun 2022
Topic — Evaluation of EU consumer protection laws to ensure effectiveness in digital markets.
Message — The organization calls on the EU to use existing laws like the Digital Services Act instead of introducing new measures. They argue that current regulations are sufficient to handle issues like dark patterns and online transparency.123
Why — The industry avoids the financial burden of new information requirements and complex compliance obligations.4
Impact — Consumers lose potential new legal protections against manipulative digital business practices.56
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Response to Cyber Resilience Act

24 May 2022

Please find DIGITALEUROPE's feedback in the position paper attached.
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DIGITALEUROPE Calls for Practical Rules and Limited Liability

23 May 2022
Topic — This consultation addresses proposed EU rules on mandatory corporate human rights and environmental due diligence.
Message — DIGITALEUROPE recommends decoupling due diligence duties from liability and aligning the framework with international standards. They advocate for a risk-based approach that limits corporate responsibility to direct supply chain relationships rather than the entire value chain.12
Why — These changes would reduce legal exposure and the administrative burden of monitoring product end-use.3
Impact — Affected communities would find it more difficult to hold companies accountable for indirect harms.4
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

18 May 2022 · TTC

Meeting with Karlo Ressler (Member of the European Parliament, Rapporteur for opinion) and Intel Corporation and

17 May 2022 · Chips Act

Meeting with Didier Reynders (Commissioner) and

11 May 2022 · Artificial Intelligence, Data protection and corporate sustainability directive

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and American Chamber of Commerce to the European Union and

11 May 2022 · Corporate Sustainability Due Diligence

Meeting with Tom Berendsen (Member of the European Parliament, Rapporteur)

4 May 2022 · Industry Strategy

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur for opinion)

2 May 2022 · Chips Act

DIGITALEUROPE Rejects Need for New EU Patent Licensing Rules

29 Apr 2022
Topic — Consultation on harmonizing EU procedures for compulsory patent licensing during crises.
Message — DIGITALEUROPE argues that current national systems work well and opposes new EU intervention. They demand that compulsory licensing remain a narrow exception and a last resort.1234
Why — Avoiding new EU rules protects the industry from mandatory technology sharing costs.5
Impact — Public health groups lose faster access to protected technologies during emergencies.6
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

7 Apr 2022

DIGITALEUROPE welcomes the recent publication of the European Commission’s EU Standardisation Strategy. We stand ready to support the Commission in leveraging global standards in support of a resilient, green and digital EU Single Market. We believe that this will be best achieved through a standardisation framework which encourages innovation, reduces fragmentation due to differing regional or national requirements, fosters scaling up and supports the deployment of products across the EU. DIGITALEUROPE has prepared an overall response to the Standardisation Strategy which is attached to this feedback. Regarding the proposed amendment to Regulation 1025/2012, we caution against the revision as the changes interfere with the governance rules of the European Standards Organisations, specifically ETSI. If the Commission aims to facilitate and streamline the timely delivery of harmonised European standards, the approach taken with this amendment is counterintuitive. In current ETSI procedures, the Commission and Member States approve and drive the standardisation requests themselves. The decisions made at ETSI about the approval of European standards are already taken on the basis of a national vote, safeguarding that EU principles are respected and upheld. The proposed amendment adds in an unnecessary and unwarranted extra procedural layer. No evidentiary record has been established by the Commission to justify this additional step: the proposal lacks proper impact assessment, preparatory studies or consultations. Further, the procedure could lead to additional delays instead, with more time spent on approving and starting new work items. As European industry struggles to deal with the lacking and delayed availability of published harmonised standards, more delays and complexity are less than ideal. Not all National Standardisation Organisations will have the resources to fulfill the additional tasks that would need to be assigned them under the new governance rules required by the Commission’s proposal, which would require their involvement in more stages of the process. Again, the consequence of these changes would likely be slowdown rather than a way forward. ETSI’s tremendous global relevance, in addition to its role as an ESO, is a valuable asset for wielding the influence of European standards internationally. Nations and industries around the world base their own standards, regulations, and products on ETSI standards. This occurs in large part due to the market relevance and industry-led nature of ETSI standards. Changing ETSI’s governance to reduce the involvement of industry in critical decisions risks weakening this global influence. Should the Commission have governance concerns, these are best dealt with via internal ETSI processes for rules amendments rather than changes to Regulation 1025/2012. DIGITALEUROPE consequently remains unconvinced that re-opening Regulation 1025/2012 prior to a more holistic review as announced in the Standardisation Strategy, following proper impact assessments and preparation, is a wise course of action. Together with these comments, please also find attached our comments on the Standardisation Strategy as a whole.
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Response to Promoting sustainability in consumer after-sales

5 Apr 2022

DIGITALEUROPE believes that consumers should be entitled to high-quality repairs that are safe, secure and reliable. Our members already treat repair, refurbishment and remanufacturing as part of their everyday business practice, performing millions of repairs annually. Their repair facilities across Europe help promote sustainable consumption, reduce the environmental impact of ICT products, deliver real benefits to consumers and create high-skilled jobs. These services are also integral to ensuring customer trust and satisfaction.The right to repair should: - Put consumer safety at the heart of the legislation, recognising that not all repairs can be carried out safely and successfully by consumers themselves. - Acknowledge the importance of existing manufacturer-led repair networks that provide consumers with convenient access to safe and effective repair options. - Ensure consistency with existing product-specific EU legislation that promotes repair. - Exclude business-to-business transactions from the scope. Businesses already have commercial repair arrangements that ensure sustainability whilst meeting their specific operational needs. -Recognise that repair is one of many tools to incentivise a shift towards a more circular economy. In some cases, replacement with a new or refurbished product might be more suitable.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

DIGITALEUROPE welcomes the European Commission’s revision of the Energy Performance of Buildings Directive (EPBD), published on 15 December 2021. Net-zero emission buildings require major changes in the way we design, build, operate and renovate buildings. Digitalisation has the potential to ensure a sustainable building sector in the European Union. The digitalisation of the entire building life cycle is critical to achieving Commission’s ambition to cut greenhouse gas emissions in the building sector by 60% by 2030. Digital technologies can accurately record, assess, simulate, measure, track and cut emissions over the entire life cycle of a building. More than before, the European Union’s quest for resilience in the energy market is and will continue to be a challenge. Digital can deliver alternative solutions for scarcity and decarbonisation. In our view, the requirements and incentives for the rollout of digital technologies through the proposal for a revised EPBD must go a step further. We believe that connecting digitally the various phases of the entire building life cycle for new and renovated buildings is key to achieving the roadmap for a sustainable building sector. Digitalisation enables stakeholders to design, build and operate high-performance buildings, conduct energy analysis at key project stages, reduce material waste and rework during construction by leveraging clash detection during design, reduce embodied carbon through design and material specification, plan for smart decommissioning and materials recovery, optimise HVAC system design and part load variable conditions, improve structural material efficiency, or optimise site planning among others. Many of the ways to reduce carbon emission and improve building sustainability occur during the design phase of a building. For example, by using recycled materials for a building – most heavily influenced during the architecture, engineering, and construction phases, energy requirements and emissions can be lowered by up to 90 percent. At the operation phase, building automation and controls constitute the brain of the building. They generate 30% energy savings on average, with a return of investment of 3 to 5 years. It supports factor screening across distinct areas that contribute to the energy performance of buildings, helping teams uncover the interventions or areas for investment with the highest impact. The proposal for a revised EPBD should also incentivise assessing and addressing lifecycle carbon emissions from buildings for all new and renovated buildings. To enable this transition, the proposal should serve to foster a data-centric approach. Data is paramount to describe the system and its use (i.e., master data/system data for Building Information Modeling (BIM), digital twins). Furthermore, we encourage institutional stakeholders to ensure consistency across all building-related provisions in the “Fit for 55” legislative package during the upcoming negotiations on the EPBD recast. We need a coherent and robust framework in place for buildings to meet the EU’s 2030 and 2050 targets.
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Response to European chips act package – Regulation

29 Mar 2022

DIGITALEUROPE thanks the Commission for the opportunity to provide feedback on the European Chips Act package. Our organisation represents multiple stakeholders across the semiconductor ecosystem, including in areas like chip design, chip production and chip usage. As the proposal for a Regulation on the Chips Act moves forward, the co-legislators should: a) Clarify the terms and conditions for the development and third-party access to the virtual design platform and the pilot lines in Pillar 1; b) Increase legal certainty in Pillar 2 by adding details on eligibility criteria for European first-of-a-kind semiconductor facilities and by foreseeing, in exceptional circumstances, ‘’continued operating support” for the facility; c) Designate a single, EU central entity for reporting requirements, rather than 27 different bodies, and remove confidential data from the scope of ‘’crisis stage reporting obligations’’ in Pillar 3; d) Boost the involvement of industry in the European Semiconductor Board and give them full membership rights of the Board’s sub-groups. We appreciate the opportunity to work closely with the EU institutions to ensure the most favourable business environment for semiconductor companies and the broader EU industrial base. In attachment, we include our position paper addressing key aspects in the overall package and offering more detail on concrete recommendations on the proposal for a Regulation.
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Response to Instrument to deter and counteract coercive actions by third countries

21 Mar 2022

On 8th December 2021, the European Commission published its proposal for a “Regulation on the protection of the Union and its Member States from economic coercion by third countries”, the Anti-Coercion Instrument (ACI) Proposal. DIGITALEUROPE recognises the instrument’s important objective of, in line with public international law, dissuading or offsetting coercive action, which can have a negative and sometimes even destructive impact on businesses. The European Union, as a staunch defender of the rules-based international trading system now under severe and increased strain, must ensure that its ACI bolsters its recognised position as a proponent of international rules. It is important that provisions are made to support businesses affected by coercion, safeguard them from adverse harm of countermeasures and that care be taken not to exacerbate international trade tensions. Here, the progressive and proportional approach, which prioritises diplomatic action and mediation, will be fundamental to the efficacy of the instrument. In the attached document, we set out some of the key considerations the decision makers, legislators and officials of the European Union must make in order to ensure discussions result in an effective instrument, fit for purpose and protective of European interests, workers, businesses.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The European technology industry provides the backbone for the future of the EU. Our sector will help the European Commission to deliver on each of its six core priorities including the European Green Deal and the Circular Economy Strategy. Technology provides the key to coming out of the Covid-19 crisis in a fair, resilient and responsible way, paving the way to full and sustainable economy recovery. DIGITALEUROPE stresses the global importance of RoHS which has been put in place or is being introduced in >50 countries outside the EU . It is a shining example of what the Commission and the Union want to achieve politicly and strategically in terms of global leadership and a global level playing field. The Directive has been highly successful in achieving its objectives on the environment and human health. It sets a worldwide reference for the digital technology sector and its complex global supply chain. DIGITALEUROPE and its members have been key contributors to the current Directive to everyone´s benefit. Among many other, we drove the establishment of the RoHS Umbrella Industry Project (“the Umbrella Project”) which assembles the world’s technical experts from more than 70 trade associations to foster cross-industry dialogue and alignment on possibilities for adaptation of RoHS Exemptions based on scientific and technical progress on an ongoing basis. Further, we have has also been heavily involved in the assessment and consultations undertaken to date as part of the Directive’s evaluation process, providing continual support to the European Commission and the Consultant(s) regarding key considerations and options to improve RoHS provisions and procedures. This legislative review is an opportunity to simplify and clarify certain aspects of RoHS which will help to achieve global harmonisation. From our perspective, some of these aspects could be improved by devoting more resources to EU RoHS and its processes. Indicative areas include the exemptions´ process and mechanism, establishing a periodical basis for the review of restricted substances, and fully applying the Commission´s Common Understanding paper between REACH and RoHS. Finally, we would also like to profit from this opportunity to draw your attention to the attached earlier DIGITALEUROPE´s contribution(s) to the assessment and consultations undertaken to date as part of the RoHS Directive’s evaluation process, including relevant considerations for further analysis and discussion. Recognizing the nature and breadth of this complex task, DIGITALEUROPE looks forward to continue contributing to the next stages of the Directive’s review, including the detailed Open Public Consultation, Impact Assessment, and beyond, working with all stakeholders to upgrade this important international legal framework. Annexes in attachment: (1) DigitalEurope initial views on the RoHS revision. Also available on: https://www.digitaleurope.org/resources/digitaleuropes-initial-views-on-the-revision-of-directive-2011-65-eu-on-the-restriction-of-the-use-of-certain-hazardous-substances-in-electrical-electronic-equipment-rohs/ (2) Joint paper on the Global Importance of RoHS
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Meeting with Bart Groothuis (Member of the European Parliament, Rapporteur) and Hanbury Strategy and Communications Limited

3 Mar 2022 · APA meeting on NIS 2

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

28 Feb 2022 · RED including datacentres - staff level

Meeting with Axel Voss (Member of the European Parliament)

16 Feb 2022 · Artificial Intelligence

Response to Review of ecodesign requirements for standby and off mode electric power consumption

4 Feb 2022

DIGITALEUROPE would like to provide the European Commission with the views of the ICT sector and our recommendations regarding the review of the Ecodesign Regulation for off, standby, and networked standby modes’ electric consumption. DIGITALEUROPE members remain committed to improving the environmental performance of electrical and electronic appliances and support the ambition of the European Commission to decrease CO2 emissions and deliver financial savings for European consumers. DIGITALEUROPE welcomes the revision of Regulation 1275/2008, and updating of the requirements for electrical product low power modes, but would like to raise the following concerns and formulate corresponding suggestions : 1. The scope needs to be clarified as for the reference to standards. The Commission could further clarify which products are included in scope (EMC Class B products intended for the residential environment) and address the issues created by the inclusion of low voltage power supplies. 2. DIGITALEUROPE invites the Commission to consider the requirements for Automatic Power Down (APD) - including the warning message, required default duration and opportunity for the user to adjust these settings - and to examine available data on this topic 3. DIGITALEUROPE suggests some changes as for the technical documentation and information requirements. 4. DIGITALEUROPE suggests that the Commission provides industry operators with clearer and unambiguous requirements via more detailed information in the regulation. Such approach would support both the industry and market surveillance authorities across the EU member states. 5. DIGITALEUROPE finally suggests further editorial changes towards a clearer draft text.
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Meeting with Nils Torvalds (Member of the European Parliament, Rapporteur)

31 Jan 2022 · RED III

Response to Common chargers for mobile phones and similar devices

18 Nov 2021

DIGITALEUROPE fully supports and shares the Commission’s ambition to reduce the amount of electronic waste and to increase consumer convenience. Our members have already shown their commitment to carbon neutrality and we recently launched a new tool for recyclers, the Information for Recyclers Platform (I4R), to collectively fight e-waste. Equally, our members are constantly innovating to create products and experiences that enhance people’s lives, often by making everyday tasks easier and more intuitive. This includes commitments to provide interoperable charging solutions based on the latest USB-technologies which have become the common charging solution across consumer mobile and electronics product categories. In our attached submission, we provide our feedback and suggestions on this Commission proposal for a Common Charger for electronic devices, amending the Radio Equipment Directive. Our approach aims to: 1) Maintain the NLF and implementing the necessary interoperability requirements for a common charging solution via a standardisation request, instead of written into the Radio Equipment Directive itself. 2) Develop guidance documents on product scope as well as more flexible arrangements to support unbundling.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital solutions play a key role in achieving the climate goals and allowing grids to absorb more power from renewable energy sources whilst also helping to balance supply and demand. Furthermore, DIGITALEUROPE’s members are developing and enabling significant volumes of renewable energy in Europe through their energy procurement strategies and intend to expand these efforts. In this context, we are taking the opportunity to comment on the proposal for the Renewable Energy Directive (RED III), with a focus on data centres. As European and world leaders in corporate procurement of renewable electricity, the ICT industry supports the provisions in Article 15, which strengthen the role of renewable Power Purchase Agreements (PPAs). Whilst we welcome the requirement for mandatory issuance of Guarantees of Origin (GO), we believe that article 19(2) needs further amendments to accommodate more temporal granularity in GOs. We welcome steps to address bottlenecks in renewable energy permitting processes. We also support the introduction of a coordination framework that will make it easier for businesses to make their waste heat available for district heating and other heating applications. We are sharing in attachment a more detailed response on the points above.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital plays a key role in enabling the green transition and achieving the ambitious climate goals. Studies show that carbon emissions of traditional sectors e.g., construction, manufacturing, energy, transport, or agriculture can be cut by a fifth by 2030 through digitalisation. This is ten times more than what the ICT industry produces. Hence, we welcome the opportunity to comment on the proposal for the Energy Efficiency Directive (EED), in particular on data centres. DIGITALEUROPE supports efforts to better measure the progress of the data centre sector towards climate neutrality. We also recognise the importance of monitoring and tracking the progress of all sectors towards sustainability goals. Our industry supports the “energy efficiency first” principle, as we have been taking solid steps towards minimising our own energy consumption. We are ready to collaborate to identify suitable data and sustainability indicators that data centre operators have the capability to report on, and which can help track progress towards climate neutrality. In addition, ensuring a level playing field for the data centre industry in the European Union that captures facilities of all sizes is essential. Therefore, we are recommending a more inclusive scope for reporting that encompasses all data centres above 100 kW. Further, we ask the Commission to recognise the sustainability leadership of the data centre industry. We seek a partnership with EU policy makers to communicate the strategic importance of data centres and their important contribution. Data centres are leading the transition to climate neutrality whilst enabling the decarbonisation of the European economy via digitalisation. We are sharing in attachment a more detailed response on the points above.
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Response to Improving access to emergency services through the single European emergency number ‘112’

29 Oct 2021

DIGITALEUROPE thanks the European Commission for the opportunity to provide feedback to the roadmap on ensuring effective access to emergency services. Ubiquitous, efficient and effective access to emergency services is critical to Europeans’ safety and security. From adopting 112 as the single emergency number, Europe gave a simple, standardised way for people to reliably access emergency services. Simplicity helps bolster adoption, and appropriate standards are indispensable for cross-functional systems to work. For this next chapter of emergency service access in Europe, we believe these same fundamentals – simplicity and appropriate standards – can accelerate next-generation capabilities for public safety answering points (PSAPs), strengthen the providers’ partnership with emergency services and advance innovation. Due to their technical characteristics, number-independent interpersonal communications services (NI-ICS) should not be mandated to provide access to emergency services and precise location information. Instead, we believe that the roadmap should start with a foundation in publicly available number-based interpersonal communications services (NB-ICS) that have control over the underlying network. We elaborate further on our feedback in the position paper attached.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

25 Oct 2021 · Preparation for a keynote speech on digital for the Green Deal

Meeting with Alejandro Cainzos (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

13 Oct 2021 · TTC

Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

5 Oct 2021 · Data flows, digital decade

Meeting with Axel Voss (Member of the European Parliament)

5 Oct 2021 · GDPR

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

8 Sept 2021 · Digital Decade

Response to Smartwatches and connected toys

27 Aug 2021

DIGITALEUROPE appreciates the opportunity to provide its feedback to the European Commission’s draft Delegated Regulation under Arts 3(3)(d)–(f) of the Radio Equipment Directive (RED). DIGITALEUROPEs response expands on, the scope of application, particularly with respect to the definition of ‘wearable device, the applicability of Art. 3(3)(d); and the necessary period for the delegated act’s entry into application. See attached document for DIGITALEUROPEs full response.
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Meeting with Kurt Vandenberghe (Cabinet of President Ursula von der Leyen)

26 Aug 2021 · The role of digital in Europe’s Green Deal ambitions

Response to Requirements for Artificial Intelligence

6 Aug 2021

Please find attached our detailed feedback, and a summary below. DIGITALEUROPE welcomes the European Commission’s legislative proposal for a Regulation laying down harmonised rules on artificial intelligence (‘AI Act’). We have been a key partner to EU institutions on AI topics for years, having notably participated in the work of the Commission’s AI High-Level Expert Group. We are committed to keep supporting EU policymakers and to actively participate in the policy and technical discussions surrounding AI. In the attached document, we present our initial assessment of the proposed AI Act, which will be complemented by an in-depth analysis with concrete recommendations at a later stage. Find below an overview of our initial findings: - The overall objectives and focus on high-risk cases is appropriate. - The scope needs to be further refined to ensure legal certainty. - Some of the requirements will be difficult to implement, especially if no harmonised standards are available. - The allocation of responsibilities between providers and users should be reassessed to best reflect the complexity of AI systems and their value chain. - Applying the EU product safety approach (New Legislative Framework) to AI will be challenging for most companies, particularly smaller software providers. - Effective safeguards and coordination measures would help mitigate fragmentation, regulatory divergence and differing implementation by national authorities. - High compliance costs and paperwork are expected, which would negatively impact businesses, particularly SMEs and start-ups. DIGITALEUROPE looks forward to working with the European Parliament, the Council and the Commission to discuss and assess how to best improve and implement the proposed AI Act, so that it achieves its ambition of stimulating the development and uptake of trustworthy AI, in line with European values.
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Response to Standardisation Strategy

5 Aug 2021

DIGITALEUROPE thanks the European Commission for the opportunity to provide input to this Roadmap on the upcoming European Standardisation Strategy. We have previously provided input and recommendations on the matter of standards in the past months, such as through our paper on the European Standardisation Strategy as well as our joint letters with other trade associations to the Council and Commission. Many of the points reflected in our submission were therefore already raised in these previous publications. Our main points can be summarized as: The European standardisation system and the New Legislative Framework underpin the EU Single Market and are essential to Europe’s competitiveness and innovation. The European Standardisation Strategy should urgently address the recent bottlenecks such as with the interface between the Commission, European Standardisation Organisations and HAS consultants. Efficient development and high quality of standards can go hand in hand. The goal of speeding up the standardisation process should not come at the cost of safety, quality, innovation, or lead to the use of less inclusive and more top-down and prescriptive instruments. The best way for the EU to set an international example is through the support of active European participation in standardisation on the global stage, in international standard developing organisations, such as ISO and IEC, global fora and consortia. Stakeholder interaction, for example through the Multistakeholder Platform for ICT Standardisation, remains key and plays an essential role for dialogue and bringing in international perspectives. DIGITALEUROPE supports measures to bolster the inclusiveness of the European standardisation system, in particular to ensure the involvement of SMEs, civil society organisations and industry. Inclusiveness and stakeholder collaboration can also be aided by the digital transformation of standards development processes, such as through virtual or hybrid meetings when possible and useful. The European Standardisation Strategy should promote and encourage standards awareness among various communities, including policy-makers and regulators. Our detailed comments can be found in the attached paper.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

20 Jul 2021 · Discuss their involvement in the Industrial Forum, digital technologies across several ecosystems, and the monitoring of digital technologies uptake.

Response to Addressing distortions caused by foreign subsidies

15 Jul 2021

DIGITALEUROPE welcomes efforts by the European Commission to address the distortion caused by foreign subsidies in the Single Market, which may provide certain businesses an unfair competitive advantage in the global market. Any new instrument should be focused on identifying, assessing, and mitigating distortion caused specifically by subsidies while remaining proportionate, fair and non-discriminatory. DIGITALEUROPE believes that several components of the proposed Regulation on foreign subsidies require further consideration in an effort to ensure that the initiative efficiently tackles foreign subsidies that are most likely to distort the Single Market, avoids unintended consequences, and maintains workability. We are providing our detailed position in the attachment.
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Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager)

6 Jul 2021 · Green deal

Meeting with Alina-Stefania Ujupan (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

2 Jul 2021 · Digitalisation of health sector

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

DIGITALEUROPE welcomes the possibility to provide feedback on the European Commission’s inception impact assessment for a Data Act and a revision of the Database Directive. Find attached all our comments. We also plan to reply to the public consultation. - Scope: The different notions applicable to the Data Act will need to be carefully defined. For instance, the delineation of ‘data’ will be key: any future legislation should be clear whether its provisions address raw and/or processed data, personal and/or non-personal, the ownership status, etc. What is considered as ‘IoT’ should also be thoroughly defined, and the notion of ‘smart contracts’ should be adequately conceptualised. - Data sharing: Voluntary, cooperative solutions are preferred for any exchanges of data involving the private sector, whether between companies (B2B) or towards the public sector (B2G). Voluntary solutions ensure a swift implementation of data sharing practices benefitting all, and they preserve contractual freedom of companies. This guarantees steady industry investments in innovation to collect and use data, creating growth. --- B2G: Any EU framework for business-to-government data sharing should favour partnerships and agreements with companies. Any obligations would have to be duly justified and limited to exceptional circumstances. Clear and well-delimited definitions of ‘public sector’ and ‘public interest’ would be key. It is also of utmost importance that such framework prevents any potential data breaches, IPR and commercially-sensitive data leaks, administrative burden and unfair competition. --- B2B: Companies are already and increasingly actively sharing their data. Further development and uptake of international standards and good practices can facilitate existing data arrangements. Any framework leading to potential data sharing rules should be aligned with EU competition law. Potential obligations should only be considered when market failure has been proven in a given sector, and that all other solutions failed. - Cloud portability: The SWIPO process successfully developed cloud switching and porting codes of conduct for the industry. As the SWIPO codes were only finalised in 2020 and will likely be updated over time, we believe that it is too early to fully assess their impact and effectiveness, and decide on potential legislative actions. - Portability for individuals: While we fully support the development of data portability in accordance with article 20 of the GDPR, existing standards and techniques may not be applicable to the wide range of IoT devices and related services mentioned in the roadmap. Several industry initiatives are working towards that goal, so they should be recognised and assessed before any requirements are considered. --- Additionally, the roadmap refers to “real-time portability”, a concept that would actually necessitate further interoperability solutions to ensure that privacy is preserved, and would go beyond the scope of the portability right under the GDPR. - International data access: While we recognise the need to provide clarity regarding government data access requests, we believe that an intergovernmental solution stemming from existing international agreements would be most appropriate. Currently, data access is being discussed as part of the eEvidence and the DGA negotiations, as well as in international settings through the OECD, the WTO and the Budapest Convention. Setting new provisions in different pieces of legislation would increase legal uncertainty for both cloud service providers and users. --- International access is also heavily scrutinised as part of the review of data transfers mandated under the CJEU’s Schrems II ruling. This was recently complemented by the adoption of new standard contractual clauses (SCCs) by the European Commission as well as recommendations on supplementary measures adopted by the European Data Protection Board (EDPB).
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Meeting with Claude Bocqueraz (Cabinet of Commissioner Mairead Mcguinness)

21 Jun 2021 · Digital Finance Package DORA

Response to Declaration of Digital Principles

10 Jun 2021

Our DIGITALEUROPE vision In our 2019 manifesto, we set out our vision for a stronger digital Europe. European citizens are at the centre of our vision. We outlined 7 key areas for action, under the heading D-I-G-I-T-A-L. Building on these seven areas, we suggest the following principles. Digital Single Market • Every European citizen should have the opportunity to launch a digital business. • All companies should be able to sell their goods and services anywhere in Europe under the same rules, both offline and online. Inclusion • Every European citizen should have the right to digital education. Citizens should have access to digital skills training throughout their lives – at school, at work, or in the community. • Digital should promote a non-biased and inclusive society. • All public services should be available in a digital format – safe, accessible and integrated – ensuring special attention is given to the elderly and people with disabilities • Everyone has the right the reap the benefits of the digital age and should have access fast and secure connectivity regardless of location. Green growth • Every European citizen should have access to digital solutions, devices and services that enable them to reduce their carbon impact, such as home smart meters. Innovation • Public and private investments in innovation should be promoted and enhanced to ensure that innovative technologies are available to provide Europe’s people with competitive jobs, better health, and better public services. Trust • New and disruptive technologies like artificial intelligence should be designed with humans in mind – (see ethics principles for trustworthy AI below) • Every European citizen should have access to a secure and trusted online environment. Agile and mission-based policy • The regulatory framework should be fit for purpose and ensure citizen protection and in particular take care of the most vulnerable. • The digital policymaking process should be open, inclusive and transparent. Leadership • Every European citizen should have access to a secure online environment, no matter in which country the website is based. • Europe should continue to be seen as a leader in promoting and enhancing the just transition and citizen protection to ensure the digital transformation truly benefits all. The ethics principles for trustworthy AI The Commission’s stated aim with this part of the Communication is ‘to set the European standard for ethical and fundamental values and human rights in the digital space’. We believe that there is no need to reinvent the wheel here. The Commission already launched a lengthy – and fruitful – process involving all types of stakeholders as part of its High-Level Expert Group on Artificial Intelligence. One of the deliverables of that group – which included representatives of consumers, businesses, academics and trade unions – was to create seven ethical principles for artificial intelligence. We believe that these seven principles are an excellent base for the digital charter. Artificial intelligence is but one of numerous technological trends that is already having an enormous impact on our lives. It may be new, but the social questions that it raises are not unique. Due to the inclusive process which led to their inception, those seven principles also have legitimacy across a wide range of stakeholders. The challenge now will be to take these seven principles and provide descriptions and examples that are relevant across all digital technologies. The Guidelines put forward a set of 7 key requirements that AI systems should meet in order to be deemed trustworthy. A specific assessment list aims to help verify the application of each of the key requirements: • Human agency and oversight • Technical Robustness and safety • Privacy and data governance • Transparency • Diversity, non-discrimination and fairness • Societal and environmental well-being • Accountability
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Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

Future Ecodesign Implementing measures that will be developed as an outcome of the 2020 2024 Ecodesign and Energy Labelling Working Plan will play a key role in the establishment of a successful Circular Economy in Europe. It is extremely important that these implementing measures (IM) are drafted based on the product specific attributes and recognising the objective of circularity. In this view, Industry DIGITALEUROPE welcomes the opportunity to provide feedback to this Working Plan and its roadmap. Please see our recommendations in the attached document.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

DIGITALEUROPE supports the ambition to manage substances to the best possible extent in order to protect human health and the environment. The REACH Regulation is a fundamental piece of legislation for the management of chemicals both in the EU and globally and across many industries, including the digital one. Therefore, DIGITALEUROPE welcomes the opportunity to provide input to the Regulation revision. See attached paper for our recommendations.
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Response to Online and distance learning in primary and secondary education

11 May 2021

We appreciate the opportunity to give feedback on a Proposal for a Council Recommendation on online and distance learning in primary and secondary education. The use of digital tools and online video platforms in education have enabled pupils and teachers to stay connected around the world during the COVID-19 lockdown. Hybrid teaching methods, mixing in-person and remote learning, will become increasingly common as their benefits emerged from this crisis. Yet, the pandemic also exposed existing areas which must be improved to accelerate the digital transformation of education. The Recommendation should include a focus on three important areas: 1. Teacher professional development: today less than 40% of teachers feel ready to use digital technologies. We must empower them not only to carry on their work during lockdowns, but also to inspire their students in integrating technology into their everyday life and become innovators themselves. Teacher training is a precondition for more digitally-oriented school curricula including the basics of computational thinking and the development of assessment/feedback methods tailored to blended learning. It should focus on a blended learning experience that includes not only readiness and enablement for online teaching and e-learning, but also teaching across online and offline dimensions (blended, hybrid pedagogies and methodologies) allowing for student’s creativity and actual and practical learning how to use the digital tools. Finally, teachers need more support both for pre-service and in-service. 2. Digital equipment and infrastructure: NextGenerationEU must invest in modern equipment and high-quality connectivity to accelerate digital uptake. It is key to bridge the technology gap for the least advanced Member States without losing sight of increases in investments in those with fairly good infrastructure. Adequate network infrastructure is key to meet digital education connectivity needs and make our educational systems more inclusive and flexible. Connecting our schools to high-quality secure broadband and creating the right digital infrastructure will allow teachers to use expanded educational materials, access e-learning, and collaborate from different locations. Importantly, these investments will also directly benefit people living in remote rural areas, allowing them to access the best teaching available regardless of their location. Devices for education need to be better understood: looking into different device configurations according to learning scenarios, student age, etc. rather than a one size fits all approach. 3. Partnerships: collaboration is vital for the success of online and distance learning. The Recommendation should foster the creation of partnerships between private sector, national and local authorities, training and education providers, as well as NGOs. They should focus on issues like the role of digital technology as infrastructure (enabler) and as curriculum to help develop talent who will not only be able to use the technology but also create new solutions. The COVID-19 crisis gave momentum for partnerships. For instance, DIGITALEUROPE members have collaborated with many of these entities, including Ministries of Education, to develop ad-hoc distance learning modules, toolkits and deployment/adoption strategies for education systems. Finally, we also caution against significant decreases/discrepancies by country in education infrastructure or training unit costs eligible for support to less developed Member States. Such decisions would be especially detrimental for advanced technology innovation in education infrastructure, training and employability programmes. They would prevent learners in these countries from accessing the best-in-class technology, knowledge and skills, thereby delaying their economic convergence with the other EU territories.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

4 May 2021 · Sustainable Corporate Governance initiative

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton), Pauline Weinzierl (Cabinet of Commissioner Thierry Breton)

4 May 2021 · Transatlantic Relationship

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

13 Apr 2021 · Speech at Working Group for Digital in the EU Green Deal

Response to Enhancement of European policy on critical infrastructure protection

8 Apr 2021

The changing nature of the threat landscape requires better protection and more investment in the EU’s resilience capacities to secure our critical infrastructure. DIGITALEUROPE welcomes the Commission’s effort to strengthen the resilience of critical entities across the EU by developing and updating relevant legislation. The proposal for a Directive on the resilience of critical entities (RCE Directive) expands both the scope and depth of the 2008 European Critical Infrastructure (ECI) Directive. The following elements should be addressed during the legislative process: Requirements regarding physical non-cyber protection under the proposed RCE Directive should be more clearly separated from requirements regarding cyber protection under the revised Directive on Security of Network and Information Systems (NIS2); The RCE Directive should not introduce additional requirements or obligations on digital infrastructure, which is already covered exhaustively under the NIS2; Clearer and more transparent supervision practices should be introduced; and Better harmonisation can be achieved between the RCE proposal, the NIS2 and the proposed Regulation on digital operational resilience for the financial sector (DORA), including in terms of regulatory cooperation, implementation timelines and reporting thresholds. Please see the attached DIGITALEUROPE response for more details.
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Response to Instant Payments

7 Apr 2021

DIGITALEUROPE believes the baseline policy option detailed in the inception impact assessment is the most suitable to advance instant payments today in Europe. At this stage, monitoring the market evolution and assessing the effects of voluntary efforts is the most sensible decision to foster the growth of instant payments, while the industry works to address their challenges. Please see attached our response.
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Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

7 Apr 2021 · Digital decade, Cloud, AI, semiconductors (virtual meeting)

Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Mar 2021

The Digital Services Act (DSA) proposal marks an important update to internet regulation in Europe. DIGITALEUROPE's membership supports the European Commission's ambition to strengthen the Single Market for digital services in the EU. Clarity is needed on the role and responsibilities of online intermediaries to address the problem of illegal content online and help boost trust in the internet. Internet regulation is a balancing act between protecting fundamental rights like freedom of speech on the one hand, and preventing illegal and harmful activities online on the other. In the paper attached, DIGITALEUROPE proposes some constructive suggestions to the EU institutions to help improve the proposed DSA. -We welcome that the proposal preserves the eCommerce Directive's core tenets, which have allowed Europe to develop and enjoy a vibrant internet economy. Maintaining principles such as limited liability, no general monitoring, and the country-of-origin is key to the continued innovation and growth of these digital services in Europe and will be crucial to a rapid economic recovery. -We agree that the DSA needs to clearly distinguish between the liability and responsibility of online players of all sizes and risk profiles. The law should uphold the foundations of the tried and tested eCommerce regime where liability should be based on actual knowledge and failure to act. Liability should not result from illegal content of which the platform is not aware. -We welcome that the DSA recognises that harmful (but legal) content requires a different set of provisions than illegal content. Harmful content is contextual, difficult to define, may be culturally subjective and is often legally ambiguous. -DIGITALEUROPE strongly believes that important definitions, such as what constitutes a very large online platform, should not be left to delegated acts. All relevant stakeholders should be given the opportunity to contribute to developing definitions and methodologies which can significantly impact the implementation of the law. -We believe the DSA due diligence requirements such as trusted flaggers, trader traceability, and transparency mechanisms, if developed in a proportionate and workable way, will provide opportunities to enhance collaboration among all stakeholders leading to a safer online environment. -We welcome the formalisation of rules on notice and action mechanisms across online intermediaries. This formalisation will facilitate the review process and expeditious action on illegal content and goods. -We support providing stakeholders with meaningful transparency about content moderation and enforcement practices. However, it will be important that transparency measures in the DSA ensure that users' privacy is protected, bad actors cannot game the system and that commercially sensitive information is not disclosed. -DIGITALEUROPE has concerns about the feasibility of the implementation timeline. We would recommend a 12 to 18 month period to leave sufficient time to build and implement new processes We look forward to working with all stakeholders to create a framework that improves trust in digital services, unlocks innovation and reduces the prevalence of illegal and harmful content online.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The revision of the Energy Performance of Buildings Directive is a great opportunity to lay the foundations for deep, digital and future-ready renovations of the EU’s buildings stock. The potential is obvious as buildings now contribute to about 40% of EU energy consumption and 36% to greenhouse gas emissions. DIGITALEUROPE welcomes the revision and recommends a new approach to put digital at the centre of the Directive.
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Response to Revision of the NIS Directive

18 Mar 2021

The review of the Directive on Security of Network and Information Systems (NIS2) is an essential step towards a more resilient Europe, ensuring state-of-the-art risk management of current and emerging cyber threats to vital sectors of the EU economy and society. One of the goals of the 2016 NIS Directive was to harmonise Member States’ cybersecurity protection initiatives and to boost the EU’s overall level of cybersecurity. Despite attempts to achieve this goal, there remain variances and fragmentation standing in the way of a single European approach. This is compounded by increased complexity in the interplay between the NIS and other EU laws. These are among the areas for improvement that should be addressed as primary objectives of the review. The revised NIS should: Provide greater clarity on the scope of the proposal, particularly with respect to the definitions of certain categories of ‘important entities,’ as well as the territorial jurisdiction for enforcement. Ensure Member State harmonisation and regulatory consistency. There remains a pressing need to enhance consistency and reduce Member State fragmentation. The NIS2 should also take into consideration, and align with, other regimes and legislative developments at EU level. Streamline the reporting requirements and maintain proportionate obligations for entities, notably preserving the voluntary nature of certification obligations. Foster international alignment with standards and existing industry best practices in the area of risk management, especially in relation to supply chain security assessments, information sharing and vulnerability disclosure. Promote and ensure consistent, predictable enforcement at Member State level, with proportionate punitive measures. More information and details can be found in the attached DIGITALEUROPE submission.
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Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

18 Mar 2021 · A call with DIGITALEUROPE on upcoming legislation on child sexual abuse

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

17 Mar 2021 · Digital transformation and eprivacy

Meeting with Valdis Dombrovskis (Executive Vice-President)

12 Mar 2021 · Recovery and Resilience Facility - focus on digital transition and national reform plans; Trade Policy Review and digital trade, also - international data flows and Digital tax; EU-US relations for trade on technologies.

Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

Following the 2008 crisis, the EU launched its Europe 2020 strategy to overcome the imbalances and weaknesses exposed by the financial collapse. It prioritised economic coordination, set clear targets and responsibilities for Member States, created a substantial institutional mechanism to help them get there, and gave it just enough teeth to keep them on track. The COVID-19 crisis has different origins, but similarly, it has revealed imbalances and weaknesses, notably in our digital skills and infrastructure. As in 2010, now is the time to think big and set ourselves up for the crucial decade to come. By calling the next ten years “the Digital Decade” and launching this consultation, President von der Leyen has shown the political will necessary to build ‘a stronger digital Europe’. The challenge now lies in matching that ambition with concrete aims and the means to reach them. Digital technologies have proved essential during the crisis, yet the pandemic has exposed the gaps in the system. Like back in 2010, we must use this crisis as an opportunity: -We must set ambitious targets for digital transformation and stick to them. -We must invest wisely and link the funds to national reforms and the EU’s wider digital agenda. -We must coordinate our efforts and multiply the opportunities for pan-European collaboration. We in DIGITALEUROPE have been calling for the above efforts since our manifesto in 2019, before the crisis. We are therefore uniquely placed to help set the agenda: -Although the timeframe needs to be extended to 2030, our Vision for 2025 is a model for what a stronger digital Europe should look like. -Our KPIs can act as inspiration for the common digital targets. -Our Investment Plan can help direct the funding to those multi-country projects that will deliver the most bang for our buck. -Meanwhile, as a leading member of the Commission’s High Level Expert Group on Artificial Intelligence, we call on the Commission not to reinvent the wheel for its proposed Digital Charter. A cross-sector group of civil society organisations already agreed on seven principles for ethical AI, which should serve as a basis for any broader digital charter. Regarding the Digital Compass and its aim to better monitor investments and funds, we must learn the lessons of the recent past. Although it is too early to tell for sure, it seems that the political boldness of the Recovery and Resilience Facility might not deliver on its promise, at least in part due to insufficient governance. Despite the unprecedented step taken to pool common debt at EU level, the investment projects identified by Member States too often follow narrow national or regional priorities; they lack a European vision. The process is rather untransparent and the draft plans we have seen are unfortunately not clear or coordinated enough. If we are serious about reaching our digital decade goals and encouraging transformational pan-European digital projects, we must decide what kinds of institutional structures are necessary to get us there. Formed from the ashes of the 2008 crisis, the European semester process could serve as a model for national and EU coordination for today’s moment of need. To realise the promise of the Digital Decade, we will need a strong Commission, equipped with the necessary funding, tools and personnel. Now, as then, we must turn the crisis into an opportunity for Europe. And finally, on the international dimension. DIGITALEUROPE fully agrees that “the EU can only success in its digital transformation if it builds a Digital Decade in an outward-looking manner”. The Commission’s Trade Policy Review communication noted that already by 2024, 85% of the world’s GDP growth is expected to come from outside the EU. If we want our companies to grow and our citizens to benefit, the EU must remain open to international trade and continue to have an open market based on reciprocity and a level playing field.
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Response to Micro-credentials

5 Mar 2021

Up to 59 million jobs in Europe are at risk due to COVID-19. Large-scale upskilling and reskilling efforts can help to minimise the impact of job losses. Micro-credentials can help these activities by lifting individuals’ employability while creating flexible and inclusive learning paths to accommodate an increasingly diverse population. Just in 2019, there were more than 820 MOOC-based micro-credentials available world-wide. Education technology companies, online learning platform providers and many other businesses contributed to a great share of those. Comparing to conventional degrees and certificates, micro-credentials offer shorter, more targeted and flexible ways to fill the gap between academic programmes and skills required in a fast-changing labour market. 80% of individuals in OECD countries found professionally useful the non-formal education and training activities they undertook. To drive the successful uptake of micro-credentials, we need a clear definition of micro-credentials that will forge a more common and clearer understanding of the content and quality of these new learning possibilities, their different digital or physical storing options, as well as usage modalities. We welcome the Commission’s recent effort to define the concept of micro-credentials in its recent “European approach to micro-credentials” publication, and look forward to helping it to officially adopt a definition in 2022. We also strongly believe the success of this initiative will depend on: - A focus on minimum levels of objectivity and standardisation in the skill certified by micro-credentials; - Clear differentiation between traditional degrees and micro-credential certificates delivered upon completion of a learning programme; - Quality assurance, through the establishment of an EU register of trusted issuers open to non-formal education providers, like industry, regardless of their headquarters’ location; - Interoperability across learning management systems and promotion of learning content standards; - Financial support to leverage content from various micro-credential providers; - A future-proof European Digital Credentials Infrastructure (EDCI) envisaging badging/recognition of skills validated in professional networking online platforms. Attached are included our recommendations on micro-credentials in more detail.
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Meeting with Axel Voss (Member of the European Parliament)

4 Mar 2021 · GDPR

Response to Digital Operational Resilience of Financial Services (DORFS) Act

15 Feb 2021

The draft DORA regulation is an opportunity to further accelerate the digital transformation of finance and show the EU’s global leadership in defining a first-of-its-kind framework for outsourced ICT operations in financial services. Yet, unclear and potentially overlapping provisions in the existing draft risk to dramatically hamper the achievement of these goals. It is essential that the Council and Parliament work on the text to substantially improve the ability of DORA to accelerate the deployment of digital technologies for finance. We urge to focus on the following aspects moving forward: - An efficient regulatory framework and material consistency with the NIS Directive: The EU needs an efficient and (as much as possible) harmonised regulatory regime ensuring consistency among the different legislative initiatives on resilience and security. DORA must not unnecessarily introduce duplication, complexity, or legal uncertainty, especially since the functioning of the proposed multi-layered Oversight Framework is already complex. In particular, the proposal for a revised NIS Directive has introduced substantial overlaps with DORA which makes it crucial that policymakers design a clearer hierarchy between DORA and NIS Directive for ICT providers. - Proportionality: This should be a unifying element across DORA’s provisions. Elements like scope, powers of authorities and requirements for outsourcing to ICT providers should all be proportional to the intended goal of enhancing digital operational resilience and trust in finance as well as be proportionate to the identified risks. The oversight framework must be based on the materiality and importance of the outsourced services, not the type or scale of the outsourcing provider. Digital services which do not create critical operational and/or outsourcing dependencies (such as digital marketing and advertising) should be clearly exempted from the scope of the oversight. This is fundamental for the concrete viability of DORA and its adaptability to a fast-evolving technology context. Size and scope of penalties and oversight fees should be also proportionate to the business of provision of the critical services to the EU financial entities. - The ability to rely on third-country technologies: DORA must avoid limiting the technology choices available to EU financial entities on the basis of the geographical profile of the ICT provider. The material gains in terms of customer well-being and improved security of ICT operations from the deployment of best-in-class digital technologies should remain the DORA’s prevailing goals. Existing provisions would jeopardise this and should be swiftly changed. - Oversight due processes: There needs to be a transparent process of consultation and - where needed - appeal of recommendations between the Lead Overseer and the designated Critical Third-Party Providers (CTPPs), as well as proportionate safe harbour protections for the providers’ customers (financial entities and their customer data) so that privacy, security and integrity of the provided services is not unintentionally compromised while providers are complying with their obligations under the oversight. We are concerned over the lack of technical details on how the oversight framework would operate - especially with regards to innovative multi-tenant cloud environment. It is also key to streamline the oversight at the EU level as much as possible, and to ensure the NCAs are not taking any unilateral actions against the CTTPs and their customers without coordination and explicit agreement from the Lead Overseer. - ICT innovation: DORA should stimulate, not impede innovation. We call on EU institutions to put in place a framework encouraging the adoption of technologies such as cloud. Technology-neutrality and the creation of a clear label of trust for the ICT providers in scope are essential to achieve that. We provide our specific recommendations in the document attached.
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Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

DIGITALEUROPE welcomes the proposal for a Data Governance Act (DGA) and the possibility to provide feedback to the Commission. We are still finalising an in-depth analysis, but we already share below a set of early comments. Scope: The scope of the DGA needs to be clarified. ▪ Categories of publicly-held ‘protected data’ should be further defined, while considering the risks for citizens’ privacy and industry competitiveness with any ambiguity in the wording (cf. article 3) and on how such data can be used. ▪ Article 9 and recital 22 should be refined to ensure that the proposal would not apply to a wide range of data sharing services which would be negatively affected by the proposed measures. We understand the Commission’s intent was only to encompass a selected group of services. ▪ Potential fine-tuning and insertion of new definitions in article 2 could help clarify the scope. Alignment with EU law & other initiatives: The relationship with the wider legal framework (GDPR, Free flow of non-personal data regulation, Open Data directive) needs to be further explained. Related non-legislative initiatives should also be taken into account (e.g. data spaces, GAIA-X). Re-use of protected publicly-held data: While allowing the re-use of data beyond the scope of the Open Data Directive is very promising, which kind of data is concerned needs to be carefully assessed. The re-use of personal data and commercially-confidential data presuppose the creation of a robust framework preventing any misuses (averting data breaches, etc.). ▪ It is crucial to ensure that companies’ data is not shared with competitors. The provisions should not cover data licensed to government bodies by commercial actors and restrict choice of contracting terms, as it would disincentivise public-private collaboration. Requirements for data sharing services: Some obligations laid out in chapter 3 may negatively affect a significant number of companies (SMEs to larger firms) if the scope is not carefully defined. Innovative companies deploying their own data sharing platforms, to serve their customers or to exchange data with their suppliers, may be impacted. Such platforms providing value-added services would have to consider drastic changes to their functioning and business models, potentially terminating their activities. We believe the scope and requirements should be clear and proportionate to ensure legal certainty. Data altruism: The proposed framework should make possible for companies to access data donations from citizens if the data is collected for “general interest” objectives (e.g. related to healthcare, environment, mobility, etc.). A definition for the concept of “general interest” should be inserted, and include the support to research and innovative uses, including the development of new services and products by companies. National bodies: The framework of competent authorities set in the proposal can be simplified, ensuring a better access for stakeholders wanting to re-use data or enforce their rights, and reducing potential costs for Member States. The concept of single contact points briefly mentioned in the DGA should be extended and leveraged. EU harmonisation: The proposal offers considerable flexibility for Member States to implement the DGA. To enhance the Single Market, a unified implementation of requirements is needed (including data access conditions, penalties, etc.). European Data Innovation Board representation: The structure of the Board should be representative of the diverse data economy ecosystem. Industry stakeholders should be able to regularly participate in a formal setting in the activities of the Board. International data transfers: Further clarity is needed on the different provisions to avoid potential restrictions on international transfers of non-personal data (e.g. type of data to be restricted, process for determining adequacy of non-EU countries).
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Meeting with Mariya Gabriel (Commissioner)

4 Feb 2021 · Innovation, Presentation of the Future Unicorn Award at Masters of Digital 2021

Response to A European Health Data Space

3 Feb 2021

The EHDS Inception Impact Assessment sets out ambitious objectives linking together the need for secure and trusted health data sharing for what will be the creation of the first European data space. The EHDS has the potential to be the single market for digital health products and services, and the global centre of development of secure AI powered digital health. Indeed, the EHDS will be a prerequisite for Europe to lead the digital transformation of health and care. DIGITALEUROPE supports these initiatives. We need decisive EU action to harmonise conditions for health data processing for primary and secondary use across Europe, linked to meaningful investment. We would like to highlight the key recommendations from our papers on health data and an increased role for AI in health. For ease of reference, we have compiled these recommendations into one document.
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Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Mairead Mcguinness), Florian Denis (Cabinet of Commissioner Mairead Mcguinness)

29 Jan 2021 · Digital Finance Strategy. Retail Payments Strategy.

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

15 Jan 2021 · Meeting with DIGITALEUROPE’s Working Group on Digital Skills.

Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Please find our attached our contribution.
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Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

Digital has enormous enabling potential to facilitate the EU’s transition to a low carbon circular economy. Digital technologies have the potential to enable a 20 per cent reduction of global CO2 emissions by 2030, in particular in traditional sectors like energy, transport, construction, agriculture and manufacturing . That is ten times more than what is produced by the digital sector. To further leverage this enabling potential and promote the uptake of these technologies, a clear and science-based investment framework is needed. This framework should not only promote the uptake of currently existing technologies but should also be future proof and encourage the development of new innovative solutions. DIGITALEUROPE welcomes the opportunity to comment on the draft delegated acts on climate change mitigation and adaptation under the EU Taxonomy Regulation. The EU taxonomy provides a great opportunity to leverage the enabling potential of the ICT sector. However, the current draft delegated act does not truly grasp this potential. The way digital is covered in one single section of the delegated act also ignores the digital transformation of many industries. Digital should not only be covered in one section of the delegated act. Concretely, we recommend for this purpose the following improvements are made in the draft delegated act: 1. Modify the proposed criteria to qualify ICT as an enabler (section 8.2) and future technologies (section 3.5) 2. Provide greater predictability and flexibility to data centres seeking to meet the taxonomy under section 8.1 Please see the attached document for further details and concrete recommendations.
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Meeting with Eszter Batta (Cabinet of Commissioner Thierry Breton)

15 Dec 2020 · Standardisation strategy

Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data Protection Regulation (GDPR). In line with the Schrems II ruling, we also welcome the important recognition that companies should be able to take into account the specific circumstances of transfers and practical experience of transferring data to third countries when assessing whether SCCs provide appropriate safeguards. In our submission we highlight a non-exhaustive list of elements where the new SCCs could still be improved to provide more clarity.
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Response to Commission Implementing Decision on standard contractual clauses between controllers and processors located in the EU

10 Dec 2020

DIGITALEUROPE appreciates the opportunity to contribute its input new set of standard contractual clauses (SCCs) between controllers and processors located in the EU published by the European Commission. Contract negotiations following the General Data Protection Regulation (GDPR) have centrally revolved around defining clear tasks of the parties, as separate or joint controllers or processors; as in any other contract, such tasks determine responsibilities and liability. Because of the cost potentially associated with liability in relation to data subject rights and particularly data breaches, we observe that parties often try to pass on liability by negotiating a role (as processor or separate/joint controller) and subsequently attaching tasks or responsibilities to such role that may not actually fall within it. In this context, a correct application of the requirements under Art. 28 GDPR in the new SCCS is therefore especially important to avoid uncertainty in the market and ensure a correct assignment of responsibilities. In our submission we highlight a non-exhaustive list of elements where the SCCs could be improved to provide more clarity.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

DIGITALEUROPE thanks the European Commission for the opportunity to provide feedback on the Roadmap for the New Legislative Framework (NLF). We are mindful of technical developments affecting the characteristics and deployment of products and of evolving business models bringing them into the single market. Accordingly, we concur that aspects of the NLF should be assessed. The NLF, including the underlying New Approach, have formed the foundation for a successful and highly respected product regulatory system that has set a much-emulated example for other countries. Its core concepts and processes must be carefully preserved and extended only as needed to address the new product and business ecosystems. In particular, legislative harmonisation should be limited to the essential requirements and the technical specifications for meeting the essential requirements should be laid down in voluntary harmonised standards, consensually developed by technical experts representing all stakeholders in the ESOs, which can be applied alongside the legislation. Modifications to related harmonisation legislation should proceed only after any adjustments to the NLF have been completed and must bring them fully into alignment. We believe that the assessment focus should be widened: 1. Market Surveillance provisions should be excluded as explained, but elements of legislation which impinge on or interact with NLF concepts must be included within scope of this assessment to allow holistic adjustments to be achieved. 2. The concepts of economic operators and their roles are vital and while the framework might benefit from extension, the existing concepts should be adapted only where they demonstrably no longer fit for purpose. Obligations must align with the reasonable capability of operators to fulfil them without impeding innovation. 3. The relationship between cited harmonised standards and EU law which, as in the opinion commissioned by Germany’s BMWi*, we believe to have been over-interpreted and needlessly generalised should be clarified and stabilised. 4. The NLF should preserve the New and Global Approach in which technical requirements are embedded in harmonised standards, not in legislation or associated legal instruments. Regarding the six matters on which the assessment is proposed to focus DIGITALEUROPE’s views are: i) For products whose characteristics may be changed through their lifetime, any new roles and obligations must attach to those who bring those changes to the product, and must apply only where new or extended risk is introduced or the use of the product is changed. The existing NLF provisions are sufficient for remanufactured product outside the above category. ii) The toolbox of conformity assessment procedures is adequate for addressing the categories of products presenting various levels of risk. The harmonisation legislator does have the choice of which should be available and the circumstances under which these are applicable. The NLF should not be adjusted to solve problems not directly attributable to it. iii) We are not aware of any issues concerning the competence of notified bodies and so offer no recommendation. iv) As per iii) above. v) With pervasive use of digital technologies across Europe it is now appropriate to prepare for the future by enabling the inevitable transition to electronic product marking such as CE marking and delivering product information in digital formats. vi) The NLF addresses the ongoing non-crisis functioning of the market and should not be re-engineered to additionally provide for exceptional situations that cannot anticipated and therefore pre-programmed for. Where crisis intervention is required this should be achieved through time-limited case-by-case overrides. * Legal Opinion On the European System of Harmonised Standards by www.redeker.de of August 2020 for the German Federal Ministry for Economic Affairs and Energy ("BMWi"), Berlin, August 2020
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Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

20 Nov 2020 · Europe’s  digital  transition

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Nov 2020 · DIGITALEUROPE holds a high-level informal dialogue on industrial policy with ten senior executives of the Digital Manufacturing Executive Council (DMEC).

Response to Sustainable Products Initiative

16 Nov 2020

The European Green Deal and the New Circular Economy Action Plan have set out a historically ambitious agenda for environmental policy. DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. DIGITALEUROPE understands and supports the vision of the European Commission to address all products with regulation enforcing requirements regarding environmental and sustainability aspects. We support the European Commission’s ambition to set “appropriate minimum sustainability and/or information requirements” at EU level and for specific groups of products. That offers manufacturers the design opportunities for products they wish to market, keeping the environment in mind. Given the established presence of very effective sector specific instruments, we think the approach should be developing an instrument in which technology neutral overarching sustainability principles are laid down that should form the foundation of all sector specific product regulations in the EU. This instrument should serve as an umbrella for creating sector specific and aspect specific legislative measures that can serve as international standards. We recommend to reference existing regulations in the ICT industry or new emerging regulations, such as the Sustainable Corporate Governance, to leverage sustainability aspects. For further recommendations, please see the attached position paper.
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Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton) and Meta Platforms Ireland Limited and its various subsidiaries and

16 Nov 2020 · DSA

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

13 Nov 2020 · AI regulatory framework

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

10 Nov 2020 · DSA and DMA

Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

In the context of the ongoing public consultations on the updated EU rules on ecodesign and energy labelling that are open until 3 November and in view of the upcoming meeting of the Committee on Ecodesign and Energy Labelling of Energy–related Products on 10 November, DIGITALEUROPE has identified several critical issues in the adopted requirements for electronic displays, servers and data storage products. We appreciate the EU Commission’s intention of addressing these critical issues through Omnibus amendments and would like to submit the following comments on the latest drafts under consultation. Our comments attached. We remain open for any further clarifications.
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

In the context of the ongoing public consultations on the updated EU rules on ecodesign and energy labelling that are open until 3 November and in view of the upcoming meeting of the Committee on Ecodesign and Energy Labelling of Energy–related Products on 10 November, DIGITALEUROPE has identified several critical issues in the adopted requirements for electronic displays, servers and data storage products. We appreciate the EU Commission’s intention of addressing these critical issues through Omnibus amendments and would like to submit the following comments on the latest drafts under consultation. Our comments attached. We remain open for any further clarifications.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

26 Oct 2020 · DSA and DMA

Meeting with Celine Gauer (Head of Task Force Secretariat-General)

22 Oct 2020 · Recovery and Resilience Facility

Meeting with Axel Voss (Member of the European Parliament)

20 Oct 2020 · Artificial Intelligence

Response to Sustainable corporate governance

7 Oct 2020

See attached document. DIGITALEUROPE welcomes the opportunity to comment on the Inception Impact Assessment in advance of broader public consultation and publication by the European Commission of legislative proposals in 2021. DIGITALEUROPE supports the objectives of the Union to introduce a global level playing field on this important topic and looks forward to bringing our sector’s experience on responsible business conduct to the table and to facilitate and contribute constructively to the ongoing multi-stakeholder dialogue. The digital technology industry provides the backbone for the future of the EU. Our sector will help the Von der Leyen Commission to deliver on each of its six core priorities. As the coronavirus (COVID-19) remains with us, technology continues to play a crucial role. For example, artificial intelligence and high performance computing are expediting scientific research, robotics are helping medical professionals care for patients while keeping them safe from infection, and ICT-enabled teleworking continues to play an important role in our society and will be fundamental to sustainable economic recovery. In the early 2000s, our sector identified the need to create an industry-wide standard on social, environmental, and ethical issues in the supply chain. The founding members of what is now the multi-sector Responsible Business Alliance (RBA) saw an opportunity to drive positive change and increase efficiency across the industry with a unified approach, holding suppliers accountable to a common standard. This coordinated, collaborative approach has helped our industry proactively address significant challenges such as conflict minerals and modern slavery. We recognise the importance of integrating environmental social governance and due diligence (DD) into corporate decision-making in order to ensure the long-term sustainability of enterprises, to address significant societal challenges and the need to engage with and solicit input from all relevant stakeholders involved in company ecosystems.
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Meeting with Frans Timmermans (Executive Vice-President)

28 Sept 2020 · The role of digital technology in delivering the Green Deal

Meeting with Karolina Herbout-Borczak (Cabinet of Commissioner Stella Kyriakides), Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides)

25 Sept 2020 · Virtual meeting about European Health Data Space

Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Johannes Hahn)

17 Sept 2020 · MFF and COVID Recovery Plan

Response to Requirements for Artificial Intelligence

10 Sept 2020

DIGITALEUROPE thanks the Commission for this opportunity to provide feedback on the AI Inception Impact Assessment. In our attached contribution, we analyse the various Options proposed by the Commission and give our comments and recommendations.
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Response to Implementing act on a list of High-Value Datasets

25 Aug 2020

Please find attached our detailed feedback. Summary: The development of high-value datasets (HVDs) in specific fields will have major positive consequences for society. Such datasets offer significant potential for citizens and businesses, to help address societal challenges and to develop innovative services and products. To ensure a successful implementation of the HVDs concept, DIGITALEUROPE recommends the following: - Ensure maximum re-use: To facilitate the re-use of datasets, on top of the obligations present in the Directive (free of charge, provided via APIs, etc.), the HVDs should follow good practices for data sharing, notably by using generally accepted taxonomies, clear licences and non-restrictive formats, by providing detailed documentation on origin and use, and by making available up-to-date or even dynamic datasets. - Be ambitious: Our members developed proposals of specific high-value datasets for the Commission to consider, listed in this document. These proposals match the requirements of the Directive, as they have the potential to be used by a wide number of users, and to generate revenue and significant socioeconomic and environmental benefits and innovative services. This non-exhaustive list should only be a starting point to identify more dataset subcategories and further detail the ones proposed. - Preserve the Directive’s spirit: The use of the exceptions to the HVD framework set in the Directive must be proportionate and follow a thorough assessment. The development of the HVD concept should be homogenous across Europe, to avoid an uneven implementation. DIGITALEUROPE looks forward to discussing with the Commission the ideas and proposals outlined in the inception impact assessment.
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Response to Revision of the NIS Directive

13 Aug 2020

As the voice of digitally transforming industries in Europe, DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission’s roadmap consultation on the review of EU rules on the security of network and information systems. The Directive on security of network and information systems (NIS Directive) was a landmark piece of EU legislation that improved and harmonised Europe’s cybersecurity preparedness at national and Union level. It is a key component in making Europe more resilient and ensuring a state-of-the-art response to current and emerging cyber threats to vital sectors of the EU economy. In view of the upcoming review of the Directive later this year, we would like to put forward the following recommendations: - Scope: The current scope should be maintained. The review should, however, ensure that Member States are more closely aligned in defining Operators of Essential Services (OESs) and Digital Service Providers (DSPs). - Member State harmonisation: Fragmentation amongst Member State approaches should be reduced, in particular with regard to OES identification. - Regulatory coherence: The review should ensure harmonisation and collaboration with other current and draft European initiatives related to cybersecurity resilience, such as those in the financial sector and for critical infrastructure protection. - Incident reporting: The current incident reporting threshold should be maintained in order to prevent overburdening competent authorities. - Information sharing: Better information sharing between companies should be promoted without the involvement of national authorities. The creation of approved frameworks, such as codes of conduct, should be encouraged. - International standards: There should be continued support and awareness raising for a risk-based, outcomes-focused cybersecurity framework that leverages international standards relevant across sectors. Overall, we find that the NIS Directive is a robust legal framework that fulfils its stated goals. Relevant guidance on specific elements and other non-legislative measures can promote further harmonisation and clarity. DIGITALEUROPE recommends Option 2 identified in the European Commission’s inception impact assessment, or a carefully targeted version of Option 3, as the best approach to address the points above moving forward. We provide more detailed comments in the annex to our feedback.
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Response to Enhancement of European policy on critical infrastructure protection

6 Aug 2020

DIGITALEUROPE welcomes the opportunity to provide a response to the Commission’s consultation on the possible review of the existing Critical Infrastructure Directive (hereinafter “ECI Directive”) and the subsequent inception impact assessment. The current ECI Directive establishes a procedure for identifying and designating European Critical Infrastructures (ECI) and a common approach for assessing the need to improve their protection. The Directive is focused on assets, i.e. the designation of critical infrastructures at EU level, and applies to the energy and transport sectors. DIGITALEUROPE acknowledges that the protection of critical infrastructures providing essential services to European citizens is of utmost importance. The outbreak of the Corona crisis has further underscored the importance of ensuring such adequate protection and increasing the resilience of critical infrastructures. Please see attached DIGITALEUROPE's full response to the consultation on possible review of the existing Critical Infrastructure Directive.
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Response to Legislative framework for the governance of common European data spaces

31 Jul 2020

Please find attached our detailed feedback. Summary: The future EU data spaces, as outlined in the Commission’s Data strategy, will be key to create a Single Market for data that will drive the EU’s digital transformation. To ensure the success of the initiative, DIGITALEUROPE recommends the following: - Create a robust framework: While publicly-held data possesses a huge potential, safeguards are needed when accessing data outside of the PSI Directive’s scope. When requirements are met, any actor compliant with applicable EU legislation should be allowed to participate in the activities of the data spaces ecosystem. - Focus on unaddressed standard aspects: The governance framework should prioritise adoption of existing standards and assess remaining standardisation needs to improve data interoperability, interpretability and use. EU standardisation efforts should be based on existing industry-driven global standards whenever possible and on the work carried by well-established bodies. - Support open and reliable data intermediaries: Data spaces should be based on non-discriminatory, collaborative and transparent rules. Their governance should ensure adequate representation of the private sector. Other marketplaces and platforms should also be open to all actors. - Encourage data donations: Any EU data altruism framework should build and safeguard trust, notably privacy-wise. To promote public-private data donation partnerships, removing potential barriers is essential.
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Response to Update of concentration limit values of persistent organic pollutants in waste

29 Jul 2020

Background Persistent organic pollutants (POPs) are poisonous chemicals that break down slowly and get into the food chain, harming the environment and our health. Waste that contains POPs is of particular concern. The EU therefore sets concentration limits for these chemicals, which it reviews regularly to reflect the latest research. The Commission is once again reviewing the limits to: - ensure that such waste is managed in an environmentally sound way - achieve safer recycling. The EU Commission has launched a new roadmap focusing on concentration limits for POPs in waste. This roadmap is open for feedback until 07-August-2020. Feedback will be taken into account for further development and fine tuning of the initiative. The Commission will summarize the input received in a synopsis report explaining how the input will be taken on board and, if applicable, why certain suggestions can't be taken up. Feedback from DIGITALEUROPE DIGITALEUROPE members offer electrical and electronic products on a global scale by processing raw materials procured from various locations around the world. Regarding the latest decision of the Basel Convention COP as stated in Paragraph 8 which contains the following: Encourages Parties and others to, as soon as possible, develop and use methods, including screening methods, that are validated and suitable for industrial-scale use for the sampling and analysis of persistent organic pollutant content in waste, in particular of hexaBDE and heptaBDE, tetraBDE and pentaBDE, and decaBDE content in waste in the range between 50mg/kg and 1,000mg/kg. As such, DIGITALEUROPE can provide its position regarding the discussion of further lowering the concentration limits for POPs and is stated below. With respect to hazardous substances in plastics, DIGITALEUROPE members have been controlling, as producers, the content of certain brominated flame retardants to be less than 1,000mg/kg pursuant to the RoHS Directive. However, if the discussion currently being held by the European Commission concludes the threshold to be below 1,000mg/kg, producers would have to execute extremely expensive measurements unless it is consistently guaranteed that the material producer will continue to provide recycled plastics containing certain brominated flame retardants in an amount less than the specified limit. This would be unrealistic for producers in terms of workload and financial aspects, and DIGITALEUROPE is concerned that it may lead producers to becoming unable to use recycled plastic in products. Accordingly, from the viewpoint of promoting resource recycling, DIGITALEUROPE would request that the Commission consider keeping the threshold at 1,000 mg/kg as specified under the RoHS Directive. Thank you very much for your consideration.
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Response to Empowering the consumer for the green transition

27 Jul 2020

DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. Our members empower consumers to take part in the circular economy through numerous strategies, including providing transparent information on the sustainability credentials of our products and services, facilitating access to repair, and providing extended product guarantees, offering trade-in programmes and refurbished products. In the attached paper, DIGITALEUROPE shares its vision for a sustainable consumer policy agenda at the intersection of consumer, ecodesign and repair policies. Our recommendations identify four key areas of action for EU legislators: - Empowering consumers by paving the way towards online information provision in the digital age, based on EU-wide harmonised methodology and product-specific standardisation. - Protecting consumers by defining ‘Right to Repair’ as consumer access to high quality, safe and secure repair option in all cases, recognising the importance of manufacturer-led repair networks. - Upholding existing legislation for consumer protection against premature obsolescence, while unleashing competitive dynamics of the marketplace with regards to commercial extended warranties and reliability innovations. - Support and facilitate repair and refurbishment professionals. As the EU institutions work to elaborate on the announced proposals, DIGITALEUROPE stresses the need to ensure balanced requirements that promote sustainable purchasing, offer high-levels of consumer protection and enable industry’s ability to provide innovative products and services.
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Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

17 Jul 2020

DIGITALEUROPE supports an ambitious pro-investment and green digital infrastructure policy, which in addition to the alignment with the EECC and Gigabit connectivity targets (e.g. upcoming update to the 5G Action Plan), as well as stronger harmonisation of current measures, will provide an enhanced new framework for public authorities and network operators to ensure a more cost-efficient deployment of sustainable networks. Please find our detailed comments on the review of the Broadband Cost Reduction Directive in the attached contribution.
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Meeting with Věra Jourová (Vice-President)

17 Jul 2020 · EDAP, DSA, Artificial intelligence, COVID-19 disinformation

Meeting with Didier Reynders (Commissioner) and

16 Jul 2020 · AI, data protection and DSA

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

13 Jul 2020 · Exchange of views on automated mobility with DIGITALEUROPE members

Response to Strengthening of Europol’s mandate

9 Jul 2020

DIGITALEUROPE and its’ members take their responsibility to maintain the safety, security, and privacy of millions of users seriously. They also recognise that there are situations where they need to assist law enforcement agencies (LEAs) carrying out investigations into criminal activity. DIGITALEUROPE continues to openly support and work with the European Commission in its efforts to find workable solutions to improve the cooperation between industry and LEAs. Please see attached the full DIGITALEUROPE response on European Commission’s roadmap on strengthening the mandate of the European Union Agency for Law Enforcement Cooperation (Europol).
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Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Phil Hogan)

8 Jul 2020 · Digital trade

Response to Modernising the EU’s batteries legislation

6 Jul 2020

DIGITALEUROPE appreciates the opportunity to comment on the inception IA. In the past, we have extensively commented on the ongoing revision of the Batteries Directive (Directive). The inception IA document remains vague on the relationship between the envisaged “new regulatory instrument” and the existing regulatory framework for batteries. Based on the public consultation for the eco-design prep. study for batteries from 2019, we assume that the envisaged legislation will be additional and complementary to the Directive - but focused in scope on batteries in e-mobility applications. We support such a focused approach and request definite clarification on the scope of the initiative, with a confirmation of the focus on batteries in e-mobility applications. Our recommendations: 1. A dedicated regulation makes sense, focused on the fast-growing e-mobility sector which will consume the lion share of lithium-batteries in the future. 2. Such a regulation should be clearly delineating its scope and not impose requirements for all batteries put on the European market. The preparatory work done so far has not provided a sufficient evidence base to expand the scope beyond e-mobility applications. 3. The ongoing revision of the Directive will likely be significant and to the extent that the Commission considers a larger scope of the “modernizing EU batteries legislation” project, our comments as submitted apply. The position includes recommendations on: EPR obligations, recycling, removability, labelling and information provision, non-rechargeable batteries, deposit schemes, definitions and governance questions. In addition we would like to submit the following for consideration: 1. In the interest of the Single Market, the Commission should not enable MSs to regulate design or labelling requirements nationally. EPR requirements can benefit from national adjustments, but must be based on European minimum requirements. Ecomodulation criteria must be harmonized across the EU. 2. While defining sustainability requirements for batteries to be placed on the EU market, focus on creating product-specific legislation. Recycled content, durability, reusability and other such criteria are discussed in product-specific lots under the Eco-Design Directive for good reasons; and the same logic should apply to batteries. 3. Collection, treatment and recycling of waste batteries are addressed for our sector already via the Directive, and interlinked indirectly via the WEEE Directive. EPR legislation is well developed and implemented. EPR requirements for batteries currently not in scope of the Directive are beyond the scope of our association but could lend themselves to consideration under this policy initiative. 4. Batteries are already today subject to a number of labelling and information requirements via the Directive (materials, capacity, wheelie bin, removal instructions). We understand the envisaged labelling and information requirements to be considered for products out of scope of our sector. See our existing position paper on the Directive. 5. Non-rechargeable batteries are used in our sector, for instance in electronic products using memory back-up functions. The focus of the legislator should remain on considering phase-outs only where environmentally and functionally superior alternatives exist. 6. We consider that efforts to identify and mitigate supply chain risks such as forced labor and environmental pollution are extremely important. To be consistent with the Union’s better regulation principles, we strongly recommend that any consideration of the responsible sourcing of battery metals and minerals such as cobalt is considered in the context of the existing legal framework (Regulation (EU) 2017/821). The Regulation, accompanied by the European Partnership for Responsible Minerals is based on the OECD 5-step due diligence guidance and will be reviewed by Jan 1, 2023 and every 3 years thereafter.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

29 Jun 2020

DIGITALEUROPE’s membership fully supports the European Commission’s ambition to strengthen the digital services market in the EU. We agree that clarity is needed on the role and responsibilities of online platforms to make the internet safe. Illegal and harmful content is too prevalent on the internet. Our members do not seek additional liability exemptions, but rather want a legal framework that allows them to tackle the problem and play their part in creating a healthier online environment. This will help to increase the levels of trust that European citizens have in digital services. Online intermediaries, rights holders, users, government and law enforcement all have a role to improve the safety and trust in the Internet economy. The Digital Services Act should complement and provide greater clarity to the fundamental principles of the E-Commerce Directive (ECD): - It should make clear the roles and responsibilities of different actors online, and incentivise rather than discourage intermediaries to remove illegal and harmful content. - Given its wide-ranging importance to the functioning of the internet (and the potential for unintended consequences), it should retain the simplicity of the ECD and be narrow in its focus. - Where needed, it should be accompanied by additional issue-driven (voluntary or regulatory) measures to tackle specific problems, as has been the case in areas such as product safety, counterfeits, hate speech, terrorist content, copyright infringement, and disinformation.
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Response to Chemicals strategy for sustainability

19 Jun 2020

DIGITALEUROPE strongly supports the European Green Deal objective of a digital and ecological transition. The digital (i.e. electronics) industry is a key enabler of both transitions, including climate change mitigation and the development of a Circular Economy. The use of chemicals plays an important part in the development and deployment of innovative technologies that enable those transitions. The digital industry therefore welcomes the opportunity to contribute to the Roadmap for a Chemicals Strategy for Sustainability. While the digital industry is not the primary focus of the Roadmap, we have identified several topics that are important to our industry and we look forward to engaging in policy debates to share our expertise and perspectives. Technologies and products are bound to have some level of environmental impact, and our industry is working hard to reduce its environment footprint, including at the level of chemicals use and management. DIGITALEUROPE strongly supports a move towards a more sustainable chemicals industry. More sustainable chemicals, as well as a broader range of such chemicals, will help the digital industry to make products and solutions more sustainable. The future of chemicals management is a key subject that DIGITALEUROPE is working on in relation to management both by companies and at a regulatory level. The digital industry relies on a complex and global supply chain. Compliance with legal requirements must be addressed throughout the many tiers of the entire supply chain, all the way from raw materials to the final product. This requires producers to push requirements back through all levels of the supply chain and provide education where relevant. New requirements introduced in the EU are almost immediately accepted as requirements across the whole supply chain. Risks of worker exposure to chemicals are typically assessed under Environmental Management Systems required by producers. Adherence to these is demanded throughout the supply chain. The digital industry thus helps promote and apply the EU’s high standards in environmental and health protection outside the EU. Additionally, virtually all of the larger producers in the industry have adopted a global approach to their substance management programs, resulting in many products sold outside the EU complying with all EU requirements. Substitution, while a fundamental element of chemicals management, is also key to the development and use of more sustainable chemicals. Regrettable substitution (i.e. the substitute being not safer/more sustainable, or being restricted shortly afterwards, or not providing required durability, performance and reliability) however, must be prevented through regulatory transparency and predictability. The way forward is not only to have future-proof restrictions but also future-proof substitutes. Incentivising sustainable chemicals management must include consideration of substitutes. Such an approach will help accelerate a greater uptake of sustainable chemicals and therewith the development of such chemicals. Similarly, we see a benefit in this context to also review the benefits and issues associated with the grouping of chemicals. DIGITALEUROPE supports simplifying and strengthening of the legal framework and is very committed to take part in discussions relative to identifying and addressing regulatory gaps and overlaps. This will involve making best use of scientific evidence, EU scientific bodies and agencies, as well as exploring what a one-substance-one-assessment approach would entail for the digital industry. Finally, the digital industry is keen to further discuss and explore industry specific options to address the chemicals-products-waste interface. This is especially with a view to helping the establishment of a circular economy and specifically the re-use of materials and what this means; in terms of providing relevant practical and useful information related to products and their constituents
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Meeting with Nele Eichhorn (Cabinet of Executive Vice-President Margrethe Vestager)

28 May 2020 · To discuss industrial strategy, recovery plan.

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

28 May 2020 · Digital manufacturing and the European recovery (open online panel discussion)

Meeting with Margrethe Vestager (Executive Vice-President)

20 May 2020 · EU Digital policy / COVID19

Meeting with Virginijus Sinkevičius (Commissioner) and

14 May 2020 · To exchange the views on the role of digital technologies in various areas of EU policies, including European Green Deal and discuss the question how ICT can contribute to Sustainability and zero emission goals

Response to Report on the application of the General Data Protection Regulation

29 Apr 2020

DIGITALEUROPE welcomes the opportunity to provide feedback on the implementation of the GDPR. DIGITALEUROPE is the leading trade association representing digitally transforming industries in Europe. Our membership represents over 35,000 businesses who operate and invest in Europe. It includes 71 corporations which are global leaders in their field of activity, as well as 40 national trade associations from across Europe. Please find our feedback attached.
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Meeting with Margrethe Vestager (Executive Vice-President)

24 Apr 2020 · EU digital policy / COVID19 crisis

Response to Action Plan on the Customs Union

21 Apr 2020

1/ As per the objective: Risk analysis is a crucial element of the efficiency of customs controls. In order to improve the risk capabilities of registered companies in the member states, a unified policy amongst sharing import and export data should be established. Currently each member state decides the policy on whether a registered company can access import and export data which has been made in their name. Without a centralized approach companies are not able to flag entries that seem questionable and completely self-monitor. In some member states you can subscribe to obtain the data, while in others you must be a self-filer. Though a unified data exchange registered companies could perform risk assessments covering all locations in the EU where their companies are registered. Today this is not possible due to the various country level policies that are in place. By enabling this capability companies would also be able to flag out issues that they may not be aware of today (Ex Unauthorized Clearance) helping reduce the overall risk which meets the programs objective. 2/ Harmonisation on BTI: Currently BTIs are applied in country where the importer is established. It would highly help companies if there would be a central point where BTIs are be issued. Still if national authorities continue to do BTIs, much more coherence is needed as there are still conflicting BTIs and BTIs being ignored.
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Meeting with Thierry Breton (Commissioner) and

21 Apr 2020 · Impact of Covid19 on digital companies

Response to Light deployment regime for small-area wireless access points

2 Apr 2020

Joint response by GSMA, ETNO, Small Cell Forum, DIGITALEUROPE and GSA Our organizations welcome the European Commission proposal to give effect to the SAWAP provisions of the EECC to allow harmonized light deployment regimes leveraging simple criteria such as volume, emission power and compliance of SAWAP installation with the applicable European Standards (EN50401 and EN62232). We welcome Recital 16 that allows Member States to adopt less restrictive approaches, noting that many Member States already permit larger volumes or higher powers than those defined in the proposed SAWAP regulation or provide for no restrictions at all indoor as opposed to the proposed SAWAP regulation. Our objective is that the criteria defined in this Implementing Regulation (IR) support the fast deployment of SAWAPs to meet the criteria of broadband objectives of the European Commission. Therefore, we propose changes to strengthen the effectiveness of the proposed measures. 1. The current SAWAPs deployed outdoor or indoor in larger areas such as museums, stadiums, convention centres, airports, metro-transport stations, railway stations, or shopping centres, have an emission power of 10 W or more as defined in 3GPP specifications and as such belong to classes E100 or sometimes E+. Therefore, the criteria for applicability of the IR should be 10 W emission power so that it applies to a wide range of installations. 2. Installation classes E10 and below are generally dedicated to indoor applications and deployed very close to where people work and live. Therefore, limiting the applicability of the draft IR to class E10, corresponding to emission power 0.5 W, which is similar to a mobile phone, means that it will have very limited potential benefit for stakeholders in real world deployments. 3. The proposed volume of 20 litres applies to limited functionality SAWAP that can serve a single mobile radio access technology in a single sector, potentially across multiple bands, excluding the auxiliary equipment (for example, the power supply) that is not part of the 20 litres. 4. A minimum volume of 50 litres is required to support multi-technology or multi-operator SAWAP. Unless this is permitted, we will see a negative business impact on small cells deployment (and future synergetic usage of co-located technologies like cellular vehicle-to-everything) and an overall risk of Europe falling behind other regions. 5. The proposed IR will have to be updated shortly after the update of EN62232 in order to incorporate the simple deployment criteria for active antenna systems (AAS) for example those using millimetre waves. We recommend to review the provisions of the IR six months after publication of the updated EN62232. The attached document sets out the proposed amendments.
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Response to Europe’s Beating Cancer Plan

2 Mar 2020

DIGITALEUROPE calls on European governments to accelerate the adoption and usage of data-driven Artificial Intelligence (AI). The technology is key to improve cancer care by supporting European healthcare delivery systems and research communities. In medical imaging, AI brings efficiencies by freeing up time for specialists while, at the same time, helping to maintain high-quality care over time. For example, in breast cancer screening, studies show AI lowered by 9.4% false negatives (Nature, 2020). Data collected in real life settings (i.e. real-world data) can help drive new understandings of value by supporting healthcare decision-makers faced with the challenge of assessing different forms of technology and treatments in the context of fixed healthcare budgets. We call on policy-makers across the EU to firmly consider the following recommendations in the development of the Plan: - Support the uptake of digital solutions addressing the shortcomings of cancer screening programmes. For early detection and screening, we need better access to digital technology, better use of scarce resources both in terms of experts and healthcare infrastructure, and foster the accessibility and interoperability of health data. We also need to ensure that new cancer screening programmes potentially recommended in the near future fully use existing digital solutions right from the start. - Train EU market assessment bodies on new medical AI solutions: we need regulators to properly understand the inner-workings of new AI technologies, including self-learning AI. In the case of the Medical Device Regulation, today AI medical software is ‘’locked-down’’ after certification , meaning the software can’t learn from real-world data. Regulators must be guided and equipped with skills to understand how to exploit AI’s potential to optimise real-time device performance to detect cancer. - Creating a connected, interoperable and sustainable Common European Health Data Space based on trust and ethical principles, where better access to health data coexists with individual privacy protection. To achieve that, the European Commission must focus on: 1) Leveraging existing successful data access initiatives: trust-based and privacy-preserving initiatives on the secondary use of health data in the EU should play a central role in the data space. Finland’s Act on Secondary Use of Health and Social Data 552/2019 is one example. It has eased access to high-quality data sets in data-scarce environments like oncology, opening up new cancer prevention and treatment opportunities. 2) Data infrastructure building, quality, interoperability and standardisation: these are crucial aspects to better inform patient pathways, boost research and reward innovative solutions. The EU must support them with sufficient MFF investments (R&D programmes, DEP, structural funds and promotion of public private partnerships) and scale up existing national activities on aspects like national cancer registries. It should also promote data storage according to widely accepted standards as well as interoperability based on standard formats (like FHIR) and secure accessibility through technical and organisational measures. Data quality is still a barrier for organisations wanting to leverage data opportunities, especially for resource-constrained ones. Data is often poorly labelled, curated or contains too much meaningless information. It is vital the EU improves data quality. 3) Skills: it is a key topic to promote a data culture where EU and Member States encourage training and retraining of the healthcare workforce as well as regulators, policy-makers and other stakeholders. The EU should also prioritise digital literacy for citizens and patients to better understand the use of digital technologies and build further trust and uptake.
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Response to Evaluation of the Electromagnetic Compatibility Directive

20 Feb 2020

Thank you for giving us the opportunity to provide DIGITALEUROPE’s feedback on the upcoming EMCD evaluation and fitness check at this early stage. For decades we have applied the EMCD including its current version, which has been mandatory since April 2016. Like the LVD we consider the EMCD as an essential cornerstone under the NLF. It has proven to be highly effective and relevant and provides the common ground for all players to balance the electromagnetic interference potential and susceptibility of products placed on the European market and of installations put into service. By doing so the EMCD ensures the coexistence and compatibility of a huge variety of products in a widely accepted and efficient way. The current EMCD has only been in place for less than 4 years. As we haven’t experienced any significant issues with its application we don’t see an urgent need for a revision after such a short lifetime. We believe that the essential requirements of the EMCD have been wisely chosen in such a way that they remain valid and fit for purpose for new and future technologies. We strongly believe that technical evolution can effectively be covered by the ESO’s in developing state of the art harmonised standards addressing the Commission’s mandate. From our perspective recent EMC issues have not been caused by shortcomings of the EMCD, but by delays and unavailability of harmonised standards, which to a large extent result from the new processes implemented to address the requirements of the standardization regulations 1025/2012 in light of court cases, such as James Elliott. We recognise that the Commission is working on improving these processes and remain optimistic that we can get back to a situation where a robust and stable EMCD is supported by state of the art harmonised standards. We think that the scope of the EMCD is appropriate and shouldn’t be changed. Regarding the possible inclusion of cables (RMCD), DIGITALEUROPE has already expressed its view (in earlier communications in response to an EMC Working Party questionnaire) that this should be covered by voluntary schemes. Keeping the EMCD coherent with other regulation is certainly important, but we are concerned about the suggestions of merging the EMCD with the RED. The result could be a very complex construct calling on many distinctly different areas of expertise, which has the potential to increase confusion rather than providing clarification for users. Concepts provided by the EMCD, (e.g. fixed installations) are not available in the RED and vice versa. Combining all of that into one directive would require a major rewrite initiative with the risk of breaking well-established concepts. To summarize our position, we think the EMCD in its current form is still fit for purpose and relevant, which also justifies its continued coexistence alongside the RED. We don’t see any pressing need for a revision in the near future. In the event that the evaluation does lead to a revision of the EMCD, it should be done in a very careful way to ensure existing, proven concepts and practices do not break. DIGITALEUROPE remains available for any further discussions in the course of this evaluation.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

6 Feb 2020 · Panel discussion on digital technologies and the Green Deal

Response to Climate Law

5 Feb 2020

DIGITALEUROPE is convinced that digital technologies are key enablers for attaining the sustainability goals of the European Green Deal and contributing to the Paris Agreement and United Nations Sustainable Development Goals (SDGs) . In order to leverage this enabling potential and to facilitate the achievement of the EU’s 2050 climate-neutrality objective, we believe that digital and sustainability should work hand in hand. Industry’s digital transformation is offering new prospects to unlock innovation, provide new opportunities to workers, decarbonise and generally do more with less. Digital technologies have the potential to enable a 20% reduction of global CO2 emissions by 2030. At the same time, it is essential to ensure a sustainable digitalisation. For numerous years, the carbon footprint of ICT products has increasingly improved due to a combination of regulatory initiatives and industry efforts. Typically, the industry has heavily invested to improve the efficiency and increase the use of green fuel alternatives within data centres. That explains partly why the total energy consumption of ICTs remains close to 3% despite the ever-increasing digitalisation of the economy. Europe is known for its extensive regulatory framework of product policies, which has expanded significantly over the years. Especially in our sector, we have a significant amount of legislation in place, which is often also adopted (in-part) by jurisdictions outside the EU. This years-long knowledge and experience, together with the EU institutional change, puts us now in an excellent position to reflect and ensure the framework remains fit for purpose and contributes to reaching the long-term climate goals. Harmonised and incentive-based policy instruments leveraged by digital technologies will send a strong and positive message to the market for companies to do the right thing. We need to find the right balance and make sure the pieces of the puzzle fit better together. We need to think about innovative ways of regulating and we should focus on the key long-term goals we want to achieve. We should look at the full toolbox available in terms of legislation, non-legislative policies, education & skills, funding, voluntary industry initiatives etc. When we think about new initiatives and how they can make a difference and create the necessary scale, we should also think about how they are going to be implemented and enforced. As DIGITALEUROPE we support greater harmonisation, avoid fragmentation and work towards a stronger single market. We understand that in the area of environmental legislation, some Member States want to go beyond EU rules. As industry, we would prefer EU rules to be ambitious, harmonised and justified in order to avoid a fragmented market. Fragmentation impacts the ultimate effectiveness of environmental regulation. The European Green Deal is, rightly so, one of Europe’s top priorities. Climate change, and its related adverse economic, societal, and ecological risks, is the biggest challenge of our time and it requires a thorough approach that must be jointly addressed by the EU and industry. It is essential to find sustainable and innovative ways for both society and business to move towards a low carbon circular economy and ensure sustainable growth.
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Meeting with Phil Hogan (Commissioner)

4 Feb 2020 · Trade Issues

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

21 Jan 2020 · Overall digital policy, industry data pooling, open data, artificial intelligence (HLG), European Green Deal & ICT energy use

Response to A new Circular Economy Action Plan

17 Jan 2020

DIGITALEUROPE is convinced that digital technologies are key enablers for attaining the sustainability goals of the European Green Deal and contributing to the United Nations Sustainable Development Goals (SDGs) . In order to leverage this enabling potential and to make the big transformation to a circular economy happen, we believe that digital and sustainability should work hand in hand. Industry’s digital transformation is offering new prospects to unlock innovation, provide new opportunities to workers, decarbonise and generally do more with less. Digital technologies have the potential to enable a 20% reduction of global CO2 emissions by 2030. At the same time, it is essential to ensure a sustainable digitalisation. For numerous years, the carbon footprint of ICT products has increasingly improved due to a combination of regulatory initiatives and industry efforts. Typically, the industry has heavily invested to improve the efficiency and increase the use of green fuel alternatives within data centres. That explains partly why the total energy consumption of ICTs remains close to 3% despite the ever-increasing digitalisation of the economy. Europe is known for its extensive regulatory framework of product policies, which has expanded significantly over the years. Especially in our sector, we have a significant amount of legislation in place, which is often also adopted (in-part) by jurisdictions outside the EU. This years-long knowledge and experience, together with the EU institutional change, puts us now in an excellent position to reflect and ensure the framework remains fit for purpose to deliver and is tailored to accelerating Europe’s circular economy transition. Harmonised and incentive-based policy instruments leveraged by digital technologies will send a strong and positive message to the market for companies to do the right thing. We need to find the right balance and make sure the pieces of the puzzle fit better together. We need to think about innovative ways of regulating and we should focus on the key goals we want to achieve. We should look at the full toolbox available in terms of legislation, non-legislative policies, education, funding etc. When we think about new initiatives and how they can make a difference and create the necessary scale, we should also think about how they are going to be implemented and enforced. As DIGITALEUROPE we support greater harmonisation, avoid fragmentation and work towards a stronger single market. We understand that in the area of environmental legislation, some Member States want to go beyond EU rules. As industry, we would prefer EU rules to be a bit stricter but harmonised and justified to avoid a fragmented market. Fragmentation impacts the ultimate effectiveness of environmental regulation. The transition to a circular economy requires a thorough approach that must be jointly addressed by the EU and industry. It is essential to find sustainable and innovative ways for both society and business to move towards a low carbon circular economy and ensure sustainable growth.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

3 Dec 2019 · The role of digital technologies in the clean energy transition

Meeting with Sabine Weyand (Director-General Trade)

31 Oct 2019 · Digital issues, US-China trade

Meeting with Daniel Calleja Crespo (Director-General Environment)

28 Oct 2019 · Digital and sustainability

Meeting with Ilze Juhansone (Secretary-General Secretariat-General)

8 Oct 2019 · Exchange of views on the Political Guidelines of President-elect von der Leyen

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

8 Oct 2019 · Standardisation

Response to Contract summary template for electronic communications service providers

9 Sept 2019

DIGITALEUROPE believes providing clear information to consumers is crucial. To this end, it is important that the contract summary template is flexible and principle-based in order not to restrict innovation that improves user experience. The draft implementing act partly fulfils this flexibility goal. We are nevertheless concerned that some elements of the draft are too prescriptive and exceed the letter of the EECC. In particular: - Art. 2(2) prescribes a specific font size, allowing exceptional exemptions. Given the spread of new user interfaces, this exception is likely to be insufficient. - Art. 2(3) prohibits the use of visuals overlaying text. This is overtly prescriptive and would discourage service providers’ use of both graphics and text that could indicate something meaningful for consumers. - Art. 2(4) prohibits the use of specialised language, while in some cases such language may be understandable to the specific community targeted. - Recital 5 prescribes the use of commonly used fonts, while proprietary, easily readable fonts could equally fulfil the requirements of Art. 102(3). In terms of content, the draft act and its Annex also require the inclusion of information that goes beyond the text of the EECC, makes it more difficult to comply with it or is contradictory: - The description of the headings outlined in the Annex suggests that information on price must be included, including when the service is provided without direct monetary payment. - The pricing information requirements as detailed in Recitals 9 and 12 seem to presume that all services utilise volume-based pricing models, whereas many offer unlimited service plans. - Recital 16 provides an extensive list of elements to describe accessibility features, which would make it difficult for service providers to fulfil the conciseness criteria of the EECC and A4 equivalence in Art. 2(1). DIGITALEUROPE believes that the use of separate information pages, accessible through hyperlinks, will provide the right solution to ensure that the summary remains concise and easily readable. The use of hyperlinks should therefore be encouraged throughout, as long as the service provider provides the basic contract summary information required by Art. 102. In the document attached to our response, we provide more detailed justifications and suggestions for amendments to the draft implementing act and its Annex.
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Response to Informative guidance on the Regulation on the Free flow of non-personal data

13 Mar 2019

Please find pdf attachment with DIGITALEUROPE comments.
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Response to Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems

4 Mar 2019

DIGITALEUROPE believes that this initiative should only be limited to classes of radio equipment for which there is a clear evidence showing that the upload of software on radio equipment could lead to a serious risk of non compliance in the EU market. So far, problems causing a risk of non-compliance with the RED due to software uploads have not been clearly identified. Unless there are well founded reasons, DIGITALEUROPE recommends letting the free market play its role, benefiting the competitive advantage for manufacturers that already apply such mechanisms to ensure only compliant software can be loaded on the radio equipment. In case of any clearly identified problems in the market due to software updates, DIGITALEUROPE requests that the proposed measures under Article 3.3i of the RED respect the principles of proportionality and smart regulation. Any new legislative measure shall be proportionate to the clearly identified risks, without leading to unjustified new requirements affecting radio equipment for which no compliance problems have been identified. In addition, any potential new measures should be practical for manufacturers, minimise additional administrative burden and provide legal certainty. Due to the additional administrative burden brought by Article 4 of the RED, which offers no added value to the authorities and end users, DIGITALEUROPE is not in favour of any additional statement of compliance. We consider that current requirements of RED are sufficient to inform authorities and end users about compliant software versions. Any additional administrative burden that is disproportionate compared to the potential risk shall be avoided. DIGITALEUROPE remains at the disposal of the EU Commission to provide further details on these initial comments. Furthermore, DIGITALEUROPE expresses its interest and availability to provide additional explanations and evidence during the next steps of the impact assessment, as well as in the Expert Group on Reconfigurable Radio Systems.
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Response to Smartwatches and connected toys

4 Mar 2019

DIGITALEUROPE submits that the adoption of a delegated regulation under the Radio Equipment Directive (RED) would not be an appropriate instrument to address risks for the protection of personal data, privacy and cybersecurity. While potential risks do exist, existing legislative and regulatory instruments are at present better able to address them. As such, we support Options O and 1 identified in the inception impact assessment. Should the Commission’s final impact assessment find supporting evidence of specific risks for specific products, we urge the Commission to assess a further option not presently included in the inception impact assessment, that is, the possibility to introduce the necessary requirements under relevant sectorial product legislation. Because the inception impact assessment is largely centred around connected toys, we suggest that the Toy Safety Directive might be a more suitable first step to address consumer concerns in this sensitive space. DIGITALEUROPE remains at the Commission’s disposal to provide additional details and evidence during the next steps of the impact assessment.
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Meeting with Martin Selmayr (Secretary-General Secretariat-General)

21 Feb 2019 · Europe: A digital continent - State of play

Response to Common chargers for mobile phones and similar devices

31 Jan 2019

DIGITALEUROPE appreciates the opportunity to provide its views and feedback on the roadmap objective to limit fragmentation of charging solutions in the EU while not hampering innovation in the smartphone market. It is important to recall that the amount of 90% of compliant mobile phones reached in 2013 is due to the commitment and efforts by leading industry players signing the first Memorandum of Understanding (MoU) in 2009. The deliberate choice for a voluntary industry agreement forged under the auspices of the European Commission to tackle fragmentation has successfully delivered over the last decade common charging solutions in the Single Market. Subsequently, after regular exchanges with the European Commission, leading mobile manufacturers signed the second MoU on common charging solutions for smartphones published in March 2018. The latest MoU reconfirms industry’s commitment to the next generation of common charging solutions by leveraging the latest innovation and standardisation efforts. These accomplishments make clear that smartphone manufactures share the initiative’s objective to minimise the risk of a market fragmentation while successfully rolling out the next generation of common charging solutions across the EU. In DIGITALEUROPE’s view, the most effective policy option going forward is to build on the achievements of the first MoU and the renewed industry commitment via a continued voluntary approach for delivering equal benefits for consumers, the environment and the Single Market alike.
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Response to More efficient law-making in taxation: a move to QMV

17 Jan 2019

In order to secure more efficient law-making in taxation policy, the Commission wants to substitute unanimity with qualified majority voting at the Council and consultation with codecision as far as the European Parliament is concerned. The business of today is global. DIGITALEUROPE supports comprehensive, global, long-term tax solutions negotiated through the OECD that also includes Europe’s main trading partners. The tax proposals that have recently not been adopted by the Council as they could not command unanimity, for example in respect of the Digital Services Tax, did not align to accepted international tax principles and thus would likely lead to double tax and costly disputes, harming the EU's competitiveness. The goal should be to make the globally unique EU’s single market a more competitive, appealing and well-functioning environment for all businesses, as well as fair and supportive for all Member States. This can be achieved by building up on the best practices of all Member States as effective decision-making systems are those geared to the depth and scope of the decisions to be taken. In contrast, those catering to short-term interests and gains make for quick results and nice publicity without serving the real cause of more united Europe. This robust, stable foundation is a prerequisite for the equal and fair co-operation between all Member States and the OECD that DIGITALEUROPE strongly supports.
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Meeting with Andrus Ansip (Vice-President) and

17 Jan 2019 · MFF, AI, digital manufacturing, Digital Single Market including free flow of data, e-privacy and copyright, eHealth

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

7 Jan 2019 · P2B Regulation

Response to Ecodesign requirements for external power supplies

13 Nov 2018

The association of the European digital technology industry, DIGITALEUROPE, welcomes the opportunity to provide comments on the European Commission’s draft Regulation for ErP Lot 7 (External Power Supplies - EPS). DIGITALEUROPE welcomes the global harmonization approach taken by the European Commission (EC), by aligning Tier 1 limits of the draft ErP Lot 7 Regulation with the existing US DoE. Concerning the 10% load efficiency information requirement: industry agrees to do so for products without batteries. However, as already underlined by the EU preparatory study, there is no benefit of addressing the 10% load for battery charged products, e.g. shavers, mobile phones, tablets. Since EPS with an output power <= 10W are typically used for battery charged devices, DIGITALEUROPE proposes that the EC exempt EPS with an output power level <=10W from the 10% load information requirement. For EPS with an output power level >10W the information requirement could be maintained to allow further review of the benefit of a potential 10% load efficiency requirement in a future regulation revision. About the definition of EPS as a device used with an household and office equipment: manufacturers wish to keep providing clarity on what “household and office equipment” refers to, and so would suggest that such clarification be provided directly in the revised EPS Regulation. Regarding multiple voltage output EPS: industry recommends updating definition in Article 2 to reflect the inclusion in scope of multiple voltage output EPS. Similarly, the EC should launch a standardisation mandate to update current version of EN50563. To ensure consistency, EU should align with the test method already validated by the DoE. Finally, about adaptive external power supplies: DIGITALEUROPE believes that they are not addressed in the proposed regulation, and so would recommend a proper definition and test method, that should align with the DoE. For more information, please refer to attached document
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Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

13 Nov 2018 · Common charger & harmonised standards, e-labelling

Response to Ecodesign requirements for electronic displays and televisions

6 Nov 2018

DIGITALEUROPE is supportive of the Ecodesign and Energy Labelling frameworks and our members aim to ensure that their products are designed, produced, used, and recycled in a sustainable and safe manner whilst providing increased benefits to our customers and society at large. We appreciate the opportunity to provide feedback on the proposed display regulations via the better regulation portal, and we remain committed to contributing with our technical expertise to the ongoing discussions, provided that transparency becomes the guiding principle in the development of technical requirements. The revision process for the Lot 5 regulations has been ongoing since 2012 and in some cases it lacked transparency, thorough analysis and proper impact assessment. In addition, the data provided by industry was not given due consideration in the setting of the on-mode power consumption requirements, and there is no line of sight in the technology roadmap to achieve future energy efficiency gains proposed by the Commission. We understand the Commission’s political ambition to integrate strict energy and resource efficiency aspects in ecodesign but we are concerned about some of the requirements put forward that either (1) are unmanageable (unrealistic energy efficiency limits), (2) lack proper impact assessment (e.g. inclusion of signage displays into the scope), or (3) provide no added value (extensive repair and end-of-life information requirements). KEY MESSAGES: (1) We would like to reiterate that such severe energy efficiency requirements will seriously limit the capacity of state-of-the-art technologies to remain on the European market. Instead of removing the least efficient models, the proposed requirements will disproportionately deny market access to new display technologies and high resolution televisions and monitors, and as a result, EU consumers will not be able to benefit from the most recent breakthroughs in picture quality improvement (2) We question the Commission’s decision to include signage displays in the scope of the Energy Labelling proposal, especially given that no prior analysis of the complexities of these products has been conducted. (3) We are extremely concerned regarding the draft provisions requiring to disclose repair and End-of-Life (EoL) information as soon as a product is placed on the market. It is crucial to note that repair and dismantling information are usually proprietary and constitute manufacturers’ intellectual property. Disclosing such information will directly undermine manufacturer’s competitiveness and increase the risk of reverse-engineering, an impact that can be avoided if the requirements become mandatory starting 2 years after the product is first placed on the market. We are providing as an attachment our detailed position on the proposed display regulation containing our analysis and requests. We hope that, with your support, the concerns of the display industry would be considered during the development of the final drafts of these regulations. We remain at your disposal for any questions or comments.
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Response to Energy labelling for electronic displays

6 Nov 2018

DIGITALEUROPE is supportive of the Ecodesign and Energy Labelling frameworks and our members aim to ensure that their products are designed, produced, used, and recycled in a sustainable and safe manner whilst providing increased benefits to our customers and society at large. We appreciate the opportunity to provide feedback on the proposed display regulations via the better regulation portal, and we remain committed to contributing with our technical expertise to the ongoing discussions, provided that transparency becomes the guiding principle in the development of technical requirements. The revision process for the Lot 5 regulations has been ongoing since 2012 and in some cases it lacked transparency, thorough analysis and proper impact assessment. In addition, the data provided by industry was not given due consideration in the setting of the on-mode power consumption requirements, and there is no line of sight in the technology roadmap to achieve future energy efficiency gains proposed by the Commission. We understand the Commission’s political ambition to integrate strict energy and resource efficiency aspects in ecodesign but we are concerned about some of the requirements put forward that either (1) are unmanageable (unrealistic energy efficiency limits), (2) lack proper impact assessment (e.g. inclusion of signage displays into the scope), or (3) provide no added value (extensive repair and end-of-life information requirements). KEY MESSAGES: (1) We would like to reiterate that such severe energy efficiency requirements will seriously limit the capacity of state-of-the-art technologies to remain on the European market. Instead of removing the least efficient models, the proposed requirements will disproportionately deny market access to new display technologies and high resolution televisions and monitors, and as a result, EU consumers will not be able to benefit from the most recent breakthroughs in picture quality improvement (2) We question the Commission’s decision to include signage displays in the scope of the Energy Labelling proposal, especially given that no prior analysis of the complexities of these products has been conducted. (3) We are extremely concerned regarding the draft provisions requiring to disclose repair and End-of-Life (EoL) information as soon as a product is placed on the market. It is crucial to note that repair and dismantling information are usually proprietary and constitute manufacturers’ intellectual property. Disclosing such information will directly undermine manufacturer’s competitiveness and increase the risk of reverse-engineering, an impact that can be avoided if the requirements become mandatory starting 2 years after the product is first placed on the market. We are providing as an attachment our detailed position on the proposed display regulation containing our analysis and requests. We hope that, with your support, the concerns of the display industry would be considered during the development of the final drafts of these regulations. We remain at your disposal for any questions or comments.
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Response to Restriction of hazardous substances - evaluation

12 Oct 2018

DIGITALEUROPE welcomes the opportunity to provide input to the consultation on the Roadmap for the Review of the Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS). The RoHS Directive is an important piece of EU environmental legislation that not only drives technical substitution of hazardous substances but also sets the global regulatory bar. We endorse the focus on its effectiveness, efficiency, relevance and coherence with other EU and national laws and policies. The Directive is by and large working well and this provides an opportunity to improve the legal framework based on experience with the functioning of the Directive since 2002. There are a few areas which Europe’s digital technology industry would like the Roadmap and Review to incorporate: 1.Global Dimension: this needs to be included. DIGITALEUROPE co-signed a cross-association statement in this respect [see separate submission]. As the originator of this legislation, the EU should take more responsibility and devote more resources to ensure alignment across geographies. 2.Adequate consultation periods: stakeholders should be given sufficient time to gather data, intelligence; consultation should be coordinated with other consultations running in parallel, for example, Pack 15. 3.Efficiency of the exemption system from substance restrictions: As key participants of the RoHS Umbrella Industry Project, currently involving 34+ partnering industry associations globally, DIGITALEUROPE’s members have been key contributors to the current Directive and Exemptions’ technical adaptations to everyone´s benefit. Further, we are long-standing supporters of efforts to simplify legislation, remove red tape and lower costs without compromising policy objectives, contributing to a clear, stable and predictable regulatory framework supportive of growth and jobs. In that regard, we appreciate the ongoing collaborative approach and look forward to continue supporting stakeholders at large on the various significant related initiatives underway. We understand the evaluation will assess the Efficiency of the exemption system from substance restrictions. Recognizing the nature and breadth of this complex task, we look forward to continue sharing views, experience and concrete examples, and jointly exploring opportunities for regulatory simplifications and improvements to the exemption system. We welcome this opportunity to ensure a continued open and transparent dialogue between stakeholders on key considerations such as stakeholder need for predictability and legal certainty, consistent regulatory environment and global harmonization, scientific methodology with key consideration of socioeconomic impacts, realistic timings and feasible transition periods, and beyond. Furthermore we understand the general review should include the specification of a realistic deadline for a decision by the Commission on an application for renewal of an exemption before the expiry of the relevant exemption. Importantly, in this context, the existing exemption shall continue to remain valid until a decision on the renewal application is taken by the Commission. Finally, RoHS Exemptions requirements are complex, and the amount of time and work required to organize exemption requests that are found to be necessary and to effectively disseminate any changes globally and to allow stakeholders at large to take appropriate action globally should not be underestimated 4.Reasonable examination of substances for restriction: we consider that Art. 6 of Directive 2011/65/EU is adequate for the purposes of restricting substances. When substances are reviewed for possible restriction, sufficient time should be given for data, information gathering and assessment. Prioritization should be accordingly done based on evidence. DIGITALEUROPE looks forward to further contribute to the upcoming evaluation.
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Meeting with Kasia Jurczak (Cabinet of Commissioner Marianne Thyssen)

9 Oct 2018 · Skills Agenda

Meeting with Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

9 Oct 2018 · State of play of Single Market

Meeting with Andrus Ansip (Vice-President) and

20 Sept 2018 · GDPR, privacy shield, e-privacy

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

13 Sept 2018 · EU trade policy - latest developments and future perspectives

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

13 Sept 2018 · Ecodesign for servers

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

13 Sept 2018 · Ecodesign for servs aned data storage

Response to Environmental impact of enterprise servers and data storage products

31 Jul 2018

DIGITALEUROPE, with the assistance of TGG SERT Analysis working group, has analyzed the Commission’s proposal for a revision of the Ecodesign Directive for enterprise servers and data storage products. Based on this assessment, and with a view to constructively improve the proposal, DIGITALEUROPE has prepared the attached file which outlines our concerns with the current text and presents concrete solutions. The attached file includes an executive summary, technical briefings on energy efficiency and material efficiency. We separately submit proposed amendments to the text and a summary table explaining the justifications for the amendments.
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Meeting with Thomas Zerdick (Cabinet of First Vice-President Frans Timmermans)

17 May 2018 · Exchange of views on cross-border data flows

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

14 May 2018 · Cross-border data flows

Response to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)

19 Mar 2018

DIGITALEUROPE's initial comments on the proposed Compliance & Enforcement regulation (COM/2017/0795) Brussels, 19 March 2018 DIGITALEUROPE welcomes the Goods Package as a necessary next step to deepen the Single Market and to ensure a truly level the playing field for economic operators. If properly designed, the regulation will benefit consumers and end-users, market surveillance authorities as well as industry. DIGITALEUROPE recognises and supports the harmonisation of powers that each National Market Surveillance should be given to ensure that products placed on the Single Market are compliant, and at the same time to ensure that Market Surveillance Authorities (MSAs) have all the means necessary to identify and ban products whose lack of compliance undermine the consumer confidence and the well-being of EU Citizens. DIGITALEUROPE also acknowledges that, in serious cases, well-defined new coercive powers need to be considered. Finally, DIGITALEUROPE very much welcomes the reference to the fundamental principle of proportionality, which is the basis for effective market surveillance in the EU and Member States. For further detailed comments please see the attached paper. For more information please contact: Klaus-Dieter Axt, DIGITALEUROPE, Director Policy +32 478 17 39 01 or klaus-dieter.axt@digitaleurope.org
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Response to Energy labelling requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU’s own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) PCs, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. Further, it’s estimated that implementation of CEC regulation and ENERGY STAR (E*) v7.0 specification will result in approximate energy efficiency improvements in Idle power of 50% for DT/AIO and NB PCs respectively. Future improvement potential will, however, diminish over time with only marginal incremental improvements in energy efficiency. The last stakeholder meeting provided some rough estimates of active usage patterns from ONE E*compliant NB. The conclusions suggest that “estimates around how long PCs are used for vary considerably across different studies even for the same type of PC (e.g. desktop PC)”. No data exists to quantify a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study assessing the significance of active power is necessary to determine active power as significant, selection of the right workloads will also be a challenge to properly measure active mode power of PCs. Without such a study, proposing an energy label based on active power metric is premature. DIGITALEUROPE would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterize a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label Introducing a PC Energy Label would be a complex exercise, high configurability of PC products based on active performance requires specific analysis. The existing E* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European GPP. Noting the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and its continued basis for the PC regulatory review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number of “hybrid devices” in the market which combine NB and tablets. Customer acceptance will increase further innovative designs. Legal uncertainty for such devices is a risk if regulated by 2 different regulations with differing requirements. Material efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of PC product group" in February ‘17. Some of these comments have been integrated into the final report, but many proposed measures to improve the material efficiency of PCs still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes make no use of the information. Industry questions whether consumers seek technical performance details such as the IP class of a device, or the battery management features. Material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Response to Review of ecodesign requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU’s own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) PCs, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. Further, it’s estimated that implementation of CEC regulation and ENERGY STAR (E*) v7.0 specification will result in approximate energy efficiency improvements in Idle power of 50% for DT/AIO and NB PCs respectively. Future improvement potential will, however, diminish over time with only marginal incremental improvements in energy efficiency. The last stakeholder meeting provided some rough estimates of active usage patterns from ONE E*compliant NB. The conclusions suggest that “estimates around how long PCs are used for vary considerably across different studies even for the same type of PC (e.g. desktop PC)”. No data exists to quantify a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study assessing the significance of active power is necessary to determine active power as significant, selection of the right workloads will also be a challenge to properly measure active mode power of PCs. Without such a study, proposing an energy label based on active power metric is premature. DIGITALEUROPE would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterise a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label Introducing a PC Energy Label would be a complex exercise, high configurability of PC products based on active performance requires specific analysis. The existing E* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European GPP. Noting the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and its continued basis for the PC regulatory review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number of “hybrid devices” in the market which combine NB and tablets. Customer acceptance will increase further innovative designs. Legal uncertainty for such devices is a risk if regulated by 2 different regulations with differing requirements. Material efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of PC product group" in February ‘17. Some of these comments have been integrated into the final report, but many proposed measures to improve the material efficiency of PCs still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes make no use of the information. Industry questions whether consumers seek technical performance details such as the IP class of a device, or the battery management features. Material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Meeting with Pierre Moscovici (Commissioner) and Google and

7 Mar 2018 · Meeting to discuss digital taxation (also with representatives from Deezer and Volumental)

Meeting with Stephen Quest (Director-General Taxation and Customs Union) and Google and

7 Mar 2018 · Meeting to discuss digital taxation

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

5 Mar 2018 · data flows

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

26 Feb 2018 · DSM progress, security, industry

Meeting with Andrus Ansip (Vice-President) and

30 Jan 2018 · GDPR, e-privacy

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

18 Jan 2018 · Artificial Intelligence

Response to 2nd Data Package

18 Dec 2017

DIGITALEUROPE, as the voice of Europe’s digital technology industry, welcomes the general principle of free flow of data and reinforces the importance of banning national data localisation rules. This principle will provide legal certainty for companies, boost the European economy and herald new innovative technologies. Recent studies show that data localisation reduces competition and increases storage costs with up to 120% for companies and consumers. If existing data localising measures are removed, GDP gains are estimated to up to 8 billion euros per year (up to 0.06% of GDP), which is on par with the gains of recent free trade agreements (FTAs) concluded by the EU.[1] This Regulation represent an opportunity not to be missed. However, to maximise the benefits of cross border dataflows, the scope should not be narrowed. In our opinion, Member States should be able to localise non-personal data in only exceptional cases. Any limiting the scope and widening the exemptions will risk defeating the purpose of the Regulation. Our members and national trade associations stand ready to discuss this topic with the co- legislators. Our members consolidate views in clarifying the current text (http://www.digitaleurope.org/DocumentDownload.aspx?Command=Core_Download&entryID=2578) : ARTICLE 2 – SCOPE The general principle of free flow of data could be undermined by limiting the scope and widening the exemptions. The Regulation proposed by the Commission covers non-personal data in general. DIGITALEUROPE support this scope and firmly believes this includes non-personal public data. As public institutions adopt cloud, they lower the tax burden for their operations, bring more efficiencies to their internal work processes, and improve constituent interactions by offering e-governance solutions. Removing public data from the scope risks incentivising public authorities to (i) insource their data storage and processing or (ii) not to outsource it at all. This could have the following consequences: • Running your storage facility might not give you access to the latest innovation-enabling technology. • Hindering innovation as it does not allow SMEs to create a cloud ecosystem to offer services and products for the Government. • Cloud services become less scalable and unable to respond to changes in demand. • Member States could unnecessarily increase capital expenditures and decrease operational efficiencies including weakening cybersecurity options. Leading public servants to maintain their own infrastructure and services instead of dedicating time to create further value to customers/citizens. ARTICLE 4 - FREE MOVEMENT OF DATA ACROSS BORDERS WITHIN THE UNION The Regulation states that grounds of ‘public security’ can constitute an exception to the rule of free flow of non-personal data. This term has not been defined in EU secondary legislation. The public security exception should not be broadened, or lead to any uncertainty in interpretation as to which data localisation measures could be justified on public security grounds. We seek clarification in a recital with regards to the meaning of public security in line with the interpretation of the European Court of Justice.[2] Regarding the oversight mechanism, it is not clear if the Commission has the power to block a draft act which it considers to be unjustified. In the case of data localisation, a notification procedure should be extremely robust and give clear blocking powers to the Commission in order to be effective. DIGITALEUROPE fully supports transparency obligations on Member States regarding justified data localisation measures. ARTICLE 6 – PORTING OF DATA The one-year deadline for all data service providers to effectively implement these codes of conduct is too short. More time will be needed to ensure all stakeholders are involved and to achieve a robust and future-proof result. Therefore, we suggest a more realistic timeframe.
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

6 Dec 2017

As part of the Cybersecurity Package, the European Commission’s Cybersecurity Act is based on two pillars, the second one proposing the creation of an European framework for Certification Schemes for ICT products and services. This proposal is of particular importance to DIGITALEUROPE, which had already expressed its views on cybersecurity certification and labelling schemes in March 2017 (see DIGITALEUROPE’s views on Cybersecurity Certification and Labelling Schemes, 23 March 2017: http://www.digitaleurope.org/DesktopModules/Bring2mind/DMX/Download.aspx?Command=Core_Download&EntryId=2365&language=en-US&PortalId=0&TabId=353) The proposed framework for cybersecurity certification plans to empower the European Commission to adopt EU-wide certification schemes for ICT products and services. DIGITALEUROPE welcomes the main objective of creating a harmonized EU market for cybersecurity certification schemes. However, we believe that the proposal put forward by the European Commission should be improved to guarantee higher participation and involvement of the industry and rely on market-adopted and global cybersecurity standards. The following key elements should, therefore, be taken into due account in the law-making process: - Self-certification and voluntary industry-led initiatives have to remain the first option EU cybersecurity certification: although the proposal is based on a voluntary approach, certification by national accredited conformity assessment bodies dismisses the possibility of self-certification; - The issue of the relationship and the compatibility of the EU certification framework with existing schemes and national certifications should be addressed; - The scope of the framework must be further clarified: at this stage, it is unbounded and unclear whether it is intended to cover all ICT products, services, or a combination of these; - Global standards shall remain the key reference to certification process in Europe. Except for National Security aspects, open global industry-driven standards relying on the market dynamics is the most efficient driver of increased security; - Security objectives of EU schemes should be adapted so that they better reflect the range of security certifications that will be adopted under the EU framework; - The proposal has to be more explicit about the openness and transparency of the preparation and adoption of certification schemes, to allow industry involvement; - Additional considerations relate to compliance and enforcement, to guarantee trust, security and a proper functioning of the European Single Market.
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Response to Evaluation of the Low Voltage Directive 2014/35/EU

27 Nov 2017

Dear Sir or Madam, As a key stakeholder representing the ICT industry, DIGITALEUROPE thanks the Commission for the opportunity to participate in the evaluation of the Low Voltage Directive and is ready to provide representatives to respond directly to the targeted consultations and other tools to be used in the evaluation. The LV-D is very much a success story in the history of EU legislation and it is remarkable that the Directive – largely unchanged from the original text - remains a relevant and highly effective tool in legislating for product safety in the 21st century. As the success of the Directive is evident – with product safety rates comparing favourable with other global regions – we do not anticipate a need for major changes to the scope or fundamental principles of the Directive. There are of course always opportunities to improve and the functioning of the Directive could benefit from consideration of modern concepts such as electronic labelling and documentation. In any case, we do look forward to actively participating in the evaluation. Yours sincerely, Klaus-Dieter Axt Policy Director DIGITALEUROPE klaus-dieter.axt@digitaleurope.org
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Meeting with Isabelle Magne (Cabinet of Vice-President Cecilia Malmström)

25 Oct 2017 · conflict mineral regulations

Meeting with Mariya Gabriel (Commissioner)

26 Sept 2017 · DSM priorities and policies

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

26 Sept 2017 · DSM; free flow of data; spectrum

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

20 Sept 2017 · Digital Assembly - Digital industry transformation - cybersecurity strategy - free flow of data

Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

6 Sept 2017 · Digital Single Market

Meeting with Pauline Rouch (Cabinet of President Jean-Claude Juncker)

11 Jul 2017 · Digital Single Market

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

22 Jun 2017 · Digitalisation Europe

Meeting with Andrus Ansip (Vice-President) and

12 Jun 2017 · Progress of DSM, data economy, better regulation

Meeting with Andrus Ansip (Vice-President) and

24 May 2017 · GDPR Implementation and Privacy Shield

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

17 May 2017 · Digital trade

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

11 May 2017 · digitisation of industry, entrepreneurship, SMEs

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

17 Apr 2017 · Digital Single Market

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

9 Mar 2017 · DSM Mid-term review

Meeting with Günther Oettinger (Commissioner)

7 Mar 2017 · digital policy

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

3 Mar 2017 · Data flows in trade agreements

Meeting with Violeta Bulc (Commissioner) and

17 Feb 2017 · Meeting with Markus Borchert, president of Digital Europe

Response to Commission Implementing Regulation -information provided for in Article 10 (10) of the RED 2014/53/EU

13 Feb 2017

Digital industry comments on the draft Implementing Regulation on Article 10(10) of RED DIGITALEUROPE wishes to express two main concerns that create challenges for manufacturers to place their class 2 Radio Equipment on the single market and suggests ways to improve the draft to a Better Regulation. Indication of EU Member States Article 2 of the Implementing Regulation specifies that if radio equipment is subject to restrictions on putting into service or to requirements for authorisation of use, as provided for in Article 10(10) of the Radio Equipment Directive, the packaging of the radio equipment shall indicate visibly and legibly a pictogram or wording, indicating the abbreviations of the Member States where such restrictions or requirements exist. The proposed draft regulation provides the Member States abbreviations that shall be used. Due to the fact that common cases of Radio Equipment (such as 5 GHz Wireless LAN access points) are subject to restrictions in all EU Member States, a list of at least 28 Member States shall be indicated on the packaging. As other country abbreviations, such as Turkey and EFTA Member States, will be required as well, this list of abbreviations will be very exhaustive. Manufacturers will need to assign necessary space on the packaging to indicate all these Member States in a visible and legible way. In addition, due to the possibility of changing EU memberships, updates of packaging might be required, causing unnecessary overhead to manufacturers. Therefore, DIGITALEUROPE requests to update Annex II with the flexibility to indicate the well‑known abbreviation ‘EU’ in case a restriction or requirement for authorisation of use exists in all EU Member States. This will simplify the information on the packaging and reduce the complexities for manufacturers. DIGITALEUROPE considers that consumers nowadays are well aware about ‘EU’ and will easily understand that such a restriction or requirement exists in the harmonised European Union covering all individual Member States. Time of application Article 3 of the Implementing Regulation proposes that this regulation shall apply as of 6 months after its entry into force. DIGITALEUROPE wants to point out that manufacturers have to go through a time consuming process for updating their product’s packaging to new requirements. Updating the packaging artwork, material planning, production, supply chain and placing on the market is very challenging to achieve in 6 months. In addition, one should take into account existing stocks of Radio Equipment without the new pictogram would need to be re‑worked, depleted or scrapped by the time of application. Therefore, to reduce the impact on current manufacturing operations and offer all manufacturers a suitable transition time to comply with these new marking requirements, DIGITALEUROPE suggests an extension of this transition window to at least 18 months.
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Meeting with Carlos Moedas (Commissioner) and

27 Jan 2017 · Digital Technologies

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová) and ITI - The Information Technology Industry Council

27 Jan 2017 · Privacy Shield and GDPR implementation

Response to Ecodesign requirements for electronic displays

17 Jan 2017

DIGITALEUROPE has reservations with the WTO notified draft display regulation. Despite providing significant amount of data to the process, our comments have been largely disregarded. We will detail our concerns around on-mode, standby, resource efficiency and information requirements in a specific paper. In the following we will focus on procedural aspects and the scope of the regulation. - When the review process started in 2011, assessment focused on energy efficiency and was limited to TVs and some monitors. Scope extension (resource efficiency requirements and information requirements) to all type of displays including displays integrated into other products (e.g. displays in machinery, white goods, computers) has not followed the procedural requirements of Directive 2009/125, to conduct a scientific impact assessment prior to defining the scope and content of a regulation. The JRC study on CCFL televisions is insufficient (position paper 11/2012) as it does not cover other types of displays, including displays integrated into a wide variety of other products. The scope of the regulation and all requirements should be backed up by data, rather than being chosen randomly without prior assessment of the “impact on the environment, consumers and manufacturers (…) innovation, market access and costs and benefits” (Directive 2009/125/EC Art. 15 4b). DIGITALEUROPE raised concerns in a series of position papers in 2012-2014 regarding information requirements for end of life for displays integrated in other products. - Under Directive 2009/125 (Art. 15 2a) any product regulated must represent a significant volume of sales and demonstrating significant improvement environmental impact potential without entailing excessive costs or compromising safety and functionality. The proposed restriction of gluing and welding for displays in industrial machinery and laboratory equipment introduces safety hazards. The specific design aspects of these products have never been considered. Therefore they should be completely exempted from the display regulation. - According to First Vice President Timmermans, better regulation impact assessments shall not only take place in the beginning but also when the scope is amended. By including all displays > 1 dm2 makes this draft a de facto horizontal regulation for end of life and information requirements thus requiring a new impact assessment. The costs vs benefits ratio of setting resource efficiency requirements for displays included in other types of products have not been studied and the reasoning that they are very similar to normal displays is not sufficient to justify their inclusion. - The lack of such a thorough assessment coupled with a continuously changing scope and requirements lead to the fact that the draft regulation will create disproportionate administrative burdens for a large number of manufactures, which have incorporated displays in their products. - The scope is very broad and the differentiation in requirements very confusing. Professional/broadcast/security displays, even though exempted from most of the energy requirements, still have to comply with the 0.3W power demand, which is very problematic. DIGITALEUROPE maintains that the scope of this draft regulation remains limited to TVs and computer monitors, and should not cover products for which no scientific impact assessment has been carried out and/or which are covered by other Ecodesign implementing measures or voluntary agreements. Those products should be subject to their own separate studies in line with MEErP. We call on the EC to clearly exclude all displays integrated into products, which as their primary function are not a display. We also ask the EC to critically re-assess the relevance to apply the same resource efficiency and related information requirements for specialized display products such as digital signage displays, professional displays, broadcasting and security monitors.
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Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

9 Jan 2017 · DSM general

Meeting with Andrus Ansip (Vice-President) and

19 Dec 2016 · Discussion with industry on general data protection regulation implementation

Meeting with Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

14 Dec 2016 · digital trade

Meeting with Laure Chapuis-Kombos (Cabinet of Vice-President Andrus Ansip)

23 Nov 2016 · e-privacy position paper

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

23 Nov 2016 · Free flow of data

Meeting with Julie Fionda (Cabinet of Commissioner Marianne Thyssen), Stefaan Hermans (Cabinet of Commissioner Marianne Thyssen)

8 Nov 2016 · Skills

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

27 Oct 2016 · Smartphones in the Ecodesign workplan

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

27 Oct 2016 · Radio-Equipment Directive

Meeting with Michael Hager (Digital Economy) and Business Software Alliance and

27 Sept 2016 · DSM

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and ITI - The Information Technology Industry Council

20 Sept 2016 · Data, privacy, copyright

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

16 Sept 2016 · digital trade

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and IBM Corporation

12 Sept 2016 · digital trade

Meeting with Günther Oettinger (Commissioner) and BUSINESSEUROPE and

8 Sept 2016 · Dual use

Meeting with Günther Oettinger (Commissioner)

5 Sept 2016 · DSM

Meeting with Kilian Gross (Digital Economy) and Siemens AG and Bitkom e.V.

28 Jul 2016 · trade policy

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

14 Jul 2016 · publishers rights, text and data mining, free flow of data

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

1 Jul 2016 · Digitising Industry initiative

Meeting with Andrus Ansip (Vice-President) and

30 Jun 2016 · Privacy shield, data protection

Meeting with Anna Herold (Digital Economy)

22 Jun 2016 · platforms

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

16 Jun 2016 · Telco review, investment in networks, spectrum

Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

14 Jun 2016 · Digital Single Market

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

13 Jun 2016 · DSM

Meeting with Michael Hager (Digital Economy) and Business Software Alliance and

3 May 2016 · DSM

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

3 May 2016 · Memorandum of Understanding

Meeting with Lucie Mattera (Cabinet of Commissioner Pierre Moscovici)

27 Apr 2016 · copyright issues and indirect taxation

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

27 Apr 2016 · Spectrum: 700MHz

Meeting with Anna Herold (Digital Economy)

13 Apr 2016 · copyright

Meeting with Michael Hager (Digital Economy) and ITI - The Information Technology Industry Council

8 Apr 2016 · platforms, DSM

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

14 Mar 2016 · DSM, cloud, data flows, platforms, skills

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová)

10 Mar 2016 · Working group on Digital issues – on copyright levies

Meeting with Szabolcs Horvath (Cabinet of Commissioner Tibor Navracsics)

4 Mar 2016 · Digital Single Market

Meeting with Michael Hager (Digital Economy) and Business Software Alliance and

23 Feb 2016 · DSM

Meeting with Kilian Gross (Digital Economy)

18 Feb 2016 · DSM

Meeting with Anna Herold (Digital Economy)

17 Feb 2016 · copyright

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

16 Feb 2016 · DSM, copyright

Meeting with Eduard Hulicius (Cabinet of Commissioner Věra Jourová), Simona Constantin (Cabinet of Commissioner Věra Jourová)

11 Feb 2016 · DSM agenda – online platforms, geoblocking and digital contracts

Meeting with Andrus Ansip (Vice-President) and

11 Feb 2016 · Next steps under DSM - discussion with Digital Advisory Council

Meeting with Günther Oettinger (Commissioner)

11 Feb 2016 · DSM

Meeting with Andrus Ansip (Vice-President) and

8 Feb 2016 · EU-US Privacy Shield

Meeting with Michael Hager (Digital Economy) and ITI - The Information Technology Industry Council

29 Jan 2016 · data protection

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

29 Jan 2016 · Safe Harbour

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

21 Jan 2016 · Copyright

Meeting with Anna Herold (Digital Economy)

18 Jan 2016 · copyright

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and ArcelorMittal and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

14 Jan 2016 · Telecom review - I4.0 - DSM - EU cloud

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

11 Dec 2015 · GDPR

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

8 Dec 2015 · Safe harbour / cross border data flows

Meeting with Bodo Lehmann (Digital Economy)

1 Dec 2015 · Safe Harbour

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

24 Nov 2015 · Digital single market, Single market strategy

Meeting with Günther Oettinger (Commissioner) and Google and

20 Nov 2015 · Digital transformation of the European industry

Meeting with Andrus Ansip (Vice-President) and

26 Oct 2015 · Digital Single Market, Data economy, Safe Harbour

Meeting with Andrus Ansip (Vice-President) and

14 Oct 2015 · Meeting with tech businesses after Safe Harbour ruling

Meeting with Anna Herold (Digital Economy)

13 Oct 2015 · copyright

Meeting with Bernd Martenczuk (Cabinet of First Vice-President Frans Timmermans)

23 Sept 2015 · Digital Trade

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

22 Sept 2015 · copyright

Meeting with Michael Hager (Digital Economy) and ITI - The Information Technology Industry Council

15 Sept 2015 · DSM

Meeting with Kamila Kloc (Cabinet of Vice-President Andrus Ansip)

8 Sept 2015 · geo-blocking, platforms, telco review

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

31 Aug 2015 · DSM

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and IBM Corporation

14 Aug 2015 · Digital Trade

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology)

27 Jul 2015 · DSM and Innovation

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

15 Jul 2015 · Digital trade

Meeting with Michael Hager (Digital Economy) and Business Software Alliance and

14 Jul 2015 · DSM

Meeting with Markus Schulte (Digital Economy)

13 Jul 2015 · DSM

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and ITI - The Information Technology Industry Council

24 Jun 2015 · TTIP negotiations

Meeting with Anna Herold (Digital Economy)

23 Jun 2015 · DSM

Meeting with Günther Oettinger (Commissioner) and ITI - The Information Technology Industry Council

22 Jun 2015 · DSM

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

9 Jun 2015 · Internal Market, Single Market for goods, standardisation, competitiveness

Meeting with Michael Hager (Digital Economy)

3 Jun 2015 · DSM

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

2 Jun 2015 · DSM & TTIP

Meeting with Alfredo Sousa De Jesus (Cabinet of Commissioner Carlos Moedas), Keith Sequeira (Cabinet of Commissioner Carlos Moedas)

18 May 2015 · Digital Single Market - Research and Innovation aspects

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology)

24 Apr 2015 · Digital Single Market

Meeting with Anna Herold (Digital Economy)

16 Apr 2015 · copyright

Meeting with Manuel Szapiro (Cabinet of Vice-President Maroš Šefčovič)

23 Mar 2015 · Energy Union follow up: digital agenda and energy efficiency

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström), Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

16 Mar 2015 · Conflict minerals

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

16 Mar 2015 · Digitalisation and interoperability of charges for mobile electronic devices

Meeting with Günther Oettinger (Commissioner)

13 Mar 2015 · DSM

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

12 Mar 2015 · Digital Single Market

Meeting with Michael Hager (Digital Economy) and Business Software Alliance and

20 Jan 2015 · Digital Agenda

Meeting with Edward Bannerman (Cabinet of Vice-President Jyrki Katainen), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

14 Jan 2015 · ICT and digital industries

Meeting with Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

17 Dec 2014 · Introduction of action and issues

Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

15 Dec 2014 · Trade aspects of the Digital Agenda

Meeting with Michael Hager (Digital Economy)

4 Dec 2014 · Digital Economy