EURALARM
Euralarm
EURALARM is the only European trade association representing the European Fire Safety and Security industry engaged in manufacturing, installing and servicing fire safety and security products and systems.
ID: 94201247949-87
Lobbying Activity
Response to Revision of the 'New Legislative Framework'
2 Sept 2025
Euralarm reviewed the call for evidence issued by the European Commission on revision of the New Legislative Framework (NLF) and wants to reiterate the considerations sent back in 2022 during the evaluation phase: - Improvements brought by NLF - On CE marking itself - On harmonised standards - On conformity assessment procedures - On notified bodies - On the accreditation system - On digitalisation of the information. See those considerations in the attached file.
Read full responseResponse to Revision of the Standardisation Regulation
14 Jul 2025
Euralarm has carefully reviewed the call for evidence issued by the European Commission on revision of the Standardisation Regulation. Besides the call for evidence itself, Euralarm also considered other Commission documents related to the whole context, e.g. the Omnibus IV initiative, the accompanying Staff Working Document SWD(2025) 130 about Common Specifications and the three published Common Specifications supporting the Medical Device Regulation and the Regulation on In Vitro Diagnostic Medical Devices: (EU) 2020/1207, (EU) 2022/1107 and (EU) 2022/2346. Euralarm is of the opinion that the majority of harmonised standards clearly specify the expectations of the products, devices and services intended and thus serve the practical needs of the sectors they cover. However, Euralarm also generally agrees with the observation that the current system for production and citation of harmonised standards doesnt deliver at a level that allows the Single Market to work as intended. We also generally agree with the text provided in the call for evidence under the headline Problem the initiative aims to tackle and listing the issues we can all observe. The attached Position Paper is based on those issues for which we would like to put forward some constructive proposals. Fundamentally, Euralarm agrees that simplification is needed to reduce the administrative burden on bringing products to the market but it is wholly inappropriate and misleading to focus on reducing the technical content of harmonised standards while increasing the complexity of the processes by which harmonised standards are regulated. The 1025 regulation is largely fit for purpose and familiar any changes need to make a significant difference to the administrative burden and not increase the complexity of bringing products to the market. Our proposals are detailed in the attached document.
Read full responseResponse to Digital Networks Act
9 Jul 2025
Euralarm takes the opportunity of the call for evidence issued by the European Commission on a Digital Networks Act to raise an issue faced by our members with the phasing out of mobile technologies. The attached Position Paper follows our briefing on risks and challenges of uncoordinated shutdown of 2G and 3G networks responding to the ECs White Paper "How to master Europe's digital infrastructure". It explains the issue, provides references highlighting it and proposes some elements for incorporation in the future Digital Networks Act. The proposal is also in line with Priority 3 (Empowering end-users) of BERECs draft Strategy 2026-2030 where they call for a close monitoring of the process for phasing out legacy networks to prevent negative impacts.
Read full responseResponse to Update of EU rules on radio equipment for reconfigurable radio systems
23 May 2025
Euralarm has carefully reviewed the call for evidence issued by the European Commission on enforcing Article 3(3)(i) and/or Article 4 of the Radio Equipment Directive and would like to repeat the answers sent back on 2 June 2020 to the Public Consultation on the upload of software into radio equipment: - no known concern in our sector; - strengthening regulatory protection would unnecessarily increase burden; - short Range Devices, IoT devices and short-range radiodetermination devices should not be in scope; - strengthening the Directive would not increase trust in products in our sector. Further details can be found in the attached position paper.
Read full responseResponse to Technical description of important and critical products with digital elements
18 Apr 2025
Euralarm is pleased to provide their feedback on the proposal from the European Commission for the technical description of 2 categories of products with digital elements: - Annex I, Class I, 17. Smart home products with security functionalities, including smart door locks, security cameras, baby monitoring systems and alarm systems - Annex II, 1. Hardware Devices with Security Boxes. See the feedback attached. Euralarm remains available to further discuss this topic.
Read full responseResponse to How to master Europe’s digital infrastructure needs?
27 Jun 2024
Euralarm is pleased to offer its thoughts on the White Paper published by the European Commission on February 21, 2024, titled "How to master Europe's digital infrastructure." The White Paper discusses the need to adapt spectrum management to meet the demands of the Digital Decade, including the coordinated shutdown of 2G and 3G networks while ensuring the continued support of essential legacy services such as emergency and critical communications. Euralarm would like to emphasise the potential risks and challenges associated with an uncoordinated and premature shutdown of 2G and 3G networks. (see attached document for argumentation and proposal)
Read full responseMeeting with Adam Jarubas (Member of the European Parliament) and European Chemical Industry Council and
15 Nov 2023 · EFSW2023: Taking stock of progress on fire safety – what should the Commission and Parliament do to improve fire safety in Europe?
21 Jun 2023
Euralarm, the European trade association representing the electronic fire safety and security industry, greatly appreciates the opportunity to comment on the proposal from the European Commission for a Delegated Regulation amending Delegated Regulation (EU) 2022/30 as regards the date of application of the essential requirements for radio equipment and correcting that Regulation. Making the radio equipment cyber-secure is a technical task that our members accomplish with care in order to ensure the reliability of their alarm systems. This is the main target but, in addition, the European legislation imposes through the New Legislative Framework (NLF) and its set of directives specific rules for the completion of the conformity assessment procedures. This step can currently not be completed. We have stressed the need for a sufficiently long transition period at several occasions during the preparation process of the initial Delegated Regulation within the Expert Group on Radio Equipment and several pure facts show today that the current applicability date is not sustainable. This Position Paper provides these facts and their foreseen consequences advocating in support of the proposal from the European Commission. (see document attached)
Read full responseResponse to Promoting sustainability in consumer after-sales
25 May 2023
Euralarm, the European association representing the electronic fire safety and security industry, greatly appreciates the opportunity to comment on the proposed Right to Repair Directive. Our comment is developed in the attached document.
Read full responseResponse to Cyber Resilience Act
20 Jan 2023
Euralarm, the European trade association representing the electronic fire safety and security industry, has for more than 2 years asked for a horizontal legislation on cybersecurity for products instead of adding pieces of cybersecurity provisions in vertical legislations. The proposal for a Cyber Resilience Act pushed forward by the European Commission has therefore been carefully assessed by our members to highlight the principles that we find particularly beneficial to our industry, our customers and the users of our systems and the rooms for improvement. This Position Paper provides our view on the elements of the proposed CRA that should be kept for the published legislation, identifies some unclarities that, if maintained, would lead our manufacturers into some legal uncertainty and proposes several amendments to the text.
Read full responseResponse to Review of the Construction Products Regulation
6 Jul 2022
Euralarm, representing Europe’s electronic fire safety and security industry, a sector whose products are already largely subject to the existing CPR, welcomes the publication of Commission’s proposal for a new CPR. However, we have a number of concerns and we are believing that some suggestions presented in the position paper attached will contribute to a clearer regulatory environment for the construction sector if the proposal goes ahead ...
We note that the legal framework proposed is very flexible and, contrary to the consultation process, makes fundamental changes to the CPR. However, the times scale for the introduction of the new legislation, coupled with complexity of options and need for delegated acts to establish the details and consequences for our sector, fail to address the core issue which is, that the EU standardization process has stagnated under the weight of the legal interpretations and obligations of the current CPR.
Notwithstanding this fundamental observation we provide input into the Commission’s proposal consultation to address key points for our industry and also to make proposals for improvement of a new CPR-regulation.
We welcome:
CE-marking being still a part of the new CPR and a stronger Single Market
increased focus on sustainability
the use of digital tools
empowerment to adopt delegated acts to avoid double assessment of products
product requirements now being in the new CPR becoming mandatory by delegated acts
We call for clarifications and ask for reconsideration on the following points:
Complexity and missing simplification
Scope
Product requirements
Double testing
Modified declaration of performance for used, remanufactured and surplus products
Declaration of Conformity
Product marking
Obligations on manufacturer
Construction products standards and derogations and transitional provisions
Standardization
Product information requirements
for details see our position paper attached.
Read full responseResponse to Sustainable Products Initiative
20 Jun 2022
Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give feedback on the proposal for ESPR.
We generally support the proposal but also wishes to raise some comments, concerns and proposals. Orgalim’s position paper on this same initiative provides general considerations that Euralarm supports. In addition, we would like to raise additional concerns that are more specific to our sector. These can be read in our Position Paper attached to this feedback.
Read full responseResponse to Standardisation Strategy
22 Jul 2021
Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give comments and suggestions on their roadmap to a Standardisation strategy.
Standards, both harmonised and non-, are important tools for the fire and security industries. They ensure a high level of performance, reliability and robustness for safe and secure buildings across Europe, they mitigate risks, increase customers’ confidence, contribute to removing trade barriers and, when they are harmonised and cited in the Official Journal of the European Union, they provide presumption of conformity in all the 27 Member States.
Euralarm considers the European Standardisation System (ESS) a successful system, which allows for the development of open, voluntary, market-driven, and consensus-based standards. Yet, in recent years the system has been put under pressure from internal challenges linked to harmonised standardisation.
As major users of harmonised standards and key voluntary contributors to the European Standardisation System (ESS) and to international standardisation, our industry is keen to contribute to the design of the EU Standardisation Strategy and would like to provide feedback to the Standardisation Strategy Roadmap published by the European Commission on 28 June 2021.
By the attached position paper, Euralarm wishes to provide specific answers to the three questions which the Commission put to stakeholders for feedback. Besides these focal points, Euralarm generally supports the comments from Orgalim.
Read full responseResponse to Requirements for Artificial Intelligence
12 Jul 2021
Euralarm, the European association representing the electronic fire safety and security industry, welcomes the opportunity provided by the European Commission to give comments and suggestions on their proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL LAYING DOWN HARMONISED RULES ON ARTIFICIAL INTELLIGENCE (ARTIFICIAL INTELLIGENCE ACT) AND AMENDING CERTAIN UNION LEGISLATIVE ACTS.
Euralarm welcomes the proposal from the European Commission. We are convinced that the uptake of artificial intelligence is dependent on the trust of the users and the general public for this technology and their general acceptance of it. The proposal for a legislation on the existing concerns is certainly a way to help this uptake by avoiding national legislative initiatives.
The attached position paper focuses on proposals and comments regarding the following aspects of the proposed AI Act:
- definition of AI system
- prohibition of real-time remote biometric identification
- classification as high-risk
- common specifications.
Besides these focal points, Euralarm generally supports the more detailed comments from Orgalim.
Read full responseResponse to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products
2 Dec 2020
Euralarm, the European association representing the fire safety and security industry, welcomes the opportunity provided by the European Commission to give comments and suggestions in view of the evaluation of the New Legal Framework (NLF).
We generally consider the NLF as a very effective framework for the European single market for goods. It appropriately copes with the protection of the end-user safety and the possibility to innovate and compete on the basis of clear and common rules for products. The arrangement of horizontal legislations (EMCD, LVD, RED …) and vertical ones (CPR …) is a performing approach to allow for adequate and specific conformity assessment procedures.
We still see some room for improvement and this paper focuses on the following aspects:
- changes to products during their lifetime;
- conformity assessment procedures;
- rules for notified bodies;
- accreditation system;
- affixing the CE marking and other product information;
- citation process of harmonised standards.
Please find attached our Position Paper.
Read full responseResponse to Requirements for Artificial Intelligence
10 Sept 2020
Euralarm welcomes the inception impact assessment on Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence. Euralarm shares the view that artificial intelligence (AI) can drive economic growth and improve the security and safety for the benefit of the citizens, the economic actors and the Member States by enabling new products, services and solutions.
For AI-enabled products, Euralarm is in favour of Option 1 of the alternative options to the baseline scenario: “soft law” (non-legislative) approach to facilitate and spur industry-led intervention (no EU legislative instrument). Embedded AI-based applications are considered products both by the EU (1) product safety legislation (before the placing on the market) and in the (2) Product Liability Directive (PLD - after the placing on the market). While the first set of rules imposes essential safety requirements for products to be assessed and thus distributed onto the market, the latter aims at compensating victims for the harm suffered from the use of defective good. Hence Euralarm doesn’t see any need for additional legislation addressed to AI-enabled products. Nevertheless, this “soft law” should be accompanied by provisions ensuring that no national rules would impair the free circulation of these products.
For AI-enabled services, Euralarm is in favour of Option 3.b: EU legislative instrument establishing mandatory requirements for “high risk” applications. The qualification of “high risk” should not be a consequence of an intended use or sector but should be based on a risk analysis. In order to ensure liability, the risk analysis should be guided by a list of clearly identified risks. However, this requires more detailed analysis and discussions with the industry, especially when it comes to the different levels of risks generated by AI applications. In Euralarm’s view, the quality of any future regulation will depend on the possibility to identify a common, transparent and easily applicable definition of “AI” and understanding of “high-risk”. High-risk situations should be defined in cooperation with industry, based on risk-benefit considerations and adjusted when needed.
Euralarm believes that the rollout of AI must not come with the new regulation as per se. The new regulation must be used only where it is necessary (e.g. addressing clear and proven risks) and where it delivers clear benefits (e.g. helps to uptake the new technologies by creating a level playing field, ensures safety etc.). General scrutinising of AI-technologies which hampers innovation and creates uncertainty must be avoided. Clear criteria must be established for identifying critical areas in a way that is legally certain.
Europe’s security and safety industries represent companies that innovate at the crossroads of digital and physical technology. AI offers opportunities to European industries not only for further grow at global level but also to build a safer and more secure Europe, provided that the right choices are made, particularly at EU level, to support its development and deployment.
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