EUROPE INDIA CHAMBER OF COMMERCE

EICC

The Europe India Chamber of Commerce (EICC) is a non-partisan business advocacy organization that promotes bilateral trade and economic relations between the EU and India.

Lobbying Activity

Meeting with Morten Løkkegaard (Member of the European Parliament, Delegation chair)

29 Feb 2024 · Incoming Indian Ambassador

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

16 Aug 2023

The EU's Cybersecurity Framework provides guidance to organizations to better understand, manage, reduce, and communicate cybersecurity risks. It is a foundational and essential resource used by all sectors around the world. Despite evolving cybersecurity risks, it is recognised that cybersecurity certification framework remains effective in addressing cybersecurity risks by facilitating governance and risk management programs and enhancing communication within and across organizations. The CSF has been adopted voluntarily and in governmental policies and mandates at all levels around the world, reflecting its enduring and flexible nature to transcend risks, sectors, technologies, and national borders. The CSF is intended to be a living document that is refined and improved over time. The statutory authority for the CSF directs to facilitate and support the development of the Framework and coordinate closely and regularly with relevant organizations. EU's Cybersecurity frameworks provide a useful foundation for integrating cyber security risk management into our security performance management and third-party risk management strategy. With a framework as our guidepost, EU gains vital insight into where its highest security risk is and feel confident communicating to the rest of the organization that we are committed to security excellence. To address the challenges of cybersecurity, the EU did a commendable job through its General Data Protection Regulation (GDPR) which was adopted in 2016 to strengthen data protection procedures and practices for citizens of the European Union (EU). The GDPR impacts all organizations that are established in the EU or any business that collects and stores the private data of EU citizens. The prevalence, diversity, complexity, and severity of existing and emerging cyber threats require a shift from reactive ad-hoc responses to a more structured, cohesive, and strategic approach to addressing cyber threats in a manner that respects human rights. As a result, many governments around the world are increasingly turning to the development of national cybersecurity strategies to address a broad range of issues at the policy level, providing a strategic pathway and framework to doing so in a sustainable way. It is important at this juncture to acknowledge that while the current framework cannot address all EU governments digital agenda in its entirety (for example the considerations around government digital migration and national connectivity programs), it stands as a good interlocutory for those initiatives and considers security by design.
Read full response

Response to Revision of EU rules on textile labelling

5 Aug 2023

As the increasing understanding of the environmental impact of textile production and consumption has not so far been materialised in effective policy tools of the challenges, ecolabeling will therefore help consumers to select environment friendly products, while meeting high demands on occupational health, safety, and usability. Ecolabeling will also help undertake cradle-to[1]grave approach which will help in minimizing the toxicological impacts at every stage of the product life cycle. The ecolabeling procedure should call for substitution or reduction of hazardous substances thereby reducing the toxicity caused due to chemicals. It is good that the EU is leading in the race of awareness and implementation of ecolabeling schemes. In our view, the Ecomark scheme must not lack adoption of the green marketing principles and must not fail to create an impact. At the same time, the EU should recognise that the global textile retailers are however sceptic to use eco-labels actively in the marketing of their products and they definitely prefer global labels. Ecolabels are a success in most of the countries and are being applied across a range of industrial sectors. It is important to create awareness among retailers and traders of stores selling environment friendly textile products across EU countries. Although the retailers and traders of environment friendly products have low awareness of the ecolabels on environment friendly products, they are taking considerable efforts to promote and deliver environment friendly products to consumers. EU must engage in large-scale awareness drives with the involvement of stakeholders which could prove beneficial for promotion of the ecolabeling schemes. Concern for environment is an important issue and practically every industry is up against problems of pollution control, with the textile industry bearing the heaviest weight, the more so in the wet processing segment. The need to face the formidable challenge from the major players in the international market, the need to produce textiles in an eco-friendly way and guarantee them to be free from harmful chemicals must become become paramount. Most of the criteria for ecolabels are product-based at present and the limit of harmful chemicals varies with the intended use of textiles. It is in this background that ecolabels must be introduced all over EU. This represents a problem in the consumer market because the national labels are well known and trusted among consumers, while the regional and global labels are not to the same degree recognised and identified by the consumer. The tendency to political consumption in the textile and clothes market in Europe is rather weak. It is possible to identify a health dimension, but the main parameters in the consumer choices are price, quality and design. Ecolabels are a success in most of the countries and are being applied across a range of industrial sectors. It is important to create awareness among retailers and traders of stores selling environment friendly textile products across EU countries. Although the retailers and traders of environment friendly products have low awareness of the ecolabels on environment friendly products, they are taking considerable efforts to promote and deliver environment friendly products to consumers. EU must engage in large-scale awareness drives with the involvement of stakeholders which could prove beneficial for promotion of the ecolabeling schemes.
Read full response

Response to Guidelines on exclusionary abuses of dominance

18 Apr 2023

EU's Competition Law is a complex mixture of legislative, economic, and administrative measures designed to foster competition in the economy. Since competition is considered essential for economic development, competition law seeks to protect this competitiveness. The theory behind competition law is the positive effect of competition on the market of an economy, acting as a protection against the misuse of dominant undertakings. The idea of the concept of abuse is very objective as it relates to the behavior of the undertaking placing itself into the dominant position to influence the structure of a market. This involves the presence of the dominant entity on the market and the degree of competition is weakened by the use of methods adopted by the entity that are different from the generally normal conditions in the competition of product or service transactions. This has an effect that hinders the maintenance of a healthy degree of competition that still exists in the market and the growth of such competition. Under EU competition law, it is not illegal to hold a dominant position, since a dominant position can be obtained by legitimate means of competition, for example by inventing and selling a better product. Dominance is not treated bad per se; it is the abuse of dominant position which is prohibited. Thus, the Competition law must prohibit such behaviour, as it damages true competitions between firms, exploits consumers and makes it unnecessary for the dominant undertaking to compete with the other firms on the merits. Most competition laws across the globe primarily deal with three areas namely, anti- competitive agreements, the abuse of dominant position and mergers/combinations. Ordinarily, merely the fact that a firm or enterprise is in a dominant position is not prohibited by competition laws. Any abuse by one or more undertakings of a dominant position on the market should be prohibited. It is important to strengthen the primarily three stages in determining whether an enterprise has abused its dominant position, and they are Relevant Market, Degree of Market Power / Monopoly Power in that relevant market and Determining whether the undertaking in a dominant position has engaged in conducts specifically prohibited by the statute or applicable law. It is also necessary for EU regulators to define the relevant geographical market when determining a dominant position of an undertaking.
Read full response

Response to Review of the CO2 emission standards for heavy-duty vehicles

22 Mar 2023

The largest source of carbon emissions in EU is the transportation sector. Todays policies that concentrate on low-carbon fuels for road transportation may become more problematic over time. This is therefore the time for EU to show leadership, by transforming its transport sector, and at the same time achieving sustainable development benefits such as reducing air pollution, climate change impacts, fossil fuel import dependency, contributing to economic development and the creation of jobs. These benefits would also be supportive of many social and economic challenges faced by EU. An efficient transport system is crucial for EU as it witnesses rising demand for transport services and related infrastructure. As mobility needs of the EU countries are increasing, the subsequent impacts are also intensifying. With road transport sector becoming one of the major contributors towards GHG emissions, air pollution, congestion and several other negative externalities, various policy measures need to be implemented to make the sector more efficient. Coordination and collaboration between EU governments' policies and actions of non-state actors in the form of awareness campaigns, capacity building initiatives and policy research can strengthen the implementation of these policy measures. While technological improvements will reduce emissions per truck, additional measures are still needed at the EU level to address emissions from older vehicles. This will require stringent emissions regulations for the on-road older fleet, and implementation of fuel economy regulations to reduce energy impacts of road-based freight. Policy and public awareness related to heavy duty vehicle carbon emission will have to be enhanced significantly to accelerate action and protect public health. Several short- to medium-term strategies are needed both at the EU governments level to cut toxic pollution and greenhouse gas emissions. This will require follow up of the rigorous emissions standards and technology roadmaps to clean up the fleet, urban and regional strategizing of heavy duty truck movement for spatial planning of commercial hubs, and eco-driving approaches. To counter the trend of increasing fuel consumption and rising emissions along with meeting the EU commitments, a set of policy measures should be implemented by the EU member States in the transport sector. In order to ensure that the policy measures are effective in de-carbonizing the road transport sector, it is important to build a holistic approach for confirming strong implementation and compliance of various policy goals. To this end, a multi-stakeholder approach which includes contribution and actions from civil society, trade bodies, corporates, think tanks and other public and private actors through decentralized action can play a crucial role in bringing down emissions from road transport sector. EU's policies aimed at road transport can begin the process of developing and commercializing alternative energy-dense liquid fuels. The challenge of decarbonizing the transport sector and the technologies to overcome the challenges are global. Efficiently regulating and transforming the heavy transport market will rely on close coordination between technology and policy. Over time, EU policy will need to adjust to directing these fuels to where they are most needed, as EU aims to move the entire transportation system toward zero emissions. Green Hydrogen can play a critical role in decarbonizing this sector by fuelling fuel cell vehicles. The EU, like India has several opportunities to tap into the potential of Green Hydrogen. India has announced a $2.3 billion plan to promote green hydrogen -- hydrogen produced with renewable energy -- which could be the clean fuel of the future. The initiative could help the worlds third-largest emitter of greenhouse gases reach its goal of net zero carbon emissions by 2070.
Read full response

Response to Recommendation on covert interference from third countries

21 Feb 2023

European Union society is characterized by the value placed on democratic ideals, respect for individual freedoms, equality of opportunity for all people, and a commitment to the rule of law. The quality and resilience of its democratic institutions and processes are key foundations of European way of life. Protecting democratic institutions and systems is critical to EU's efforts to counter foreign interference and is essential to maintaining a healthy and robust democratic society. Democracy is fundamentally based on trust trust of each other, trust in institutions and trust in the credibility of information. Influence operations, in particular those run by foreign governments or malicious non-state actors, can pollute an information environment, eroding trust and muddying the waters of public debate. If EU appears not able to defend itself against foreign interference in its democratic institutions, it may look weak, and its global allies may begin to question whether the EU can be an effective ally. There are attempts by foreign interference at all levels of the EU institutions (Qatar Gate for example), and in Member States. Foreign powers are seeking to undermine confidence in the integrity of EU's elections. They also attempt to cultivate or recruit officials including potential future candidates and people that work closely with them, to gain a coercive or clandestine influence over EU governments decision-makers. To protect EU's right to self-governance, its law bans foreign nationals, including foreign citizens and governments, from spending in any country and in local elections. However, the laws governing EU's campaign finance system have failed to catch up to the digital age. Malicious influence operations are a growing problem in EU, exacerbated by social media platforms that enable the scale-up of misinformation, disinformation, propaganda and information disruption operations and new algorithmic technologies that might potentially cause it to even distrust EU in own eyes. Modest, but meaningful, changes are possible and necessary to counter interference. Broadly, countering the problem means addressing three aspects: exposure, receptivity and counter narrative. Another method for countering influence operations is to build up peoples online immunity so that they have less receptivity to misleading, false and polarizing information. A strong policy to prevent foreign interference in EU elections must include updating its treatment of digital campaign ads and requiring disclosure of the true source of campaign funds. Also, lawmakers should prohibit spending in elections by foreign-influenced corporations and extend the foreign national ban to prohibit spending to influence ballot measures. They disrupt the twin bedrocks of effective democratic governance: the free flow of information and trust. Countering these operations is both necessary and possible. Such efforts require the engagement of not only governments but also the platforms. Working together, these actors can preserve liberal democratic governance by minimizing exposure to fake news and other influence operations, promoting user immunity, and promulgating counter narratives to misinformation. It is not out of context to state that world's largest democracy, India was and has been the target of Chinas operations focused on its political and electoral processes. Chinas approach to disinformation, the unique characteristics of Indias digital public sphere, the proliferation and dominance of Chinese apps in India, has China encouraged in multiple levers to interfere in Indias elections and has shown an increasing willingness to exercise them elsewhere. To combat this, the Indian government has taken some hard and unpopular decisions to save democracy and EU too should follow.
Read full response

Response to Humanitarian aid evaluation 2017-2022

9 Feb 2023

The EU is one of the largest single providers of humanitarian assistance worldwide, but it needs to be better attuned to the challenges and opportunities of the 21st century. This assistance has provided life-saving assistance to tens of millions of displaced and crisis-affected people, including refugees, worldwide. The unparalleled flow of resources into the humanitarian sector can be seen as a reflection of new generation of international relations by EU whereby borders and sovereignty no longer define the boundaries of humanitarian action. The expansion in humanitarian space should also be seen as an expression of EUs global responsibility and its increased willingness to invest in accessing conflict-affected populations. The World is at an inflection point, with a confluence of crises that present significant challenges and opportunities for how the next few decades will be shaped. The world also faces terrible suffering brought on by natural and man-made disasters, and EU's humanitarian aid can play a critical role in preserving stability. However, there is a need to modernize EU's humanitarian assistance. EU's humanitarian assistance should be oriented towards a new narrative that resonates globally by focusing on select high-impact areas and leveraging EU's influence to advance the reform in the recipient countries. Nevertheless, like any investment or aid programme, this assistance is not without its pitfalls and blind spots. EU cannot ignore or look away from these challenges and moral hazards simply because of the noble humanitarian mission; in some cases, humanitarian aid does more harm than good. In the last two decades, there has been huge growth in EU's humanitarian assistance in terms of its activities and funding to many countries. This needs EU to become more professionalized in its adaptability to different contexts and emerging challenges. EU just cant afford reaching in every crisis and there needs to be sort of real observation of the needs and how the assistance is used. EU should not be naive to believe that there is not a political aspect to humanitarian assistance. In every situation, politics must be considered. There are choices to be made and unfortunately, in some circumstances, EU's aid has made situations worse and that there is a moral hazard to some of EU's humanitarian assistance because of the political aspects. In this context we would like to submit that does it make sense for EU to fund different types of humanitarian actors, which adopt very different interpretations of their roles and functions in conflict situations? Should EU strive for greater consistency and coherence in its approach? Should EU respond to complex political emergencies whether it has a geostrategic interest? Should EU and its member countries give more support to multilateral initiatives, for example, by increasing payments to the UN for peacekeeping? In the absence of effective and legitimate state structures in conflict-affected countries to guide decisions regarding the allocation of aid resources, should there be a global mechanism in place to coordinate needs assessment and to channel resources accordingly? It is important to point out that there is widespread agreement that EU's and aid from other sources to Pakistan has not been spent effectively over the past decade. Whenever, EU and international community has offered humanitarian assistance to the country, global concerns have erupted due to massive corruption in Pakistan's relief surfaces. EU should take this seriously and it should be concerned over repeated instances of corruption in humanitarian aids. Given the form of the aid and assistance relationship between EU and Pakistan, it is not so obvious what the objectives and purpose of EU humanitarian aid to Pakistan really are. Therefore, there must be conditions attached to the EU's assistance. Also, the EU must not provide countries incentives to act counter to EU's foreign policy objectives.
Read full response

Response to EU rules on fighting against corruption

30 Jan 2023

Corruption in public life has for long been a subject of much debate and ways and means of its eradication have been outlined by EU countries. Corruption in public life in the EU is a means of obtaining personal benefit through illicit means and the abuse of public office and property. It poses significant threat to EUs rule of law, economic development, democracy, social cohesion, and its national security. It also undermines public trust and weakens the integrity of EU's financial system when officials and law makers indulge in unethical behaviour and there is abuse of public office and property. Merely adopting a new anti-corruption law, creating another commission, or launching another campaign will not get the EU fight the corruption. Corruption in the EU is a symptom of a larger disease the failure of EU institutions and governance, resulting in poor management of revenues and resources and an absence of effective delivery of public goods and services. EU needs to be more strategic and rigorous, identifying and addressing corruptions underlying causes and examining the weaknesses in key institutions and government policies and practices. EU also needs to focus its efforts on the broader context of governance and accountability. With public trust in the EU and its institutions waning, strategy on countering corruption should build on laying out a comprehensive approach for how the EU works domestically and internationally. The strategy should place special emphasis on the transnational dimensions of the challenges, including by recognizing the ways in which corrupt actors have used the EU financial system and other rule-of-law based systems to launder their ill-gotten gains. Our submission is also drawn up in the background of recent bribery scandal at the European Parliament. The seizure of huge amount of money in the homes of EU lawmakers, leading to possibly the biggest bribery scandal in recent years in EU has robbed EU citizens trust in EU institutions. It has degraded the business environment, subverted economic opportunity, and exacerbated inequality. As a fundamental threat to the rule of law, corruption in EU has hollowed out institutions, corroded public trust, and has fueled popular cynicism toward effective, accountable governance. When money and resources available to the EU are diverted by corrupt officials instead of being channeled for the benefit of EU citizens, the clock turns back on social and economic development. To effectively counter corruption, the EU needs to consult and coordinate with representatives of civil society, trade bodies, the private sector, international and multilateral organizations, government partners, researchers, and the legislative bodies. To curb corruption and its deleterious effects, the EU member States should organize their efforts around the following mutually reinforcing pillars of work: modernizing, coordinating, and resourcing EU Government's efforts to fight corruption; curbing illicit finance; holding corrupt actors accountable; preserving and strengthening the multilateral anti-corruption architecture; and improving diplomatic engagement and leveraging foreign assistance resources to advance policy goals. By pursuing concrete lines of effort that advance strategic objectives under each of these pillars and integrating anti-corruption efforts into relevant policy-making processes, the EU can lead in promoting prosperity and security for the EU citizens. The EU has had a number of resources focused on combating domestic corruption, including the participation of public officials in commercial activities, political gifts and contributions, and private commercial bribery. The EU should look at India's Right To Information Act (2005) which has helped to break and bridge the gap between the government and its people, and how this has ensured transparency by letting its people be aware of what and how the country functions.
Read full response

Response to Preventing and combating trafficking in human beings - review of EU rules

19 Jan 2023

Human Trafficking exists in every region of the EU and poses a grave danger to individual well-being, public health, public safety, national security, economic development, and prosperity. While EU seems committed to strengthening its approach to preventing human trafficking addressing the cause of human trafficking is fundamental to achieving this desired objective. It is proposed that EU enhances its outreach and education efforts to prevent human trafficking, enhance community-coordinated responses, re-examine existing initiatives to reduce demand and encourage research and evaluation of future initiatives. EU must also take steps to build capacity to prohibit goods produced with forced labour from entering EU markets and stop those seeking to criminally benefit from forced labour overseas. It is important that EU partners with trafficking survivors for outreach and policy development, actively engage with EU Member States to build effective human trafficking responses across EU, build relationships with existing human trafficking taskforces and develop new taskforces in Central and Eastern Europe, in particular. In addition, EU must prosecute traffickers, support prosecutors and Law Enforcement, train and collaborate to raise awareness, strengthen on collection and sharing trafficking intelligence, collect and analyze human trafficking data, create victim service online platform. Promoting training for front-line service providers, support and develop new human trafficking awareness campaigns within EU, provide assistance to communities to identify people and places most at risk, distribute awareness materials at the Embassy of the EU Member States and EU Delegations abroad. Among many causes, poverty remains the main cause behind human trafficking. Other causes are porous nature of EU borders, corruption in law agencies, the involvement of international organized criminal groups or networks and limited capacity of or commitment by immigration and law enforcement officers to control borders. There is a need to ensure that the relief and rehabilitation process takes place in a smooth manner. Lack of uniformity in EU states towards human trafficking encourages human trafficking (Portugal) provides temporary residence permit which attracts human traffickers to use humans to "export" to EU. EU must also see that protection from humanitarian associations and equally government policies under Geneva Convention are not abused and exploited by applicants. Outsourcing of visa applications by the European Embassies have helped multiply Visa frauds. It is important to address the Tourists, Business and Student visas carefully and only who qualify be allowed to enter EU.
Read full response

Response to Vaccine-Preventable Cancers

16 Jan 2023

In EU countries, a substantial number of preventable cancers can be attributed to non-tobacco risk factors including infections, alcohol use, dietary factors, physical activity/body composition, and environmental and occupational exposures. Vaccination is the most cost effective and powerful weapon of prevention. Vaccination is one of medicines greatest accomplishments, reducing and in some cases eradicating once life-threatening diseases. Primary prevention of cancer is an important goal of EU, as this alone can reduce cancer incidence. Given the high burden imposed by risk factors such as physical activity and body fatness, investment in built environments could offer an important strategy for prevention of non-tobacco risk factors of cancer. The increasing prevalence of cancer demands a planned approach to reduce its burden on both individuals and society in the EU countries. Strategies which may be effective in reducing the incidence of new cancer cases include continued and sustained effort in tobacco control, focus on early diagnosis of cancers (including innovative health communication strategies to increase awareness), and strengthen health promotion strategies through existing health programs to include cancer risk factors. Prevention and control of Cervical cancer require a concerted effort to improve awareness among women regarding primary and secondary prevention strategies as well as access to care for treatment and palliation. Introduction of non-cytological screening by HPV test and VIA has brought a paradigm shift in the cervical cancer screening. There is a need to generate awareness among the general population and train healthcare professionals in diagnosing cancers at an earlier stage. Similarly, the successful implementation of HPV vaccination programmes also needs the support from the primary healthcare system like any other vaccination programme. Organizing HPV vaccination centers in schools and colleges for vaccination could be useful. In our opinion, the world is witness to the many epidemics and pandemics to date (COVID-19 2019) and a threat of emerging and re-emerging diseases is quite real in the near future. Therefore, this seems the right time for EU to invest to set future priorities to find significant gaps in the uptake of vaccination beyond childhood. Furthermore, a consensus must be agreed upon by the policymakers, civil society groups, non-political organizations and this life course vaccination approach must embed with the current programme and policies. In addition to the above, social media offers a communication tool for disseminating and interacting with youth and young adults about HPV vaccination, given their daily message exposure on these platforms. Preventing cancers caused by HPV through vaccination remains a significant public health priority in the EU member states. Given that young adults' daily exposure to social media typically encompasses lifestyle, identity, and entertainment messages, vaccine intervention strategies that evoke interest and curiosity about HPV vaccination in the competitive message environment will be needed. Social media is a powerful tool that has the potential to revolutionize health interventions. Dissemination of HPV vaccine messages will differ depending on the social media platform, but different strategies and a comprehensive strategy are recommended to adapt vaccine interventions and increase reach to connect with potential users who may benefit from HPV vaccine message. It is important in the context of the Commissions proposal to European Parliament and Council to examine the system of incentives and obligations to boost innovation and ensure better access to first-line medicines and vaccines, it is important that the EU collaborates with pharma companies for affordable vaccines and medicines. India being the largest producer of vaccines and affordable drugs, it will be helpful if EU and India can work together.
Read full response

Meeting with Dermot Ryan (Cabinet of Commissioner Phil Hogan)

18 May 2020 · future EU-India trade relations