European Committee of Electrical Installation Equipment Manufacturers
CECAPI
Cecapi represents the Associations of Manufacturers of Electrical Installation Equipment within the member states of the European Union and the EFTA region.
Please find attached CECAPI's position to the European Commission's call for feedback in view of the Omnibus Regulation Aligning product legislation with the digital age.
Please find attached CECAPI's position to the European Commission's call for feedback in view of the Omnibus Directive Aligning product legislation with the digital age.
CECAPI (European Committee of Electrical Installation Equipment Manufacturers) has prepared the following answer to the CALL FOR EVIDENCE FOR AN IMPACT ASSESSMENT related to the reconfigurable radio systems initiative: Amongst the policy options, CECAPI supports Option 1: industry self-regulation, which is non-legislative and aims to raise awareness through guidance on managing software updates and ensuring ongoing compliance throughout a devices lifecycle. This guidance could clarify how manufacturers should handle software changes and emphasize that standards should prevent users from altering critical settings that could compromise essential requirements. For most radio devices, with unchanging firmware, this issue is minimal. Only Software Defined Radios (SDRs), capable of reconfiguring parameters via software, require manufacturers to ensure continued compliance. Most firmware updates typically add functionalities without affecting essential health and safety requirements. Hardware design remains the primary factor in safety, and software updates are unlikely to significantly alter compliance or safety risks. Therefore, CECAPI believes that additional regulation may not be necessary given the low risk, but if regulation is considered, it should be proportionate and risk-based. Any new administrative requirements should be limited to high-risk product categories and should not hinder innovation or competitiveness. EU legislation should promote innovation and growth, and encourage policymakers to follow principles that reduce regulatory burdens.
CECAPI, the European coordinating committee representing the Associations of Manufacturers of Electrical Installation Equipment, would like to submit the following comments to the Public Consultation to harmonize metrology requirements for electric vehicle charging stations and hydrogen refilling stations.
CECAPI, European Committee of Electrical Installation Equipment Manufacturers, would like to submit the following comments to the draft ANNEX of the Commission Delegated Regulation (EU) amending Regulation (EU) 2023/1804 of the European Parliament and of the Council as regards standards for wireless recharging, electric road system, vehicle-to- grid communication and hydrogen supply for road transport vehicles.
CECAPI, European Committee of Electrical Installation Equipment Manufacturers, supports the EU energy savings objectives for 2050 and the transition towards a more circular economy. CECAPI has analysed the new updated draft Ecodesign requirements for external power supplies and its updated draft Annex. The attached document contains the CECAPI comments to the draft Act regarding Ecodesign requirements for external power supplies. CECAPI kindly requests that the following comments to be considered during the ongoing review of Regulation 2019/1782, and we are open to further discussions and collaboration to achieve regulations objectives while increasing the understandability and increase the consistency between regulations.
CECAPI, representing the Associations of Manufacturers of Electrical Installation Equipment, appreciates the efforts of the European Commission to address the current timing constraints faced by the European Standardization Organizations (ESOs) for the delivery of the harmonized standards related to the RED Delegated Regulation 2022/30 on cybersecurity aspects. In response to the consultation, CECAPI fully supports the proposal to extend the applicability date of the Commission Delegated Regulation (EU)2022/30 to August 1st, 2025. It is important that the timing for the expected delivery of the harmonized standards and the applicability of the delegated regulation go together to ensure that manufacturers have the necessary time to adapt their products and to complete the relevant conformity procedure. Even with the proposed extended applicability date manufacturers will still have to work with a tight schedule to bring their products in conformity. Furthermore, we would like to stress the importance of first, a timely assignment of appropriate HAS consultant and an early involvement in the process. This mitigates the risk that once CEN/CENELEC has finalised the standard, it is not considered harmonised due to the lack of assessment by the HAS consultant. The process will only be completed when the standard will be cited on the official journal. More and more products under CECAPIs scope will be impacted by this legislation as being radio equipment connected to internet, therefore our industry needs to rely on the expected harmonized standards in due time to succeed in this task. June 19th, 2023
CECAPI is the European coordinating committee representing the Associations of Manufacturers of Electrical Installation Equipment within the member states of the European Union and the EFTA region. CECAPI appreciates the opportunity to provide inputs on the EU taxonomy and would like to comment on the following three points: 1 CE - 1.2 Manufacture of electrical and electronic equipment; 2 CCM - 3.20. Manufacture, installation, and servicing of high, medium and low voltage electrical equipment for electrical transmission and distribution; 3 CCM - Appendix C of DNSH criteria f) and g).