European Committee of Manufacturers of Electrical Machines and Power Electronics

CEMEP

3.1.

Lobbying Activity

Response to Review ecodesign electric motors and variable speed drives.

22 Sept 2025

CEMEP emphasises the need for regulation at the system level to maximise energy savings and support the European Unions climate objectives, while welcoming the Ecodesign for Sustainable Products Regulation as an opportunity to realise the considerable energy saving potential of motors. It highlights the challenges created by overlapping regulations, regulatory uncertainty and the growing complexity of compliance, particularly for small and medium sized enterprises. The organisation calls for clear, consistent and technically feasible rules that balance sustainability goals with industrial realities, reduce administrative burdens and maintain competitiveness. Close collaboration between policymakers, Member States and industry is regarded as essential to ensuring coherent regulations that enable innovation, safeguard Europes industrial base and fully realise the regulations potential.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

25 Aug 2025

The European Carbon Border Adjustment Mechanism (CBAM) is fundamentally pursuing the right goal: climate protection by preventing carbon leakage. In its current form, however, the CBAM fails to achieve this goal, and at the same time jeopardizes the international competitiveness of European industry. Discussions about extending CBAM to downstream steel and aluminum products miss the point. This approach does not resolve the structural problemit merely shifts and increase it along the industrial value chain. The complexity of global supply chains is insufficiently addressed in the current CBAM design. Crucially, there is no mechanism to relieve European exports from CBAM-related cost burdens, posing a major competitive disadvantage in international markets. CEMEP European Committee of Manufacturers of Electrical Machines and Power Electronic
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

CEMEP, the European Committee of Manufacturers of Electrical Machines and Power Electronics, welcomes the opportunity to comment on the amended EU Taxonomy Delegated Acts. Please find our comments as attached in the Commissions official template for providing feedback.
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Response to Sustainable Products Initiative

16 Jun 2022

CEMEP welcomes the draft Ecodesign for Sustainable Products Regulation (ESPR) as presented by the European Commission on 30 March 2022. CEMEP believes that the draft regulation will support further development of sustainable products and markets, and we strongly encourage a common European ap-proach to this important field. The Ecodesign Directive has for many years proven to be a strong instru-ment to drive increased energy efficiency for energy related products based on important approaches such as the product group per product group approach, the study and life cycle based methodology and the involvement of all relevant stakeholders in the process. CEMEP believes that the new ESPR will serve as a strong tool for both continuation of the efforts for energy savings as well as to support better materi-al efficiency and circularity. CEMEP also sees opportunities in the coming digital product passport as a helpful tool to provide useful data and transparency throughout the value chain and during the entire product life cycle. A more elaborate feedback is attached.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

CEMEP: Position on the Energy Performance of Buildings Directive (EPBD) recast 31 March 2022 CEMEP, the European Committee of Manufacturers of Electrical Machines and Power Electronics, welcomes the revision of the Energy Performance of Buildings Directive (EPBD) and sees the recast as a key enabler to increase the energy efficiency and overall performance of buildings, in line with the ambitions of the Renovation Wave Strategy. To reach the Fit for 55 goals of achieving a zero-emission building stock by 2050, CEMEP believes the EPBD recast could provide a unique opportunity to deploy a broad range of energy saving technologies. In particular, the EPBD proposal reinforces an array of instruments that Member States can apply (nearly Zero Energy Buildings standards for new buildings, Energy Performance Certificates to inform consumers and regularly inspecting heating systems) to secure energy savings in buildings and building systems. These instruments could achieve a successful implementation if existing technologies delivering energy efficiency and energy savings are considered, and to ensure regulatory coherence with the decarbonisation objectives of the Energy Efficiency Directive (EED). CEMEP therefore strongly supports the use and regular assessment of energy-saving technologies in buildings and building systems, to make energy consumption more effective without compromising on the principle of technological neutrality. We also believe that references to energy saving technologies should be made more clearly where possible to ensure that they are duly considered. In the document attached CEMEP has highlighted in more detail the proposed amendments to the EPBD proposal for a recast. Who is CEMEP? CEMEP is the European Committee of Manufacturers of Electrical Machines and Power Electronics, representing an industry with a market value of more than €22 billion and around 200,000 employees. The members are 11 National Associations in Europe, representing manufacturers of electric motors, variable speed drives and uninterruptible power supplies - essential equipment enabling the electrification of a wide range of sectors with energy efficient solutions. Our energy efficient solutions contribute to reaching Europe’s climate neutrality goal.
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Response to Standardisation Strategy

15 Jul 2021

CEMEP welcomes the initiative for a new European standardisation strategy. Please find the CEMEP comments attached
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Response to Ecodesign and energy labelling working plan 2020-2024

26 May 2021

CEMEP, the European Committee of Manufacturers of Electrical Machines and Power Electronics, welcomes the study and the effort to identify the most promising product groups and horizontal initiatives to further study in the Ecodesign and Energy Labelling Working Plan 2020-2024. We have attached a position paper that focuses mainly on the more horizontal initiatives.
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Response to A new Circular Economy Action Plan

17 Jan 2020

CEMEP, the European Committee of Manufacturers of Electrical Machines and Power Electronics, supports the development towards a circular economy and as an industry seeks to actively contribute towards more sustainable manufacturing and responsible consumption. Circular economy and material efficiency cover many different aspects and business models for which the challenges and possible solutions vary significantly from industry to industry and even within industries. Business-to-business market conditions and solutions are different from those which prevail in a consumer-oriented environment. This must be reflected in European circular economy initiatives and regulations. It is important that implementation brings about a system which remains open, market driven and globally oriented. Energy efficiency and material efficiency go hand-in-hand and optimizing the use of resources throughout any process makes environmental and economic sense. But this requires alignment and coordination. It is important to base future initiatives on a “least life cycle cost” principle in order to focus on the measures that result in the most sustainable use of resources. This should be done in a way that avoids incompatible constraints such as targets for long life time (supporting for high material efficiency) conflicting with targets for higher energy efficiency (where new products are most often more efficient). Any actions should look for impact and solutions at the system level rather than narrowing the scope to the component level as the potential for improvements in general is considerably greater here. CEMEP remains convinced that there is still a significant untapped potential for energy savings at the system level. In the coming EU Action Plan for a circular economy, the European standards for energy and material efficiency should form the basis for implementing measures. These standards represent widely accepted methodology for assessing different aspects of circularity and material efficiency. The existing horizontal standards for material efficiency should be supplemented with more product-group specific standards that takes into account the conditions of the B2B market. Using European harmonized standards enables transparent information and a strong link to the global landscape. Many CEMEP members volunteer to actively participate in the development of their product-group specific standards. As an industry, CEMEP has been driving towards circularity for many years and will continue to do so in future. Our industry has a long history of developing durable, long-lived and energy efficient products, of maintenance services and of lead-battery recycling. Besides, there is an increasing focus on sustainable production methods, increased recyclability and improved repair and maintenance provision. Digitalization, data analysis and the increased use of sensors provide new opportunities to optimize both energy and resource utilization throughout the life cycle. CEMEP recommends policy makers to support such development and seek collaborative solutions with a long-term perspective as well as supporting research and development projects that can foster new circular economy models. Incentives for innovation projects, such as Horizon Europe funding for circular economy projects, can both propagate and accelerate this development. Any regulation should be pan-European and fully harmonized. Independent national initiatives should be discouraged, in order to ensure a sustainable business framework for the whole European industry. CEMEP would also encourage that measures are enforced through on-the-ground market surveillance, to ensure homogenous implementation. This will create a level playing field for all, including importers of goods, and ensure actual deployment of any regulation.
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Response to Ecodesign requirements for (other) electric motors

21 Nov 2018

Herewith you can find the Cemep comments to the last Ecodesign Regulation Draft for electric motors and drives
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