European Tuning Organization

ETO

ETO is the official European umbrella association for the automotive specialty eqipment and tuning industry.

Lobbying Activity

Response to Single Market Strategy 2025

28 Jan 2025

The European Tuning Organization E.T.O, representing the European automotive aftermarket specialty products industry, consisting mainly of SME`s and Micro SME´s, welcomes the initiative and opportunity to provide further feedback to the Single Market Strategy 2025. We value the presentation and aim of a new Single Market Strategy to work on the momentum to complete the single market and making it top priority again. In particular we support that the Strategy will be promoting the cross-border movement of goods and that it will strive to ensure the existing rules are fully implemented and enforced or if needed to be improved further. Removing existing regulatory and administrative barriers and preventing new ones is important for functioning inner community trade. Attached you will find our comments.
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Response to Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods

22 Jan 2024

The European Tuning Organization E.T.O, representing the European automotive aftermarket specialty products industry, consisting mainly of SME`s, welcomes the initiative of the European Commission to evaluate Regulation 2019/515 on mutual recognition of goods lawfully marketed in another Member State. While some of our product are harmonised, many of our prodcuts fall in the non harmonised category and being subject to national requirements. Resulting in that our companies are facing many national restrictions, by either technical/testing/approval requirements or even direct and indirect ban of a product. For our industry a mutual recognition system which is userfriendly for economic operators is therefore vital for successful business within Europe and to benefit from free inner community trade. Even though the revision of Regulation 764/2008, included various important improvements like for example including the restriction of use, as well as a voluntary mutual recognition declaration form and improved definitions, in practice it has so far not shown the improvements that our industry were hoping for and needed. Companies still seem to be hesitant of using the system or give up as they feel they have no chance to get a positive outcome. They find it to time consuming, are often not able to answer all the questions or have difficulties to provide the requested information. In many cases it is like a ping pong game, where the companies are directed from one contact to another. Member states/authorities still use their national technical rules and legislation to try and avoid mutual recognition for a product. Sometimes it can also be a precautionary measure in respect of EU General product safety legislation to question or deny mutual recognition by the member state. Economic operators/companies often then feel intimidated and withdraw from continuing the mutual recognition procedure. SOLVIT: Solve problems with a public body regarding EU rights (for individuals and businesses): It is required to have problems in at least two EU countries to continue with this procedure. This can be burdensome for economic operators. Our industry consists many of SME´s and Micro SME´s, which find it very difficult to collect and provide information on various cases. Day to day business and low manpower does not allow for time consuming data collection. We are happy to provide you with more detailed information if of interest.
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