Fachverband der Elektro- und Elektronikindustrie
FEEI
Der FEEI-Fachverband der Elektro- und Elektronikindustrie vertritt in Österreich die Interessen von rund 300 Industrie-Unternehmen mit knapp 74.000 Beschäftigten und einem Produktionswert von 24,6 Mrd.
ID: 54228767435-01
Lobbying Activity
Response to Revision of the EU’s energy security framework
13 Oct 2025
Option 2 is preferred, as options 3 and 4 cannot be implemented in the short term; in view of the current geopolitical situation, rapid implementation of the proposed legislative act is crucial.
Read full responseResponse to Fitness check – energy security architecture
26 Nov 2024
Goals of the EU Architecture for Energy Supply Security Comments: Devices connected to the internet require software updates to remain secure. For the software update, the manufacturer has full access to all functions of the device. This could also introduce unwanted additional functions, such as synchronized shutdowns, which could be geopolitically exploited by other states. Many devices in the energy system are directly connected to the internet (PV inverters, heat pumps, electric charging stations, etc.). The energy amount of these devices is greater than what European energy providers can regulate. The dominance of Chinese manufacturers has massively increased over the last 10 years. Current geopolitical conflicts (e.g., the Ukraine war) clearly show that the potential risk of remote access is acute in security policy considerations. China can already turn off our electricity remotely (complete blackout) Europe is NOT acting. The Cyber Resilience Act (CRA) and the Network and Information Security Directive 2 (NIS2) do not solve the problem. Are there improvements for energy supply security to support the ongoing transition (e.g., to a more electrified, renewable energy-based, and integrated EU energy system)? Comments: The increase in renewable energies and the need to integrate them into the energy system have been foreseeable for over 10 years. Even a chip crisis with its effects on energy supply and the economy was not entirely unexpected. Neither the EU framework nor national regulations have sufficiently strengthened the resilience of the energy supply. On the contrary, price-driven regulation and the effective lowest bidder principle in procurement law have exacerbated the crises. The result is higher costs in the transformation of the energy system. Lack of foresight and poor coordination between the EU Commission's directorates lead to lower resilience. Notes on relevant "supply security issues" related to technologies necessary for critical infrastructure (CI): 1. Availability of technologies (primary technology, secondary technology/digitalization) 2. Cybersecurity 3. Mindset of politics, users, and local providers 1. Availability of Technology: Since the chip crisis, we know that Austria/Europe is dangerously dependent on third-party technologies. This makes our economy and security highly "remotely controllable." In the vital area of CI, bottlenecks (deliberately induced or due to other events) could lead to enormous security risks. The technology (R&D, know-how) and production must come from European countries classified as "geopolitically safe." The Net-Zero Industry Act (NZIA) is a first idea in this regard. However, a massive reality-based update from NZIA 1.0 to NZIA 5.0 with "Europe First" and balancing the economic cost side and the business profitability side of companies is needed. 2. Cybersecurity It has already been proven (Ukraine war) that the cannons of the future are cyberattacks on CI. Therefore, it is essential to mandate comprehensive locality for development (know-how) and production for all products with cyber-critical tangents to CI. Additionally, through MIL procurement criteria and/or special state certifications, where producers/providers are also held liable, the avoidance of circumvention constructions/other risks must be ensured. 3. Mindset of Politics, Users, and Local Providers The problem is that security fundamentally costs money, but cost optimizations and revenue increases are indispensable for our supply security. To enable effective regulatory interventions by politics on this topic, the following fundamental awareness-raising work is necessary: a) In politics: We fear that the actual threat potential has not yet been understood or is not taken seriously enough. In the energy transition, the issue of supply security (points 1 and 2) is hardly or not at all addressed. b) Among users (supply companies): The danger potential is usually well known, but the constraint
Read full responseResponse to Revision of the Communication on important projects of common European interest
21 Dec 2020
1. Europe needs to define a European (Industrial) Technology Policy plan with the aim to supply Europe with
• Technologies for digital autonomy and sovereignty
• Innovation acceleration
• Technology competences to guarantee the supply of (green) energy resources
• production technologies for goods for critical infrastructures
• Real digital education
• secure data ecosystem (including European information/service providers)
Those technologies should be primarily researched by European stakeholders (i.e. knowledge, IP and production must be in European power of control)
2. Instruments to fulfil this policy plan are necessary
• IPCEI is one of those instruments
o IPCEI as implementation instrument should be coupled to a strong European production footprint
• supporting R&D programmes like KDT (ECSEL successor) and Horizon Europe
• educational programmes for MINT
• create European Market via Market Rules (i.e. if technologies are crucial for Europe, Europe needs to create an European market for them
3. Instrument IPCEI
• the effort of the IPCEI process requires huge resources of experts, which is inefficient. Please define stable, clear and simpler rules to enable a setup time for new projects in less than 6 months.
• make the instrument much faster (Europe stands in competition for key technologies, the instruments of our competitors are much faster from idea to implementation)
• ex post evaluations risk to counteract the initial intention of the IPCEI instrument (topic 49)
• Diverse International policy behaviour must be properly reflected in European State Aid regulations (European State Aid still focuses on the prevention of European market distortions)
The Funding gap calculation is not adequate as the individual accounting practices and technology cycles are not properly covered. Funding gap calculation does not a) reflect the fast innovation cycle b) the global competition in key technologies (in key technologies other regions support industrial settlement of production facilities which leads to global market distortions. Europe still loses technologies).
• Generate a framework for IPCEI projects linked to the multiannual research frame work of Horizon Europe (e.g. for microelectronic KDT) for transparent rules and fast notification path.
Read full responseMeeting with Sebastian Kuck (Cabinet of Commissioner Jonathan Hill)
16 Jan 2015 · Company financing in the electronic sector