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Fédération des Industries Electriques, Electroniques et de Communication

FIEEC

Le rôle de la FIEEC : - représenter les entreprises des industries électriques, électroniques et de communication auprès des décideurs politiques nationaux et européens - rassembler les entreprises du secteur et promouvoir leur rôle central dans l'économie - proposer les réformes nécessaires en participant activement aux réflexions et évolutions réglementaires qui présentent un impact sur l'activité des IEEC

Lobbying Activity

Meeting with Dorota Denning (Cabinet of Commissioner Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Commissioner Valdis Dombrovskis) and

18 Nov 2025 · Competitiveness and simplification

Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

25 Sept 2025

Lappel à contributions organisé ici par la Commission traite de sujets cruciaux dans la mise en œuvre du CBAM et la prise en compte de ses impacts. Les difficultés auxquelles se heurtent les trois actes dexécution sont encore accrues pour les secteurs avals qui ont demandé à être couverts par le CBAM. Cest pourquoi la FIEEC appelle à la suspension du dispositif tant que les obstacles structurels ne sont pas levés. A défaut, dans la perspective du 1er janvier 2026, des mesures correctives peuvent être apportées et sont détaillées dans la contribution ci-jointe.
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Response to Omnibus Directive Aligning product legislation with the digital age

3 Sept 2025

Definition and Concerns "Common specifications" are defined in the proposed directive on digitization and alignment of common specifications as an alternative to harmonized standards. But their development is seen as a threat to the current European Standardization System (ESS). Industry stakeholders have expressed serious reservations regarding this proposal, fearing it could lead to a parallel structure that undermines the existing public-private partnership in the European standardization system. (see letter attached) Associated Risks a. Isolation and Inconsistency: o The development of common specifications could lead to isolation and disconnection from European and international standardization processes. This could reduce compatibility with international standards and create barriers to export for European technologies. o Common specifications might not be developed in accordance with the principles of European standardization, such as consensus, involvement of all stakeholders, transparency, and national representation. o There is a risk that common specifications could weaken Europe's global leadership position, leading to market fragmentation and reducing the competitiveness of European companies by diverting from reference international frameworks (ISO, IEC, and ITU). b. Governance and Market Fragmentation: o The adoption of common specifications could replace the current balanced approach with a restrictive top-down approach, disconnected from industrial and market realities. This could lead to market fragmentation, diminish the competitiveness of European companies, and weaken the public-private partnership that has been the cornerstone of the ESS. o Creating common specifications in a new agency or in dedicated groups outside the European Standardization Organizations (ESOs) would increase the risk of inconsistency and loss of clarity in the European standardization system. c. Common specifications could become a serious technical barrier to trade as described in the WTO TBT agreement and could breach Europe's commitment to the convergence of European requirements with international standards, undermining international businesses' ability to place their products on the EU market based on the latest innovations. d. Expert Participation and Financial Implications: o The multiplication of groups and structures could dilute expertise and reduce the relevance and technical quality of standards. Industrial experts, who are already heavily involved, could become overburdened, which would disadvantage the European industry compared to actors capable of mobilizing more experts. o The financial implications on the European Commission and Member States associated with the development or adoption of common specifications have not been thoroughly investigated. The expertise necessary to prepare the required specifications is gathered in CEN, CENELEC, and ETSI. Any system trying to reach the same level of expertise, openness, and transparency will inevitably create a parallel structure. e. Process and Transparency: o The process for adopting common specifications remains unclear and non-transparent. If there is a need for alternative methods, the Commission can use existing inclusive, transparent, and stakeholder-driven processes defined in the Standardization Regulation. Recommendations and proposals in the attached file
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

The New Legislative Framework (NLF) is the foundation of the European Single Market for products. With a rationale based on a public-private partnership, it achieves a structural balance through mandatory essential requirements created by European legislation, and voluntary technical standards developed by European Standardization Organizations (CEN, CENELEC, ETSI). FIEEC advocates for a stronger New Legislative Framework (NLF) through enhanced market surveillance. While Regulation (EU) 2019/1020 established a European Market Surveillance Network (Articles 2933), national surveillance strategies (Article 13), and peer reviews (Article 12), enforcement remains risk-based rather than systemic. Non-compliant products still enter the EU through Member States with weaker controls, and there is no mechanism to substitute for deficient states. FIEECs proposals to strengthen surveillance: EU-level coordination: Create a dedicated market surveillance function within the European Commission and designate a single coordinating authority per Member State. Digital and data-driven tools: Leverage cyber-secure systems and the Digital Product Passport (DPP) for better targeting and traceability. High-risk suppliers watchlist: Introduce a proportionate monitoring system (inspired by REACH) for high-risk suppliers/regions, coupled with strengthened international cooperation. Complementary measures: Address distortions from foreign subsidies (covered under Regulation (EU) 2022/2560) as part of broader market surveillance efforts. Interoperability: Consider a future integration of the DPP with existing platforms like Safety Gate (RAPEX) and ICSMS to streamline alerts on non-compliant or dangerous products, especially given the rise of online trade. Core objective: Establish clear, effective procedures for handling non-compliant and dangerous products to ensure a robust and cohesive enforcement system. FIEEC supports linking the CE Marking with circularity requirements to adapt the New Legislative Framework (NLF) to the digital age. The Digital Product Passport (DPP) is a strategic tool for Europes transition to a circular and sustainable economy, providing standardized, accessible, and verifiable information about a products lifecycle (material origin, carbon footprint, reparability, recyclability). Starting in 2026, it will first target high-impact sectors like batteries, textiles, and electronics. CE Marking and DPP are complementary: The CE Marking remains the physical and legal anchor, certifying compliance with EU safety, health, and environmental requirements. The DPP adds a digital layer, hosting dynamic information on circularity and sustainability and compliance data (e.g., EU declarations), without replacing the CE Marking. Outcome: The CE Marking provides legal certainty and market trust, while the DPP enhances transparency and provides information. Together, they create a mutually reinforcing system that drives innovation and sustainability without fragmenting the regulatory ecosystem. See recommendations attached
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Response to Revision of the Standardisation Regulation

18 Jul 2025

Standardization is not only a technical tool, but it is a strategic pillar of industrial, technological and commercial policies. It enables Europe to: Promote its values of safety, sustainability, and quality Support innovation and the energy and digital transition Reinforce European technological and industrial competitiveness and sovereignty in a multipolar world The revision of the European Standardization Regulation is an opportunity to reinforce the role of the ESS and ensure its continued relevance in a rapidly evolving global landscape. To ensure that the ESS remains in the future a strategic asset for Europe's technological sovereignty and industrial competitiveness, it shall preserve the core principles of openness, transparency, consensus, and inclusiveness, and continue to address the challenges of speed, international alignment (preservation of Vienna and Frankfurt Agreements with ISO and IEC), industry experts involvement, and ensuring effective market surveillance. It is essential to support the evolution of the existing system rather than its disruption, ensuring that European standards continue to drive quality, safety and innovation across industries.
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Meeting with Stéphane Séjourné (Executive Vice-President) and

30 Jun 2025 · Roundtable discussion

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

Assessment on Costs and Benefits We are not convinced that third party service providers are essential for the functioning of a DPP system as they raise additional costs, and economic operators can also ensure persistent DPPs even in case of liquidation, insolvency or cessation of activity. The need for a back-up DPP at the DPP creation should be evaluated. An impact assessment shall thoroughly assess the impact of the provision of mandatory back-up services related to the costs as the ESPR clauses mandating DPP back-ups were added by the co-legislators during the late stages of the ESPR adoption process and were not part of the original Commission proposal and impact assessment. Voluntary certification schemes for DPP Service Providers An impact assessment should evaluate if certification schemes could bring the expected transparency in the market and help economic operators (especially SMEs) to trust the new system and take up DPP services. Costs for economic operators of certification schemes, especially for small economic operators (start-ups/ SMEs) should be evaluated Access to DPP back-up The need for a back-up DPP at the DPP creation should be evaluated. Indeed, it must be made available only to authorities in case of liquidation, insolvency or cessation of activity, in order to avoid leakage of DPP data and breaches to the principle of access on a need to know basis. Retention periods / availability of back-ups The retention period for DPP backup-copies must not be longer than the retention period for the original DPP. The retention period for DPPs and DPP backup copies must consider already existing retention obligations for operators of installations to avoid double holding of DPPs/DPP backups. Ensure competition and contractual freedom It must be assured that there are several DPP service providers on the market from the beginning on. Contractual freedom must be the basis of the B2B relation between the economic operator responsible for the DPP and the DPP service provider. The use of third-party services is a free choice of the responsible economic operator. Technological neutrality and alignment with standardization of JTC24 Requirements on DPP services must remain neutral to the technologies used to provide DPP services. There are different ways to provide DPP services (e.g. through blockchains, through federated data spaces, or a mixture of these), and more may appear in the future as businesses innovate. Also, the delegated acts should allow technological neutrality with no lock-in effects. DPP Service providers need to comply with standards and technical specifications provided by CEN/CLC JTC24. Level playing field within EU The legal framework for the provision of DPP services must be the same across all EU Member States to ensure legal certainty and a level playing field across the single market.
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Response to European Sustainability Reporting Standards

7 Jul 2023

Please find attached teh feedbacks from FIEEC. Best regards.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

FIEEC, the French Federation for Electrical, Electronic and Communication industries, welcomes the opportunity to comment the latest Commission proposal for the draft Taxonomy Environmental Delegated Act and amendments to the Climate Delegated Act. You will find attached our feedbacks.
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Response to European chips act package – Regulation

9 May 2022

FIEEC welcomes the Chips for Europe Initiative. However, it ought to be emphasised that the programme is targeting European industry needs adequately. FIEEC calls on the EU to focus on IP design in EU’s key verticals in automotive, industrial, telecommunication infrastructure, health, personal electronics as well as smart home and energy, keeping them in mind during budget negotiations for the Chips Joint Undertaking. The Chips JU should allow for innovations across a wide range of technologies since “leading edge” varies strongly based on applications, meaning that node shrinkage should not be the only denominator for defining innovation. FIEEC deems following an “R&D ecosystem” approach as consequential and proper; however, a balance between research & technology organisations, universities and industry must be ensured. R&D&I programmes should take rapid commercialisation into account. FIEEC believes that fast-track and/or ad hoc funding instruments are needed to focus on limited and well-defined EU priorities. The definition of “‘first-of-a-kind’ in the Union” is a positive example for enabling facilities for Europe for which it today depends on other regions. This will develop the ecosystem in the EU in an accelerated manner, enhancing innovation and supply chain resilience. FIEEC welcomes that the scope is not restricted to certain technologies and/or node sizes, allowing for projects serving the EU economy’smid- and long-term demands, e.g., chips in the 40/28-12 nanometre range as well as other important technology fundamentals for the electronic systems such as memory. Pillar 3 of the EU Chips Act suggests far-reaching and unprecedented market interventions. The definition of “crisis” raises questions. It is important to understand that the current chip shortage is not caused by a crisis in chip production due to production stops of chip factories or disruptions in raw material supply. The shortage is a consequence of rising demand for chips needed during the pandemic, coupled with big fluctuations in chip demand of important sectors such as automotive and industrial. It triggered a rippling supply-demand imbalance felt across the world. The shortage, contrary to Recital 1 of the Chips Act, is not a symptom of permanent and serious structural deficiencies in the Union’s semiconductor value chain. In fact, the current shortage is a global phenomenon and cannot be solely attributed to one region’s chip ecosystem. The shortage is experienced across the world, including in regions with the largest chip manufacturing facilities. The proposed “Toolbox” measures do not reflect the complexity and uniqueness of the semiconductor supply chain, the requirements of the users (downstream) and the manyfold reasons why a shortage may occur: e.g. from raw and ultrapure materials to gas and chemicals, tools and equipment’s shortage, worldwide logistics’ outage among the FE and BE facilities, etc. The suggested, static measures – mandatory sharing of numerous market information with unclear definition and subject to sanctions, priority-rated orders, joint procurement of chips and export controls – will not be effective in preventing supply disruptions. Today, a car comprises ca. 1000, a smartphone ca. 160 different chips. Most chips are not “off-the-shelf” or “one-size-fits-all” products. In addition, Chip factories are not homogeneous and only able to manufacture a specific range of node sizes and transistor technologies. This means that Open EU Foundries and Integrated Production Facilities in the EU would only be able to manufacture and supply a very limited number of the chips required. “Just-in-time” supply chains of downstream sectors increase the risk of disruptions since they do not reflect the long lead times for chip production (4-6 months). The focus of a toolbox should shift to instruments that can effectively help chip users to enhance their security of business continuity. Therefore, Pillar 3 should be revised entirely.
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Response to Standardisation Strategy

12 Jul 2021

1- We can congratulate ourselves on the good general functioning of the European standardization system. The organization of the CEN, CENELEC and ETSI sectors, based on their complementarity, allows real synergy between European standardization bodies. The establishment of a secretariat common to CE and CENELEC (CCMC) has made it possible to rationalize and simplify the organization, it is advisable not to go further towards bringing together CEN and CENELEC, each organization having to maintain its specificity. In addition, the excellent articulation between CEN and ISO on the one hand (Vienna agreement), and CENELEC and IEC on the other hand (Frankfurt agreement) is a real opportunity for Europe to develop or contribute to the development of global standards. We support the principle of national delegation to CEN and CENELEC, as well as to ISO and IEC, and we expect in this context that National Standardization Organisations bring the added value that stakeholders are entitled to expect. 2- We express our deep attachment to the proper functioning of this system and to the involvement of our industries and other stakeholders to contribute to its success. • In general, the involvement of the industry is a key success factor in producing standards adapted to market needs • For industry, it is also essential that European standards are as in line as possible with international standards (IEC in particular for the electrotechnology sector). • In this sense, it does not seem useful to us to review the sectoral organization into 3 organizations CEN, CENELEC, ETSI immediately (neither in the short nor in the medium term). For the manufacturers of the electrical sector, this would be a risk of an open door to a dilution of their interests and their stakes and to a loss of influence. 3- The subjects: batteries, data spaces, artificial intelligence, seem important to us and to prioritize. 4- The field of smart grid standardization remains essential: we can mention the work of the CEN - CENELEC - ETSI groups on interoperability, cybersecurity and demand response . 5- We are very attached to the principle of the new approach. One point of improvement is however expected: that the EC do everything to facilitate the process of developing harmonized standards and their citation in the Official Journal of the European Union.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

In particular, the assessment should focus on whether: i) the NLF is fit to address the way products may be changing during their lifetime to both support the take-up of smart connected or remanufactured products and to ensure safety; FIEEC remains convinced that the new approach and the new legislative framework are the best tools to support the proper functioning of the European single market. FIEEC notes that the only changes to be made should relate to clarification needs. In particular, they could clarify the ability of the NLF to address how products may evolve over their lifetimes, both to support smart connected products or refurbished products and to ensure their continued safety. ii) the conformity assessment procedures remain fit for purpose and ensure the safety and compliance with the applicable requirements of the products placed on the Union market; FIEEC is a strong supporter of the self-assessment system. We believe that the existing conformity assessment procedures are fit for purpose to ensure the safety and the compliance of products with the relevant requirements applicable on the European Union market. The well-established success of these processes has demonstrated that mandatory 3rd party certification is unnecessary and should, under most circumstances, be avoided, except in specific cases. iii) the rules for notified bodies are robust enough to ensure the competence of those bodies; Due to their nature and specifications, most of our products are self-assessed and we don’t use Notified Bodies. However, we are convinced that the rules applicable to Notified Bodies are robust enough to ensure their competence. It may worth to reinforce the harmonization of criteria throughout Europe to be sure each of them is notified with the same set of rules. iv) the accreditation system functions well and ensures that the competence of the notified bodies intervening in the conformity assessment procedures is sufficiently guaranteed; FIEEC believes that the accreditation system functions well and ensure the competence of notified bodies. However, the notification should be based on the same set of rules everywhere. For example, is it needed to be able to perform tests as a notified body or can this be sub-contracted ? v) affixing the CE marking and other product information to the product itself continues to be appropriate; More and more information, including the CE marking, are required to be put on the product itself. This will lead to industrial constraints for the smallest products, but also to confusion to the customers. It would be more efficient to focus the mandatory marking on the identification of the product (Brand, reference), the CE marking and on safety information, and to allow the use of an alternative mean (e-labelling, QR code, …) to provide less essential information such as addresses, environmental and performance ratings, …) vi) whether the lack of a crisis instrument for urgency situations renders the NLF less effective or efficient. FIEEC doesn’t believe that there is a link between the crisis’ situation and the NLF's application. NLF is here to provide a general framework for product compliance, for operators' definition and role, for placing products on the market and it works well as it is today. One of the key issues we are facing today is the late in acceptance and citation of harmonized standards, due to HAS and Commission processus, but this has nothing related to the sanitary crisis.
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