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FREE ICT EUROPE FOUNDATION

FIE

Free ICT Europe is a nonprofit foundation actively promoting the Information Communication Technology Secondary Market within Europe.

Lobbying Activity

Response to Advanced Materials Act

12 Jan 2026

Please find attached the input regarding the Advanced Materials Act from the Free ICT Europe Foundation.
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Response to Circular Economy Act

6 Nov 2025

Please find attached the input from the Free ICT Europe Foundation.
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Response to Digital package – digital omnibus

14 Oct 2025

Dear DG Connect team, Please find attached our input. Regards, Free ICT Europe Foundation
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Meeting with Thibaut Kleiner (Director Communications Networks, Content and Technology)

22 May 2025 · Exchange of views on dependencies on specific software and risks for European competitiveness and sovereignty

Response to Single Market Strategy 2025

31 Jan 2025

This Single Market consultation addresses the need for the future of European organisations. It is vital to take make improvements to support the European businesses to be able to focus on the key task and to become competitive again globally, while we secure our technological know how and independence. Please find attached our input.
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Meeting with Matjaž Malgaj (Head of Unit Environment)

16 Jan 2025 · Discussion on enhancing circularity in ICT and the challenges faced by the ICT after-market actors

Meeting with Christel Schaldemose (Member of the European Parliament)

15 Oct 2024 · Free , Fair, Open and Circular ICT Economy

Response to Reporting scheme for data centres in Europe

15 Jan 2024

As the Free ICT Europe Foundation we welcome the possibility to comment on the consultation for this topic; we support the EU in improving monitoring the energy and environmental footprint of the ICT industry. Key positions include: 1. Timeline of Reporting: We are advocating for an earlier reporting deadline of 2024 to monitor digital infrastructure growth effectively. 2. Transparency: We are asking for public access to detailed data on data center operations to foster accountability and research. 3. Data for Accountability: We are proposing specific data points for public disclosure, including data center name, owner, location, and operational details. 4. ICT Hardware Resource Usage & Electronic Waste: We stress the importance of reporting on ICT equipment purchases and disposal to understand environmental impacts. We thank the Sustainable Digital Infrastructure Alliance e.V. for their support in providing the response.
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Dear Commission, The Free ICT Europe Foundation welcomes to opportunity to share our views on priority ESPR products. Being an organisation that is representing the independent EU ICT Aftermarket, we are pleased to contribute. We strongly call for two ICT product groups to be selected as a priority, as they are vital for our ICT infrastructure and have a strong Circular Impact. 1. Network Equipment, Crucial in Connectivity & the Circular Economy 2. Software, a black box that should not be a blind spot Please find our position in the attached document.
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Response to Environmental impact of mobile phones and tablets - Ecodesign

28 Sept 2022

The Free ICT Europe Foundation welcomes the proposal, please find attached our contribution.
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

7 Apr 2022

The Free ICT Europe Foundation welcomes the opportunity to provide feedback and thoughts on the European Commission’s legal proposal for amending Regulation 1025/2012. We support the movement to increase power for national bodies in regard to standardisation and less for the economic sector. The commission also states that the European standardisation organisations must duly take into account the views of all European stakeholders including small and medium enterprises and civil society organisations. While we welcome this objective, we would like to raise awareness on the fact that to participate membership(s) of the Standardisation Organisations are required those cost thousands of euro’s annually. This is an obstacle for SME’s and for instance Non-Profit organisations. This should also be addressed to increase participation. In most cases their involvement will only be for a single or small number of standards, it would therefor be a solution to have a reduced fee based at the number of projects. Last but not least more and more standardisation is moving beyond the technical scope, for instance related to the circular economy and Ecodesign. This means that standards are having an effect on the market, competition and business models. Here it is even more important that all European stakeholders can actively participate ensuring that the European public interest is taken into account.
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Response to Ecodesign and energy labelling working plan 2020-2024

1 Jun 2021

The Free ICT Europe Foundation appreciates the work done on the research for the selection of new product groups and horizontal initiatives. It is crucial that there are no obstacles to repair, refurbish, upgrading and maintenance for independent suppliers and service providers. Today we experience that designs, policies and lack of information are hindering an open Circular system outside the Original Manufacturers channels. Therefore we request you to finalise this selection process as quickly as possible, where we strongly support these proposed groups and initiative: 1. Enterprise Network Equipment 2. Firmware and Software 3. Uninterruptible Power Supplies The Working Plan should also clearly set out the timetable for each measure, where our priority would be at the first 2 listed. For Enterprise Network Equipment we kindly ask to have a study to current constraints in the market that block the free movement of goods, im- and export restrictions, re-use and independent maintenance obstacles that hinder the Circular Economy. For all connected devices Firmware and Software are becoming of increased importance, as this is a medium to have control with wide impact including obsolescence. Hence, this initiative is crucial for the Green Deal. In addition to the study we want to address the monopolistic software practices that have spawned from outdated intellectual property and copyright laws. If acted upon, legislative changes will enable European businesses to better compete and promote greater EU industrial sovereignty combined with a longer life-time of hardware. The delay involving both the new and the previous Working Plan are a major concern. Timely revision of existing regulations is also a concern. The Commission should urgently prioritise this within its planning, budget and services and dedicate adequate human resources to the development and review of Ecodesign measures. The current EU’s approach contains the element of energy consumption, which is limiting the reach of the framework as this can only be done for comparable products. To counteract the lengthy legislative process involved in including new products, the material aspects should be elevated as priority and as such be applied to a wider scope of products in the selected area. Energy consumption and requirements therefore should be limited to select products. The structure of Ecodesign demands energy requirements for the (highly comparable) products. An adjusted structure can boost the impact of the Ecodesign framework and in this regard a complete set of products in a category should be addressed. Propose to review the structure of Ecodesign Directive to make it possible to include a family of products for the Material Aspects, while the Energy requirements will be limited to selected specific products in this group.
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Response to Sustainable Products Initiative

16 Nov 2020

Free ICT Europe Foundation(FIE) is a not-for-profit foundation actively promoting the ICT Secondary Market within Europe. Our objective is to secure the right of ownership and the freedom for consumers and businesses alike to freely choose their providers to trade, maintain and repair hardware and software. Please find our input in the attached document.
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Response to Empowering the consumer for the green transition

1 Sept 2020

Please see attachment
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Response to A new Circular Economy Action Plan

20 Jan 2020

The need to speed up to embrace the Circular Economy is a necessity. We call for a focus on products as well as Services. Extending the life-cycle, Upgradeability and Repairability can have a great impact for Europe, if the policies include involvement of and an open market for: SME’s. We suggest explicitly to include in the Circular Action Plan: 1. Networking Equipment as an Ecodesign Product group. The ICT spending on ICT Network Equipment is >€50 Bn per year, still growing and getting close to the spending on Enterprise Servers and Storage products combined. Millions of products are being placed on the EEA market every year, this will be increasing through IoT, 5G and expending infrastructures. As these systems are always powered, the energy component is important, though the Material Aspects even more. This product group should have the attention of the EC and prominently targeted in the Ecodesign Work Plan 2020-2024. 2. Smartphones as an Ecodesign Product group. This product group should have the attention of the EC and prominently targeted in the Ecodesign Work Plan 2020-2024 3. Include Software Standardisation as an important element for ICT and connected devices in the Circular Economy 4. Finalise work on the European Repair Score Index and pilot a repair label on several products (e.g. laptops and washing machines) 5. Link (independent) repair and maintenance to climate objectives allowing for better accounting the resource efficiency and the embedded energy within products 6. Allocate EU funding mechanisms (Just Transition Fund, LIFE and European Social Fund) to support the repair sector in Europe as a major provider of circular employment opportunities. Carry out an assessment of the current employment contribution of (independent) repair and maintenance to the EU. 7. Utilise environmental fiscal reform, including VAT reductions to reduce the cost of repairs and of refurbished products. 8. Recommend Green Public Procurement to systematically favor used, refurbished, (independent) repairable and long-lasting products and the GPP to promote to use SME’s for repair, maintenance and disposal.
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