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Groupement des industries de l'équipement électrique, du contrôle-commande et des services associés

GIMELEC

Le GIMELEC fédère les entreprises de la filière électronumérique française.

Lobbying Activity

Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

The Carbon Border Adjustment Mechanism (CBAM) is a tool to support European climate objectives. However, in its current form, its implementation will generate significant administrative burdens and increase production costs for the European factories of several GIMELEC member manufacturers. Their competitiveness against non-European competitors not subject to the same constraints will therefore be weakened. To avoid this situation, GIMELEC makes three recommendations: 1) Extending the CBAM scope to certain finished electrotechnical equipment imported into the EU 2) Exclude certain specific materials used in the manufacture of this equipment 3) Support European manufacturers penalized by the CBAM on exports using a compensation mechanism GIMELEC advocates for a balanced and pragmatic implementation of the CBAM, which must reconcile decarbonization and industrial competitiveness in order to sustainably strengthen the electrotechnical sector in Europe. These recommendations aim to ensure a fair balance between environmental requirements and economic performance, by promoting a coherent approach that supports the environmental transition without hindering the ability of European companies to innovate, produce and export.
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Response to Revision of the Standardisation Regulation

21 Jul 2025

In the context of industrial, energy, and digital transformation, GIMELEC emphasizes that standardization is not merely technicalit is a strategic tool for sovereignty, competitiveness, and safety. The electrotechnical sector, being highly standardized and globalized, relies heavily on international standards (notably IEC), with 80% of CENELEC standards derived from them. Europe is both a contributor and adapter of these standards, ensuring alignment with EU needs while facilitating global market access. Key Messages 1.Speed and Efficiency - Standard development must accelerate to match innovation cycles. - Tools like Online Standards Development (OSD) and smart standards can streamline processes. - The harmonization process is slow (average 300 days for citation in the OJEU) and needs reform. 2. International Alignment - Maintaining agreements with ISO and IEC is vital. - European leadership in strategic sectors (e.g., energy, digital, cybersecurity) depends on active participation in international standardization. 3. Legal Framework - The New Approach, where legislators define essential requirements and experts develop standards, must be preserved. - Harmonized standards (hEN) should remain central to EU conformity. 4. Access and Inclusiveness - Free access to hEN is welcomed but must be managed to protect the sustainability of the European Standardization System (ESS). - The national delegation model ensures inclusiveness and technical quality through stakeholder consensus. Concerns and Risks 1. Common specifications must be avoided - Proposed as alternatives to harmonized standards, they risk bypassing stakeholder consensus, reducing international compatibility, and increasing compliance burdensespecially for SMEs. - They could fragment the market and weaken the ESSs public-private governance model. 2. Institutional Fragmentation - Creating new standardization bodies or extending ESO status could duplicate roles and disrupt coherence. 3. Expert Involvement - Dilution of expertise and reduced SME participation are concerns. - Disruptions between European and international standards would burden experts and reduce competitiveness. Recommendations - Strengthen the current ESS framework and avoid creating parallel structures. - Resolve harmonization delays and clarify responsibilities in the standardization process. - Support expert participation, especially in international bodies, through funding and training. - Reinforce market surveillance to ensure compliance and fair competition. - Develop a systemic approach linking standardization with certification and surveillance. Conclusion Standardization is a strategic pillar for Europes industrial and technological sovereignty. The revision of the EU Standardization Regulation should reinforce the ESS by preserving its core principlesopenness, transparency, consensus, and inclusivenesswhile addressing speed, international alignment, expert involvement, and market surveillance. The goal is to evolve the existing system, not disrupt it, ensuring that European standards continue to support innovation, safety, and global competitiveness.
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Response to Ecodesign and energy labelling working plan 2020-2024

31 May 2021

GIMELEC is expressing these comments as the secretary of CEMEP UPS, the european association of UPS manufacturer. Please read the pdf file for full comments. Members of CEMEP UPS welcome the focus given to their products in the latest preparatory study: given the exponential growth of the digital world, it is only natural to have a specific attention to its environmental impacts. It is important to keep in mind that for most UPS markets, energy efficiency is the first criteria of choice for buyers. As a consequence, manufacturers have been working for decades to improve the environmental footprint of their products through standardization (IEC-EN62040-3 & IEC-EN62040-4) and voluntary agreements like the UPS Code of Conduct (CoC). Between 2013 and 2017, CEMEP UPS put a lot of work to provide data and expertise during the discussion about a possible ecodesign measure (lot 27). That process stopped in 2017 due to several factors: doubts about the energy savings potential and the existence of the UPS CoC as well as the recognition of the US energy star program. The main remarks from the UPS manufacturers are the following : - CEMEP UPS and the Joint Research Center agreed some weeks ago on an update the UPS CoC requirements. The final values are for all products higher than the ones that are enforced since 2014. For some proposed values are up to 8 points higher to the current ones : it is a testimony of the positive & natural dynamic of the UPS markets in terms of energy efficiency. - In the same CoC for UPS there is also a notable addition : an « elite level » has been introduced. It will be mandatory if a data center wants to be compliant with the CoC for Data Centers - 2014 & 2020 reports mention a list of BAT/BNAT based on the 2014 knowledge. Since then, several of them became “mainstream” or close to mainstream (transformerless / multi-mode / three-level converters/...). Others are either far from being available on the market (lead-carbon) or don’t have any energy efficiency interest (supercapacitors). It led to a notable reduction of the energy savings potential by the consultants between their interim and final reports. The industry still thinks that it’s still overestimated since the calculation is based on the values of the lot 27 works which are too optimistic from our point of view. In a more general way, projections made today are mostly based on data from the 2013 impact study whom robustness and reliability can be questioned. - The industry is supporting the idea of excluding specific UPS from the discussion. Those products, which represent a very small share of the overall market, answer to specific customer requirements that typically arise from particular industry segments (e.g. oil and gas, health care, offshore platforms and power plants). Given their specificities, those “custom UPS” can not be treated like “general purpose UPS”. - Like other products covered by ecodesign measures, imposing strong energy efficiency requirements could lead to oversizing, the consequence being higher costs & higher use of rare materials. In terms of circular economy (see annex I), other leads could be followed. - UPS are in the middle of several european processes either directly (ecodesign, PEFCR) or indirectly (data centers, batteries). Therefore the EU Commission needs to be careful and must provide clarity and consistency if it doesn’t want to harm the UPS industry. Given Given the situation, the natural dynamic of the market towards more energy efficiency & the update of the Code of Conduct for UPS, the industry does not see enough new reasons for the EU Commission to reconsider the decision it took in 2017 not to implement an ecodesign regulation for UPS.
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Response to Ecodesign requirements for (other) electric motors

21 Nov 2018

Gimélec (French trade association for electrical equipment -including motors and drives-, automation and related services) welcomes the initiative of the revision of regulation for motors and variable speed drives EC/ENER Lot 30. Gimélec considers that this future regulation does not allow the optimization of objectives set by the European Union for reducing energy consumption in the industry because it is still focusing on a product approach instead of developing a system approach. It leads to some incoherencies in the requirements which could harm the sustainability and competitiveness of the European Industry of Motors and Variable Speed drive systems. (Our position is attached)
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