Hager Group
Hager
Manufacturing and sales of electrical installation products and building automation and energy management systems Family owned group
ID: 53349753503-84
Lobbying Activity
Response to Evaluation of the Measuring Instruments Directive
9 Oct 2025
Our feedback is based on the consideration that the revision proposal COM(2024)561 of the measuring instrument directive ("targeted amendments") to adapt them to current markets and technological needs and consequently to avoid national regulations which acts against a well-functioning single market reaches completion. In particular the updates for electricity energy metering with the explicit definition of direct current meters as part of the directive and the definition of essential requirements for measuring systems for electric vehicle supply equipment (EVSE) which are essential. The feedback adresses 3 topics: 1.Inclusion of a new Annex on reactive electrical energy measurement 2.Displaying of the measurement result 3.Harmonisation of Notified Bodies practices and requirement for EU-based certification under Modules B and D See attached file
Read full responseMeeting with François Kalfon (Member of the European Parliament, Shadow rapporteur)
27 Aug 2025 · Modification de la directive 2014/32/UE en ce qui concerne les équipements de recharge des véhicules électriques, les distributeurs de gaz comprimé et les compteurs d’électricité, de gaz et d’énergie thermique
Response to Revision of the Standardisation Regulation
21 Jul 2025
Our position highlights the strategic importance of European standardization as a pillar of industrial competitiveness, safety, and sovereignty. It calls for accelerating harmonization processes, strengthening international alignment (IEC/ISO), and reinforcing the current tripartite model based on CEN, CENELEC, and ETSI. Hager Group strongly opposes common specifications developed without industry consensus, warning of risks to innovation and market coherence. The attached position paper emphasizes the need for expert involvement, especially SMEs, and links standardization with robust market surveillance. It advocates for evolving the current system rather than disrupting it, ensuring that standards support Europe's leadership in digital, energy, and industrial transitions.
Read full responseResponse to Update of EU rules on radio equipment for reconfigurable radio systems
23 May 2025
Hager group expresses its support for Option 0. The activation of a delegated act at this juncture is unwarranted, as no market-related issues have been observed concerning this specific category of equipment, such as reconfigurable radios. Only a small subset of devices, known as Software Defined Radios (SDRs), have the capability to reconfigure radio parameters via software. In such cases, as well as for all other type or radio equipment manufacturers bear full responsibility for any software version and updates to their equipment, which are rigorously validated to ensure compliance with the RED prior to deployment. Moreover, the RED delegated act, which enforces Articles 3.3d and 3.3e, already establishes software updates as an essential requirement. It is further noted that the RED delegated act currently applies exclusively to internet-connected products, toys, and wearables. This act is set to be repealed within three years by the forthcoming Cyber Resilience Act, which will extend its scope to all products incorporating digital elements, thereby mandating software update obligations for all products placed on the EU market. Consequently, compliance regarding software updates will be comprehensively addressed for all electronic products. The current EU radio market is already severely affected by the economic crisis; thus, the imposition of additional regulatory burdens and associated costs is perceived as detrimental to the future viability of EU industry. In light of the above, Hager considers that the existing regulatory framework sufficiently mitigates the identified risks and therefore recommends the retention of Option 0.
Read full responseMeeting with Stéphane Séjourné (Executive Vice-President) and
19 May 2025 · Compétitivité, Simplification
Response to Technical description of important and critical products with digital elements
14 Apr 2025
This implementing act to provide a better technical description of the different categories is welcomed. However, the attempt to clarify goes somtimes into more questions as the scope is extended beyond what is described in the Cyber Resilience Act. Please refer to the enclosed file.
Read full responseMeeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur) and Philip Morris International Inc. and
19 Mar 2025 · Public procurement
Response to Targeted technical update of EU rules on measuring instruments
3 Mar 2025
Hager Group welcomes the revision proposal of the measuring instrument directive to adapt them to current markets and technologic needs and consequently to avoid national regulations which acts against a well functioning single market. Considering electricity energy metering we welcome the explicit definition of direct current meters as part of the directive and the definition of essential requirements for measuring systems for electric vehicle supply equipment (EVSE). The key point is to avoid any confusion regarding the applicability of the requirements of Annex Va. In a number of cases, electric vehicle charging requires a measurement often carried out using an instrument that complies with the requirements of Annex V. Below is a non-exhaustive list of such uses: Home charging measured separately (individual house or condominium with designated parking) on a specific delivery point or not Measurement done for energy management Measurement done in the context of providing flexibility Even if the directive on measuring instruments does not define the use case, it is essential not to create confusion and to clarify the framework for the use of the requirements of Annex Va.
Read full responseResponse to Targeted technical update of EU rules on measuring instruments
18 Oct 2024
Hager group welcomes a targeted revision of the measuring instrument directive to adapt them to current markets and technologic needs and consequently to avoid national regulations which acts against a well functioning single market. Considering electricity energy metering we welcome the explicit definition of direct current meters as part of the directive and the definition of essential requirements for E-Mobility charging. As the MID revision shall help the energy transition by empowering consumers to make full use of decentralized production from small-scale renewables and of new energy services/schemes such as demand response and energy communities, an overlap of requirements should be avoided. This is particularly true for EVSE used in private location and seen as a major flexibility potential and according EU Network Code Demand Response to be measured with a dedicated measurement device. For this application neither the EVSE nor the dedicated measurement device should be in the scope of the new created annex Va but remain in annex V. To avoid any confusion we propose to limit the scope of annex Va to EVSE used in the context of the AFIR.
Read full response12 Jun 2023
Hager group soutien totalement le report des dates de délivrance des standards au 30 Juin 2024 ainsi que la date de mise en application du règlement délégué RED 2022/30, complétant la directive 2014/53/UE, sur les aspects de cybersécurité au 1er Aout 2025. En effet, malgré les efforts considérables déployés par les experts du CEN et du CENELEC, il apparait clairement que la livraison des 3 standards génériques nest pas possible avant le 30 Juin 2024. Il faut ensuite pourvoir laisser le temps à la Commission pour procéder à lexamen approfondi afin dobtenir une publication au journal officiel. Si jamais il ny avait pas de citation à lOJEU avant la mise en application, les industriels doivent avoir suffisamment de temps pour pouvoir présenter les dossiers techniques aux organismes notifiés et pour reconcevoir certains produits conformément aux exigences des standards disponibles. Même avec cet ajustement du calendrier, les délais restent très courts pour les fabricants afin d'être en conformité avec lensemble des exigences à venir.
Read full responseResponse to Cyber Resilience Act
22 Dec 2022
The exponential growth in the use of connected products makes the security of such devices obvious. As equipment manufacturer we believe that an horizontal regulation covering wireless and wired products connected to internet is needed. However, Hager thinks that the scope in CRA draft proposal is much wider than the initial intention which was to complete RED delegated Act, Regulation (EU) 2022/30, activating Articles 3.3(d), (e) and (f) by considering all internet wired products. The scope proposed in the draft regulation is covering all equipment with a digital element, which means almost all electronic products, this is a dramatic extension of the scope. The creation of a CE marking for software in this field is new and counterproductive. Hager sees especially a risk for software as it will be extremely difficult for third party labs /notified bodies to emit an opinion about software without a risk for Intellectual Property Rights. With the current proposal, its impossible to disseminate quickly a security patch without going back to a 3rd party each time. This is an unbelievable situation. This CE marking principle for software is killing the goal of security which is pursued by the regulation. Short reaction time to close a vulnerability is definitively key and cant be overridden without creating a security risk. Software updates are usually done several times per year, the cost to go each time to 3rd party for approval will be an intolerable cost for manufacturers but even more for customers. Moreover, it will create issues when providing an extension of an existing installation for new products but also spare parts as being designed before this new regulation. Spare parts need to be excluded from this regulation. To discover that a vulnerably was exploited may also take long time and time for investigation, therefore the obligation to report within 24h to ENISA will just be an impossible requirement to meet. Regarding the risk categorization, we find that Class I products should be more products related to security such as alarm systems in industrial environment and reserve class II for security systems in critical environment such as NIS 2 essential entities. In article 6: products designed to control operational technology are considered critical. Due to the large definition of Operational Technology most of products are considered critical. This is not correct, we propose to replace operational technology to include products which can cause serious effects on critical infrastructures (e.g. critical industrial processes). As general comment, when the word network is used, its not clear if it refers to public network such as internet, or its any type of networks including private networks. This will include in this regulation many products which do not have any risk related to attack over internet because they are simply not connected to internet. We noted that the recital 27 is extremely important to clarify the understanding, this clarification is more than welcome. In the class I scope described in Annex IIIAnnex III class I: (15) physical network interface is questionable: According recital (27), what does mean the core function of the products shall be a physical network interface? Are internet gateways being thought of? All connected products have one or more physical network interfaces (e.g. Ethernet, wifi, bluetooth), but depending the security architecture retained during installation, some interfaces might not have security measures because they are in a safe environment (e.g. locked doors, behind a firewall, skilled persons access only, etc) As a clarification is required here, weclarification is required here, we suggest to replace network interface by public network interface otherwise all connected products on the market will be at least class I and the default category will never exist.
Read full responseResponse to Review of ecodesign and information requirements for external power supplies (EPS)
28 Apr 2022
While, it seems to be a good idea at first glance for conventional EPS such as computers, mobile phones, wearable, there are many other usage which requires different voltage or combination of Voltage/current which are not provided by USB and Power Delivery protocol. For example, many products needs to have 48V DC external power supplies with high current. This will not be possible anymore with USB as it's limited to 100W/240W. Also many EPS which are located for example in electrical installation dashboard and are powering field buses in home or building automation systems will not be able to comply with USB EPS. At the output of such specific EPS, the data are transmitted on the same pair as the power, this is not possible with a USB connector. These field busses are using other standardised connectors and will not be able to adapt. Moreover, existing EPS were just adapted to the former evolution (2019). industry needs stability, therefore, we recommend option a) No EU change.
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