ITI - The Information Technology Industry Council

ITI

ITI is the leading trade association for global technology companies, advocating on digital policy issues in the EU, US, and Asia.

Lobbying Activity

Meeting with Egelyn Braun (Cabinet of Commissioner Michael McGrath)

14 Jan 2026 · Exchange of views on digital policy

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology)

9 Dec 2025 · Exchange of views on the simplification agenda and the digital omnibus

ITI Urges EU Quantum Act To Prioritize Global Cooperation

26 Nov 2025
Message — ITI supports a unified research framework but warns against restrictive "Made in EU" rules. They suggest a common licensing regime with trusted allies to foster innovation and resilience.123
Why — This allows their members to access European markets and funding via global supply chains.4
Impact — Advocates for strict digital sovereignty lose as the proposal rejects isolationist policies for international diversification.5

Meeting with Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

25 Nov 2025 · Participate as speaker at ITI Europe Committee meeting

Tech Industry Urges EU to Narrow Foreign Subsidies Rules

18 Nov 2025
Message — The organization requests exempting non-selective financial contributions from notification requirements, clarifying distortion criteria, and establishing guardrails around presumptions of cross-subsidization. They argue the current rules create excessive compliance burdens and unpredictable procedures at odds with EU competitiveness goals.123
Why — This would reduce their compliance costs and administrative burden from unexpectedly high filing volumes.45
Impact — EU market oversight loses tools to identify subsidies that distort competition and harm European companies.6

Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

17 Nov 2025 · EU tech competitiveness agenda

Meeting with Michael Mcnamara (Member of the European Parliament)

13 Nov 2025 · EU digital policies

Meeting with Despina Spanou (Deputy Director-General Communications Networks, Content and Technology)

13 Nov 2025 · Digital Omnibus proposal and revision of the Cybersecurity Act

Meeting with Kosma Złotowski (Member of the European Parliament)

12 Nov 2025 · Digital services and simplification of EU regulations

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

12 Nov 2025 · European tech sovereignty

ITI urges delay of EU AI and Data Acts

14 Oct 2025
Message — ITI requests postponing implementation of the Data Act, AI Act, and Cyber Resilience Act by at least 24 months. They argue current timelines are unrealistic given insufficient guidance, delayed standards, and legal uncertainty. They also call for harmonizing overlapping requirements across cybersecurity frameworks and clarifying key definitions in the Data Act.123
Why — This would reduce compliance costs and provide time to adapt technical systems.45

Meeting with Ewa Malz (Head of Unit Environment)

14 Oct 2025 · ITI Sustainability Committee

Tech Industry Urges No New Digital Fairness Rules

7 Oct 2025
Message — ITI requests the Commission abandon new Digital Fairness Act legislation and instead focus on implementing existing rules like the DSA, DMA, and AI Act. They argue current laws already address the identified problems and new rules would create legal uncertainty and compliance burdens.1234
Why — This would reduce compliance costs and legal uncertainty for tech companies.567
Impact — Consumers lose stronger protections against manipulative design and personalization practices.89

Meeting with Jörgen Warborn (Member of the European Parliament)

17 Sept 2025 · Digital simplification

Meeting with Jörgen Warborn (Member of the European Parliament) and Google and

11 Sept 2025 · GenAI and Copyright

Meeting with Emmanuelle Du Chalard (Head of Unit Communications Networks, Content and Technology)

11 Sept 2025 · Exchange of views on copyright and AI

Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)

4 Sept 2025 · Copyright and generative artificial intelligence

I T I Urges E U to Expand Digital Product Compliance Options

3 Sept 2025
Message — I T I requests that digitalization measures apply consistently across all relevant horizontal and sector-specific legislation. They recommend allowing digital-only documentation by default and removing ambiguous language regarding consumer use. The organization urges the Commission to use common specifications only as a last resort.123
Why — These changes would significantly reduce manufacturing costs and simplify global compliance efforts.45
Impact — European companies face market fragmentation and reduced competitiveness from non-consensus technical specifications.67

ITI Urges EU to Expand Digital Product Labelling Rules

3 Sept 2025
Message — ITI requests that digital documentation become the default option for all products to replace paper instructions. They also want the Commission to prioritize industry-led standards over government-imposed technical specifications.12
Why — Tech companies would lower manufacturing expenses and environmental footprints by eliminating mandatory paper manuals.34
Impact — European standards bodies lose authority as the Commission gains power to set technical rules.5

Response to Revision of the 'New Legislative Framework'

2 Sept 2025

ITI welcomes the European Commissions initiative to review and update the New Legislative Framework (NLF) as part of its broader efforts to future-proof EU product legislation. In our view, the NLF has proven to be a strong and stable foundation for harmonized product regulation across the EU, and we believe that its core architecture remains fit for purpose. That said, there is a case for selective and targeted updates, not to reinvent the framework, but to ensure that it remains relevant and effective in the face of rapid technological and regulatory change. In particular, we urge the Commission to place digitalization and regulatory coherence at the heart of this revision. We believe that doing so is essential to achieving the Commissions own goals of simplification, sustainability, and competitiveness, and to be aligned with the broader green and digital transitions. More details on the ITI's position are provided in the attached document.
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Response to Revision of the Standardisation Regulation

21 Jul 2025

The Information Technology Industry Council (ITI) appreciates the opportunity to respond to the European Commissions Call for Evidence concerning the potential revision of Regulation 1025/2012 on European standardization. As a representative of the global technology sector, ITI supports the Commissions objective to ensure the European standardization system is fit for purpose, particularly in light of rapid innovation cycles, evolving policy priorities, and increasing global interdependence in standardization processes. However, as we have consistently stated in our earlier contributions, we urge caution in approaching this revision through legal reform alone. In ITIs view, the main shortcomings of the current standardization framework lie not in the legal text of Regulation 1025/2012, but in how it is implemented. The challenges faced today, such as the slowdown in OJEU citations and the procedural complexities, stem largely from operational inefficiencies rather than regulatory design. These issues not only hinder the availability of harmonized standards but also risk undermining Europes ability to leverage mechanisms for cooperation in standards development, including the Vienna Agreement, which has been crucial in avoiding duplication and supporting global coherence. Any review of the Regulation must begin with EU customers in mind by addressing the persistent practical and procedural bottlenecks that hinder its effectiveness and the performance of the system it governs. You can find ITI's more detailed feedback and recommendations in the attached paper.
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Response to Revision of the Standardisation Regulation

20 Jul 2025

The Information Technology Industry Council (ITI) appreciates the opportunity to respond to the European Commissions Call for Evidence concerning the potential revision of Regulation 1025/2012 on European standardization. As a representative of the global technology sector, ITI supports the Commissions objective to ensure the European standardization system is fit for purpose, particularly in light of rapid innovation cycles, evolving policy priorities, and increasing global interdependence in standardization processes. However, as we have consistently stated in our earlier contributions, we urge caution in approaching this revision through legal reform alone. In ITIs view, the main shortcomings of the current standardization framework lie not in the legal text of Regulation 1025/2012, but in how it is implemented. The challenges faced today, such as the slowdown in OJEU citations and the procedural complexities, stem largely from operational inefficiencies rather than regulatory design. These issues not only hinder the availability of harmonized standards but also risk undermining Europes ability to leverage mechanisms for cooperation in standards development, including the Vienna Agreement, which has been crucial in avoiding duplication and supporting global coherence. Any review of the Regulation must begin with EU customers in mind by addressing the persistent practical and procedural bottlenecks that hinder its effectiveness and the performance of the system it governs. You can find ITI's full position and recommendations in the attachment.
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ITI Calls for Simplified Data Rules to Empower AI Innovation

18 Jul 2025
Message — ITI calls for ambitious regulatory simplification to address overlapping rules between the GDPR and the Data Act. They recommend delaying Data Act implementation by 24 months and narrowing definitions to exclude products like smartphones and computers.123
Why — This would reduce heavy compliance burdens and prevent the forced disclosure of valuable corporate trade secrets.4
Impact — Public sector bodies and data users would lose guaranteed access to proprietary technical information.5

ITI Urges EU to Modernize Rather Than Overregulate Networks

11 Jul 2025
Message — ITI opposes new regulatory interventions in the interconnection market and warns against "de facto network fees" through arbitration. They request that the Digital Networks Act focuses on simplifying the framework and ensuring cloud and content providers stay out of scope.123
Why — This approach prevents massive compliance costs and legal uncertainty for global technology and cloud providers.4
Impact — Major European telecom operators would lose the opportunity to extract non-market fees from content providers.5

ITI urges clearer EU rules for reporting unsold products

10 Jul 2025
Message — The organization requests a transitional period allowing for estimated data and a reporting format aligned with existing sustainability disclosures. They also want reporting limited to products destined for waste rather than those disassembled for parts.123
Why — This would streamline compliance and reduce the financial burden of redundant third-party auditing.45
Impact — Regulators and environmental groups lose access to precise data if companies use estimated figures.6

ITI Urges EU to Keep Cloud Markets Open and Competitive

3 Jul 2025
Message — ITI requests that the EU simplify data center permitting and avoid creating overlapping regulations. They emphasize maintaining an open market that allows partnerships with global technology providers.12
Why — Streamlined rules would lower investment barriers and operational costs for major global tech companies.3
Impact — European cloud firms lose the competitive shield of sovereignty requirements and local procurement preferences.4

Meeting with Sandro Ruotolo (Member of the European Parliament)

3 Jul 2025 · Eu digital policies (AI Act, GDPR, platforms)

ITI Urges EU to Streamline Cybersecurity Rules and ENISA Mandate

17 Jun 2025
Message — ITI requests the simplification of overlapping regulations and the removal of political sovereignty requirements. They advocate for alignment with international standards to ensure global interoperability.12
Why — Streamlining regulations would decrease compliance costs and free up resources for innovation.3
Impact — National authorities lose the ability to set unique domestic cybersecurity requirements.4

ITI Urges EU to Simplify Rules and Stop New AI Laws

4 Jun 2025
Message — ITI requests ambitious simplification of rules and urges no further AI-specific regulation this mandate. They also propose postponing certain requirements until harmonized technical standards are available.123
Why — This would lower regulatory costs and protect proprietary technical secrets from government access.45
Impact — European businesses and consumers lose access to cutting-edge tools if sovereignty-based restrictions are imposed.67

Response to Quantum Strategy of the EU

2 Jun 2025

Please refer to the attached paper for ITI's feedback on the Call for evidence.
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Meeting with Agata Gerba (Head of Unit Trade)

22 May 2025 · Digital trade policy

Response to International Digital Strategy

21 May 2025

ITI welcomes the European Commissions focus on the international dimension of the digital economy and the opportunity to provide feedback on an International Digital Strategy for Europe. As a global tech association, ITI has long advocated for open and reliable digital trade opportunities, multilateral cooperation, and the fostering of an inclusive, rules-based international digital environment. Europe plays a critical role in this landscape, both as a leading exporter and importer of technology and digital services, and as a trusted partner in shaping global digital governance. We urge the Commission to maintain a cooperative and open approach, reaffirming the EUs commitment to building international partnerships and advancing shared digital goals. ITI has consistently supported initiatives like the EU-US Trade and Technology Council (TTC), which has served as a model for international digital cooperation as well as the Digital Partnerships and Digital Dialogues. The establishment of similar frameworks globally can significantly enhance the EUs role as a key facilitator of digital innovation, particularly if those frameworks are utilized to secure clear, meaningful outcomes. Importantly, such cooperation will contribute to the EUs economic security objectives, in line with the partnering pillar and contributing to the promoting EU competitiveness pillar of the European Economic Security Strategy. We support the expansion of trade agreements, strengthening cybersecurity cooperation and policy alignment, and fostering diversification and redundancy in supply chains, prioritizing resilience over protectionism. Attracting investment in sustainable data centers, advanced computing infrastructure, and AI capacities represents a key dimension, as these technologies form the foundation of digital competitiveness. At the same time, it is important to maintain an open approach that ensures continued access to these critical technologies from global partners. We also strongly encourage a firm commitment to preventing internet fragmentation and maintaining secure, open, and interoperable data flows. These principles are essential to preserving the global internet and ensuring that digital transformation remains inclusive and innovative.
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Meeting with Manuel Mateo Goyet (Acting Head of Unit Communications Networks, Content and Technology)

15 May 2025 · State of play on the Cloud and AI Development Act.

Meeting with Cathrin Bauer-Bulst (Cabinet of Commissioner Magnus Brunner)

15 May 2025 · ProtectEU Strategy

Meeting with Axel Voss (Member of the European Parliament, Rapporteur) and Google and

6 May 2025 · Copyright and generative AI

Meeting with Matjaž Malgaj (Head of Unit Environment)

29 Apr 2025 · Implementation of the Ecodesign for Sustainable Products Regulation (ESPR)

Meeting with Dusan Chrenek (Principal Adviser Climate Action)

28 Apr 2025 · Digitalization for decarbonization in industry

Meeting with Kilian Gross (Head of Unit Communications Networks, Content and Technology)

23 Apr 2025 · Exchange of views on AI Act implementation

Response to Technical description of important and critical products with digital elements

18 Apr 2025

Thank you for the opportunity to provide comments on the draft Implementing Act concerning the technical descriptions of the categories of important and critical products with digital elements pursuant to the Cyber Resilience Act. Please find attached the response of the Information Technology Industry Council (ITI). ITI is the premier global advocate for the technology sector, representing the worlds most innovative companies.
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Meeting with Kamil Talbi (Cabinet of Commissioner Dan Jørgensen)

27 Mar 2025 · Digitalisation and energy

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

26 Mar 2025 · Discussion on how the global tech industry can support the EU’s climate goals

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

13 Mar 2025 · Simplification

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič)

13 Mar 2025 · - EU-U.S. relations on key technology and trade topics - WTO - The digital dimension of the EU Economic Security Strategy & associated EU initiatives - Standardization Regulation revision and trade implications

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

13 Mar 2025 · EU digital policy

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič)

13 Mar 2025 · International trade developments

Meeting with Nils Behrndt (Deputy Director-General Justice and Consumers)

12 Mar 2025 · Inform and discuss the Commission's work on the Digitalisation of Justice, AI and data, and consumer law - Digital Fairness Act.

Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Mar 2025 · Priorities related to the competitiveness compass

Meeting with Aurel Ciobanu-Dordea (Director Environment)

11 Mar 2025 · Exchange of views on the Green Deal legislation and EU’s sustainability goals.

ITI urges EU to simplify and harmonize public procurement rules

6 Mar 2025
Message — ITI requests a 25% reduction in administrative burdens to simplify the procurement process. They want the EU to reject "European preference" policies that restrict access to global technology. They also call for harmonized cybersecurity and sustainability standards across all Member States.123
Why — Streamlining these rules would lower entry barriers for global technology firms in Europe.45
Impact — Domestic European manufacturers lose protected status if local content preferences are eliminated.6

Tech Group ITI Urges EU to Streamline Digital Regulations

31 Jan 2025
Message — ITI requests a competitiveness check for new laws and better coordination between regulators. They also propose withdrawing the AI Liability Directive to reduce legal complexity.123
Why — This would lower administrative costs and provide the legal certainty needed to innovate.45
Impact — The withdrawal of the AI liability proposal reduces the legal avenues for injured parties.6

Meeting with Danuše Nerudová (Member of the European Parliament, Shadow rapporteur) and European Association of Communications Agencies

15 Jan 2025 · discussions on Green Claims Directive

Meeting with Brando Benifei (Member of the European Parliament)

4 Nov 2024 · Meeting on the UE digital and AI policies

Meeting with Javier Zarzalejos (Member of the European Parliament, Committee chair) and DOT Europe

18 Sept 2024 · LIBE Committee priorities

Response to Rules specifying the obligations laid down in Articles 21(5) and 23(11) of the NIS 2 Directive

25 Jul 2024

Please find attached the response to the consultation from ITI, the Information Technology Industry Council.
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

ITI, as explained further in the position paper attached, encourages the EU to maintain green list procedures for non-hazardous e-waste shipped within the EU for recovery operations. Retaining current non-hazardous e-waste codes and related green list classifications for low-risk intra-EU shipments destined for recovery will promote circularity within the EU by, e.g., allowing valuable materials to move efficiently to EU jurisdictions with facilities that have the capacity for environmentally sound management (ESM) of e-wastes and critical resource recovery. These shipments would continue to be subject to the general information requirements of Article 18 in the WSR, providing transparency and assurances of environmentally sound management of waste. Further, a green list approach for low-risk e-waste would mitigate environmental and business risks associated with delayed or trapped shipments in EU Member States without highly specialized facilities for recycling and resource recovery (where there may be risk of, e.g., mismanagement, speculative accumulation of waste materials, improper storage, and/or lower-value end-of-life treatment). Applying PIC (amber list) controls to all intra-EU shipments of non-hazardous e-wastes, on the other hand, would introduce new trade frictions and implementation challenges for competent authorities and the regulated community. In light of the current practice under the WSR, we anticipate that the regulatory burden would increase significantly if all e-wastes are subject to control under the new Basel entries even for intra-EU shipments (i.e., shipments that are taking place entirely within the EU single market). We note that Member States will also need capacity to manage the additional growth in PIC notices and other requirements that will apply to shipments of e-waste into or out of the EU. Ultimately, keeping EU non-hazardous e-waste codes and their associated green list classifications strikes the right balance between ensuring sound environmental management and facilitating trade in valuable non-hazardous materials within the EU single market. To conclude, in the event the EU opts to not retain green list classification of non-hazardous e-waste shipments within the EU (i.e., starts subjecting these shipments to amber controls), the ICT sector urges the EU to avoid compounding challenges with the current already-strained PIC system. The EU could consider, for instance, a phased implementation approach for new amber controls e.g., subjecting higher-risk hazardous waste shipments within the EU to the PIC system first, and delaying amber controls for lower-risk intra-EU shipments until the electronic PIC system is functioning and can accommodate dramatically higher volumes of PIC requests. ITI remains open to collaborating and engaging in dialogue with the European Commission and other stakeholders to further promote the goals of circularity and sustainability and appreciates the Commissions consideration of the mentioned aspects.
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ITI Warns EU Against Expanding Telecom Rules to Cloud

28 Jun 2024
Message — ITI requests a clear regulatory distinction between traditional telecommunications and modern cloud services. They urge the Commission to reduce existing administrative burdens instead of creating new rules. The organization specifically opposes mandatory dispute resolution for internet traffic routing.123
Why — This approach would protect their members from significant new compliance costs across different sectors.4
Impact — Established telecom providers lose the chance to force tech companies to pay network fees.5

Response to Options for support for R&D of dual-use technologies

23 Apr 2024

Please find attached comments from the Information Technology Industry Council (ITI).
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Response to White Paper on Dual-Use Export Controls

23 Apr 2024

The Information Technology Industry Council (ITI) welcomes the opportunity to submit comments.
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Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

23 Apr 2024

The Information Technology Industry Council (ITI) welcomes the opportunity to submit the attached comments.
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Response to Recommendation to monitor outbound investments for further risk assessment

16 Apr 2024

The Information Technology Industry Council (ITI) welcomes the opportunity to provide the attached comments on "Investments by EU companies in non-EU countries - monitoring for further risk assessment."
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ITI urges pragmatic GDPR application to foster tech innovation

8 Feb 2024
Message — The ITI requests a more proportionate application of rules without changing the underlying legislation. They advocate for streamlined international data transfers and clearer guidance on data processing. They also suggest requiring consumers to exhaust internal company complaints before contacting regulators.123
Why — This would reduce compliance costs and administrative burdens while facilitating global business operations.4
Impact — Consumers may find it harder to access regulators directly due to mandatory internal appeals.5

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

24 Jan 2024 · Digital issues

Meeting with Daniel Braun (Cabinet of Vice-President Věra Jourová), Marie Frenay (Cabinet of Vice-President Věra Jourová), Wojtek Talko (Cabinet of Vice-President Věra Jourová)

24 Jan 2024 · AI

Response to Business in Europe: Framework for Income Taxation (BEFIT)

17 Jan 2024

Please see attached document on behalf of the Information Technology Industry Council (ITI).
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Meeting with Alejandro Cainzos (Cabinet of Vice-President Věra Jourová), Daniel Braun (Cabinet of Vice-President Věra Jourová)

14 Nov 2023 · Artificial Intelligence, EU-U.S. cooperation, cyber-security

Meeting with Deirdre Clune (Member of the European Parliament)

31 Oct 2023 · IMCO Mission - Digital Policies

Meeting with Jana Toom (Member of the European Parliament, Shadow rapporteur)

23 Oct 2023 · GDPR Enforcement

Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

The Information Technology Industry Council (ITI) - the global association of the tech industry - welcomes this opportunity to provide feedback to the European Commission on the performance of the European Union Agency for Cybersecurity (ENISA), as well as on the impact, effectiveness, and efficiency of the provisions of European cybersecurity certification framework. ITI appreciates the efforts of the European Commission and ENISA to protect data, systems, and infrastructure from anomalous behaviour and prevent unauthorised access. However, we see several areas for improvement as ENISAs role is becoming more prominent as it is taking on additional responsibilities pursuant to new legislation which has recently been adopted or are currently being discussed by the co-legislators, in particular the NIS 2 Directive and the Cyber Resilience Act (CRA). In particular, we believe that: ENISAs work requires increased transparency and collaborative processes; ENISAs status as a technical and independent agency should be guaranteed; ENISA needs more resources to support an increasing workload, work collaboratively with international partners and to be more visible in international debates. Please find attached our detailed comments. We remain at your disposal for any questions you may have.
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ITI Urges Internal Resolution Mechanisms in GDPR Enforcement

4 Sept 2023
Message — ITI advocates for a hierarchy of resolution mechanisms requiring complainants to exhaust internal processes first. They also seek to ensure investigated parties can provide submissions directly to the European Data Protection Board.12
Why — This approach shields companies from immediate scrutiny while protecting sensitive documents through strict confidentiality sanctions.34
Impact — Complainants may face delayed access to independent oversight due to mandatory internal corporate dispute procedures.5

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Shadow rapporteur)

17 Jul 2023 · Metaverse

Meeting with Pablo Arias Echeverría (Member of the European Parliament, Rapporteur) and The LEGO Group

21 Jun 2023 · Virtual Worlds

Response to Promoting sustainability in consumer after-sales

25 May 2023

Please find ITI's feedback attached.
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Response to Virtual worlds, such as metaverse

3 May 2023

Please find attached the feedback from ITI, the Information Technology Industry Council.
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Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur)

11 Apr 2023 · EU Cyber Resilience Act

Meeting with Brando Benifei (Member of the European Parliament, Rapporteur)

4 Apr 2023 · Discussion on the AIA and AI

Tech industry body ITI warns against rigid GDPR enforcement deadlines

24 Mar 2023
Message — ITI urges the Commission to prioritize due process and avoid arbitrary investigation deadlines. They request that businesses be granted a right to be heard before the board.12
Why — Enhanced due process and flexible timelines reduce the risk of costly, rushed regulatory penalties.3
Impact — Regional authorities lose power if coordination rules are limited to protect lead authority independence.4

ITI Warns New EU Tax Rules Risk Trade Tensions

24 Jan 2023
Message — ITI recommends making the tax framework optional for companies to use. They urge the Commission to stick to established international transfer pricing rules. They suggest pursuing limited tax adjustments instead of comprehensive new rules.123
Why — Optional rules would prevent high compliance costs for tech companies.4
Impact — EU member states may lose investment if intangible assets are ignored.5

ITI Urges Longer Transition Periods for Cyber Resilience Act

23 Jan 2023
Message — The industry group requests extending the transition period to 72 months to develop standards. They argue incident reporting should focus only on significant events to avoid overwhelming authorities. They also recommend sending reports to national agencies instead of a central European body.123
Why — A longer implementation window would reduce immediate compliance burdens and operational costs.45
Impact — Centralizing vulnerability data creates a honeypot that risks exposing users to malicious actors.6

ITI Council Urges Balanced Liability Rules to Protect Innovation

9 Dec 2022
Message — ITI warns strict liability for software would spread responsibility disproportionately. They recommend excluding open-source software from the new rules. Maintaining financial thresholds is necessary to prevent frivolous legal claims.123
Why — This would lower compliance costs and ensure risks remain insurable for developers.4
Impact — Consumers would face higher barriers when seeking compensation for smaller product damages.5

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

6 Oct 2022 · Data Act, AI Act, EU-US Trade and Technology Council

Tech industry urges realistic EU repair rules for smartphones

28 Sept 2022
Message — ITI suggests limiting spare part mandates to frequent failures to avoid waste. They request a two-year transition and oppose rules for restoring old software.123
Why — Reducing spare part mandates and extending deadlines lowers storage costs and eases manufacturing pressure.45
Impact — Right-to-repair advocates and consumers would face fewer available parts and stricter professional requirements.67

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton) and DOT Europe and

16 Sept 2022 · Product liability directive

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Telefonica, S.A. and

31 Aug 2022 · AI Act

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion) and Amazon Europe Core SARL and

29 Jun 2022 · Joint exchange of views on the Data Act

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

29 Jun 2022 · Data & Cloud

Response to Sustainable Products Initiative

22 Jun 2022

ITI - the Information Technology Industry Council is the premier global advocate for technology, representing the world’s most innovative companies from technology, hardware, software, services, and related industries. We appreciate the opportunity to provide comments to the Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products (ESPR). Please refer to the attached document with ITI's feedback.
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Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament)

9 Jun 2022 · Digital files

Response to Cyber Resilience Act

25 May 2022

ITI - The Information Technology Industry Council appreciates the opportunity to submit comments to the European Commission on the Cyber Resilience Act consultation. ITI is the premier global advocate for technology, representing the world’s most innovative companies. Founded in 1916, ITI is an international trade association with a team of professionals on four continents. We promote public policies and industry standards that advance competition and innovation worldwide. Our diverse membership and expert staff provide policymakers the broadest perspective and thought leadership from technology, hardware, software, services, and related industries. Please refer to the attached paper for ITI's detailed feedback to the call for evidence.
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Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

18 May 2022 · Digital Services Act, Data Act

Meeting with Eva Maydell (Member of the European Parliament, Rapporteur)

18 May 2022 · Chips Act

ITI Urges Stronger Protections for Trade Secrets in Data Act

13 May 2022
Message — ITI recommends that policymakers strengthen the possibility for data holders to apply safeguards for trade secrets. They also urge an implementation timeline of three years to manage technical costs.12
Why — This would help companies protect proprietary information and avoid high immediate compliance expenses.34
Impact — Third-party innovators lose access to technical critical data needed to offer novel business services.56

Response to European chips act package – Regulation

9 May 2022

Please refer to the attached document for ITI's feedback.
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Response to Review of ecodesign and information requirements for external power supplies (EPS)

2 May 2022

The Information Technology Industry Council (ITI) is the premier global advocate for technology, representing the world’s most innovative companies. Founded in 1916, ITI is an international trade association with a team of professionals on four continents. We promote public policies and industry standards that advance competition and innovation worldwide. Our diverse membership and expert staff provide policymakers the broadest perspective and thought leadership from technology, hardware, software, services, and related industries. ITI appreciates the opportunity to provide comments on the European Commission’s Call for Evidence on External Power Supplies –Ecodesign & information requirements. Please find ITI's comments attached.
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Meeting with Didier Reynders (Commissioner) and

26 Apr 2022 · Data transfer

Meeting with Petar Vitanov (Member of the European Parliament, Shadow rapporteur)

17 Mar 2022 · AI act

Response to Minimum level of taxation for large multinational groups

11 Mar 2022

Please find attached comments on behalf of the Information Technology Industry Council (ITI). We appreciate the opportunity to provide feedback.
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Meeting with Josianne Cutajar (Member of the European Parliament, Shadow rapporteur)

21 Feb 2022 · Digital Decade Policy Programme

Meeting with Renate Nikolay (Cabinet of Vice-President Věra Jourová)

13 Oct 2021 · Privacy, data flow,transatlantic cooperation

Response to Review of the general product safety directive

26 Aug 2021

Dear Madam or Sir, On behalf of the Information Technology Industry Council (ITI), please find attached detailed comments on the proposed revision of the General Product Safety Directive. Kind regards, Vivien Witt
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Response to Standardisation Strategy

6 Aug 2021

On behalf of the Information Technology Industry Council (ITI), I respectfully submit the attached comments.
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Response to Requirements for Artificial Intelligence

6 Aug 2021

Please refer to the attached paper for ITI's detailed feedback to the proposal.
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Jul 2021

Please refer to the attached document for ITI's detailed comments to the Inception Impact Assessment.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

Please find enclosed ITI's detailed feedback to the Inception Impact Assessment.
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Meeting with Monika Maglione (Cabinet of Commissioner Ylva Johansson)

7 Jun 2021 · Meeting on the global debate on government access to data, notably within the OECD.

Response to Revision of the NIS Directive

18 Mar 2021

Dear Madam or Sir, We are pleased to share ITI's views on the proposal for a revision of the NIS Directive. Please find our detailed comments in the submission attached. Kind regards, Vivien Witt on behalf of ITI, the Information Technology Industry Council
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

15 Mar 2021

Dear Sir or Madam, Please find attached our detailed submission with feedback on the European Commission's DSA proposal. Kind regards, Vivien Witt on behalf of ITI - Information Technology Industry Council
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Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

Please refer to the attached paper for ITI's detailed feedback.
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Meeting with Valdis Dombrovskis (Executive Vice-President)

25 Feb 2021 · EU-US trade relations; Trade Policy Review; Digital trade, including EU's position on e-commerce and Digital taxation.

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

19 Feb 2021 · EU policy files relevant to the technology industry - transatlantic trade & data flows, Digital Decade, digital & green, Artificial Intelligence, Digital Services Act, Digital Markets Act

Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

19 Feb 2021 · DSA, DMA, AI

Response to Digital Operational Resilience of Financial Services (DORFS) Act

15 Feb 2021

Please refer to the attached document for ITI's detailed comments.
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Response to Digital Levy

11 Feb 2021

Please refer to the attached paper for ITI's detailed feedback.
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Meeting with Věra Jourová (Vice-President)

11 Feb 2021 · DSA, DMA, AI, Privacy and data flows

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

2 Feb 2021 · Digital priorities for Europe

Response to Legislative framework for the governance of common European data spaces

29 Jan 2021

Please refer to the attached position paper for ITI's detailed comments.
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Meeting with Axel Voss (Member of the European Parliament)

13 Jan 2021 · Artificial Intelligence

Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

Dear Sir or Madam, Please find our detailed comments on the draft standard contractual clauses for transferring personal data to non-EU countries (implementing act) in attachment. We remain at your disposal should you have questions or comments. Kind regards, Vivien Witt on behalf of ITI
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Please refer to the attached position paper for our detailed feedback.
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Meeting with Axel Voss (Member of the European Parliament)

27 Aug 2020 · Artificial Intelligence

Response to Revision of the NIS Directive

13 Aug 2020

The Information Technology Industry Council (ITI) appreciates the opportunity to submit the attached comments to the European Commission on the NIS Directive combined evaluation roadmap/inception impact assessment. ITI is the global association of the tech industry. Our membership comprises over 73 leading technology and innovation companies from all corners of the ICT industry, including hardware, software, digital services, semiconductor, network equipment, cybersecurity, and Internet companies. We welcome the European Commission’s focus on revising the NIS Directive and the plan to publish its review of the functioning of the Directive pursuant to its obligation in Article 23 (2). ITI and its members strongly believe that for Europe to achieve its ambitious digitalisation goals, the EU should ensure cybersecurity resilience of all key economic sectors and increase the level of harmonisation of requirements in different sectors. We stand ready to support these efforts by inputting to the NIS Directive review consultation. We agree with the basic premise in this consultation—that the EU should take steps to improve cybersecurity. In terms of possible policy options presented in Section B to achieve these objectives, we would suggest either #2 (non-legislative means such as guidelines) or #3 (regulatory intervention that introduces targeted changes to the current NIS Directive), or a combination of both. Regardless of the instrument chosen, we offer detailed recommendations in the full submission attached. We remain at your disposal for any questions regarding our submission.
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Response to New competition tool

30 Jun 2020

Please find our detailed submission attached. Thank you for your consideration.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

30 Jun 2020

Please find our detailed submission attached. Thank you for your consideration.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

Please find our detailed response attached. Thank you for your consideration.
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Response to Report on the application of the General Data Protection Regulation

16 Apr 2020

Dear Sir or Madam, Please find attached our submission commenting on the two-year review of the GDPR. We thank you in advance for considering our views. Best regards, Vivien Zuzok on behalf of the Information Technology Industry Council (ITI)
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Meeting with Phil Hogan (Commissioner)

5 Mar 2020 · Trade Issues

Meeting with Phil Hogan (Commissioner)

5 Mar 2020 · Trade Issues

Meeting with Didier Reynders (Commissioner) and

3 Mar 2020 · Presentation ITI + discuss the priorities with regards to privacy and data protection

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

28 Jan 2020 · Introduction association; artificial intelligence & data strategy; digital services act

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

28 Jan 2020 · Overall digital policy, including technological sovereignty, open multilateral economic governance, trade in technology, data strategy

Meeting with Filomena Chirico (Cabinet of Commissioner Thierry Breton)

28 Jan 2020 · Priorities for tech regulation, single market and enforcement

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Mar 2019 · tech policy

Meeting with Jean-Luc Demarty (Director-General Trade)

21 Mar 2019 · EU-U.S. trade, WTO, international data flows

Meeting with Fredrik Beckvid Tranchell (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Pedro Velasco Martins (Cabinet of Vice-President Cecilia Malmström)

20 Mar 2019 · General state of play trade / doing business in China

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

20 Mar 2019 · AI incl draft ethics guidelines, ePrivacy, GDPR, cybersecurity, Next Generation internet, US digital policies

Meeting with Tiina Astola (Director-General Justice and Consumers)

18 Mar 2019 · courtesy

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

11 Oct 2018 · data privacy, cybersecurity, data flows

Meeting with Michael Hager (Cabinet of Vice-President Günther Oettinger)

9 Oct 2018 · digital policy

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

9 Oct 2018 · Connect Initiatives: AI, cybersecurity, ePrivacy

Meeting with Andrus Ansip (Vice-President) and

20 Sept 2018 · GDPR, privacy shield, e-privacy

Meeting with Andrus Ansip (Vice-President) and

18 Apr 2018 · Cybersecurity

Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

21 Mar 2018 · Digital taxation

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

20 Mar 2018 · Technology sector and investment screening

Response to Energy labelling requirements for computers and computer servers

9 Mar 2018

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty. When considering the EU's own estimated sales figures from PRODCOM it shows a leveling/downward trend in sales numbers for Notebooks (NB) and Desktop (DT) PCs, this is certainly a true reflection of the market over the past few years, we continue to see a declining market in the EU. Further, it's estimated that implementation of CEC regulation and ENERGY STAR (E*) v7.0 specification will result in approximate energy efficiency improvements in Idle power of 50% for DT/AIO and NB PCs respectively. Future improvement potential will, however, diminish over time with only marginal incremental improvements in energy efficiency. The last stakeholder meeting provided some rough estimates of active usage patterns from ONE E*compliant NB. The conclusions suggest that "estimates around how long PCs are used for vary considerably across different studies even for the same type of PC (e.g. desktop PC)". No data exists to quantify a creditable estimate of the duty cycle of either NBs or DTs assuming a number of usage patterns. A comprehensive duty cycle and power study assessing the significance of active power is necessary to determine active power as significant, selection of the right workloads will also be a challenge to properly measure active mode power of PCs. Without such a study, proposing an energy label based on active power metric is premature. DIGITALEUROPE would be interested in providing support to such a study that the EC initiates to assess the usage patterns and characterize a typical duty cycle from various power modes including active, idle (short & long), sleep and off. Consideration on the Energy Label Introducing a PC Energy Label would be a complex exercise, high configurability of PC products based on active performance requires specific analysis. The existing E* label remains a well established and effective scheme for product differentiation. The E* programme serves as a significant global standard for the ICT sector, providing a stable regulatory framework and harmonization of methodologies. Furthermore the E* criteria have proven to be one of the main criteria supporting European GPP. Noting the termination of the EU-US Agreement, the ICT Industry remains committed to the E* criteria development and its continued basis for the PC regulatory review. Scope Industry cannot support a proposal to move tablets from the regulation. There are now a number of "hybrid devices" in the market which combine NB and tablets. Customer acceptance will increase further innovative designs. Legal uncertainty for such devices is a risk if regulated by 2 different regulations with differing requirements. Material efficiency The IT industry had submitted comments to the draft report "Analysis of material efficiency aspects of PC product group" in February '17. Some of these comments have been integrated into the final report, but many proposed measures to improve the material efficiency of PCs still lack practicability and present significant documentation and manufacturing effort with no added value. Namely, the industry is concerned that labelling requirements for product parts (e.g. plastics, batteries) and information requirements on materials (e.g. CRM) will not be effective to improve material recovery rates as state of the art WEEE sorting and recycling processes make no use of the information. Industry questions whether consumers seek technical performance details such as the IP class of a device, or the battery management features. Material efficiency measures should be practicable, consistent and result in quantifiable environmental benefits.
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Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis)

23 Jan 2018 · Forthcoming digital tax initiative

Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

6 Dec 2017

The Information Technology Industry Council (ITI) welcomes the European Commission’s Cybersecurity package, including the Proposed Regulation on cybersecurity certification. While we support the overall objectives of the Package, we would like to highlight some concerns and recommendations regarding the current proposal. Summary Recommendations 1. Prioritize and develop a work plan to address the creation of any cybersecurity certification schemes. 2. Promote security by design approaches grounded in international standards and best practices, and consider self-certification schemes as alternative tools. 3. Clarify the scope of any certification scheme (or schemes). 4. Leverage the expertise of public and private stakeholders to build upon existing initiatives and standards activities. 5. Continue international efforts, and prioritize international cybersecurity standardization. 6. Equip ENISA with adequate resources. 7. Prioritize investment in cybersecurity workforce training and skills development. 8. Adopt policies that facilitate cross-border data flows, within the single market and internationally, which are necessary for cyber defense. 9. Bolster initiatives that raise awareness. Select Further Detail (Please see the attached document for full detail on all the above recommendations.) 1. Develop a work plan. Because the current certification proposal is extremely broad and open-ended, we suggest the Commission approach its work in stages. There is a clear need both for prioritization and the development of a working plan, incorporating an industry role at the outset, to stage the various actions anticipated in the proposal. We suggest that as part of the first stage, the Commission should consider issuing high level recommendations focused on process, later supplementing them with recommendations on more specific issues as determined with input from industry and other stakeholders. 2. Promote security by design. ITI commends the Commission’s decision to resist developing a mandatory prescriptive cybersecurity labelling or certification regime in the EU, and we urge the adoption of safeguards to keep whatever certification schemes are ultimately developed voluntary. Foundationally, we encourage the Commission to work with the international standards bodies to establish security-by-design best practices. We applaud the commission for proposing certification schemes that are voluntary, an approach that will allow the market to drive demand and companies to differentiate their products. If a proposed certification scheme evolves to become mandatory, this may represent a market barrier especially for SMEs and start-ups across different regions of the world. Additionally, ITI encourages the Commission to consider more flexible and lightweight approaches such as self-certification schemes based on cybersecurity baselines, enabling companies of all sizes to more rapidly adopt processes defined by industry in cooperation with governments to address cybersecurity risks. 3. Clarify the scope of the proposed schemes. The certification framework as contemplated appears both extremely broad and somewhat ambiguous in its proposed application, insofar as it appears to contemplate certification schemes that would apply to all ICT products, components, systems, processes and services. Because there is no “one-size fits all” certification scheme that does or can apply across such a wide array of connected technologies and use models, the Commission should take efforts to clarify what will initially be in scope, perhaps prioritizing areas that may be ripe for progress. These areas could be prescribed in advance by scoping the legislation to products, services or systems necessitating high level security requirements, such as in critical infrastructures, and should be further refined as part of a process that ensures meaningful industry input. (Please see the attached document for our detailed recommendations.)
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Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

16 Nov 2017 · Cybersecurity

Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

16 Nov 2017 · Cybersecurity discussion

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

7 Nov 2017 · DSM general

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici), Lucie Mattera (Cabinet of Commissioner Pierre Moscovici)

21 Sept 2017 · Meeting to discuss the COM communication on the taxation of the digital sector adopted this week

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová), Renate Nikolay (Cabinet of Commissioner Věra Jourová)

23 Mar 2017 · EU-US Privacy shield, Implementation of GDPR and e-Privacy Regulation

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová) and DIGITALEUROPE

27 Jan 2017 · Privacy Shield and GDPR implementation

Meeting with Michael Hager (Digital Economy)

21 Sept 2016 · DSM

Meeting with Fabien Dell (Cabinet of Commissioner Pierre Moscovici), Lucie Mattera (Cabinet of Commissioner Pierre Moscovici), Maria Elena Scoppio (Cabinet of Commissioner Pierre Moscovici)

20 Sept 2016 · Various subjects: tax/state aid policy, trade policy, and the DSM strategy, among others

Meeting with Sebastian Kuck (Cabinet of Vice-President Jyrki Katainen)

20 Sept 2016 · Jobs and Growth Agenda

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

20 Sept 2016 · Data flows in trade agreements

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and DIGITALEUROPE

20 Sept 2016 · Data, privacy, copyright

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska)

19 Sept 2016 · introductory meeting on DSM, data flows and state aid/tax issues

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE

8 Apr 2016 · platforms, DSM

Meeting with Kevin O'Connell (Cabinet of Commissioner Věra Jourová)

8 Apr 2016 · EU US Privacy Shield

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

29 Jan 2016 · Safe Harbour

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE

29 Jan 2016 · data protection

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Vivian Loonela (Cabinet of Vice-President Andrus Ansip)

28 Jan 2016 · Safe Harbour and transatlantic data flow

Meeting with Michael Hager (Digital Economy) and DIGITALEUROPE

15 Sept 2015 · DSM

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and DIGITALEUROPE

24 Jun 2015 · TTIP negotiations

Meeting with Günther Oettinger (Commissioner) and DIGITALEUROPE

22 Jun 2015 · DSM