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Logitech

Logitech is a Swiss-American multinational manufacturer of computer peripherals and software (e.g.

Lobbying Activity

Meeting with Jessica Polfjärd (Member of the European Parliament)

20 Nov 2025 · Circular Economy

Meeting with Aurel Ciobanu-Dordea (Director Environment)

20 Nov 2025 · Exchange of views on the call for applications for derogations to Article 11 of the Batteries Regulation

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Weber Shandwick

19 Nov 2025 · Opportunities and challenges of ecodesign requirements

Meeting with Olivier Micol (Head of Unit Justice and Consumers)

17 Nov 2025 · GDPR simplification

Response to Circular Economy Act

4 Nov 2025

The forthcoming Circular Economy Act presents a critical opportunity to advance Europes transition toward a sustainable, resource-resilient economy. Logitech supports the Commissions objectives and urges targeted, harmonized reforms to ensure the legislation strengthens circularity without creating new administrative burdens. Electronic Waste Management: Electronic waste is the EUs fastest-growing waste stream, with 12 million tons generated annually and limited recycling efficiency. Logitech calls for reform of the WEEE Directive within the Circular Economy Act to improve recovery of critical raw materials and reduce waste leakage. Product categorization should be modernizedaligning WEEE groups with the European Sustainable Products Regulation (ESPR)to enable tailored take-back systems and eco-modulated fees. Logitech also cautions against premature fiscal instruments such as a 2/kg levy on uncollected e-waste, which risks penalizing compliant producers and fragmenting the internal market. Producer Responsibility and Transparency: Extended Producer Responsibility systems are hindered by low transparency and inconsistent reporting. The Act should mandate Producer Responsibility Organizations (PROs) to provide detailed performance dataincluding tonnage collected, treatment efficiency, and recovery ratesto producers. EU-wide standards for PRO accountability would create a level playing field and incentivize real circular outcomes. Digital Labelling and Simplification: Current labelling rules are outdated and administratively heavy. Logitech supports a shift toward digital tools such as the Digital Product Passport (DPP) to unify product information, improve traceability, and eliminate redundant physical labels. Digitalization will simplify compliance, empower consumers, and strengthen verification and enforcement mechanisms across the EU. Regulatory Coherence Across Frameworks: The intersection of the WEEE Directive, the Batteries Regulation, and the ESPR has created duplicative obligations and inconsistent definitions. The Circular Economy Act should harmonize these frameworks by aligning terminology, reporting obligations, and treatment of refurbished and updated products. A coherent legislative architecture will reduce costs, promote innovation, and facilitate the free movement of sustainable goods within the Single Market. Critical Raw Material Retention: Europes dependence on imported critical raw materials (CRMs) jeopardizes both economic resilience and climate objectives. The Act should establish mandatory CRM recovery targets consistent with the Critical Raw Materials Act and Batteries Regulation. Priority material lists and disclosure obligations for PROs and recyclers will stimulate investment in advanced recovery technologies and reduce reliance on virgin extraction. Conclusion: The Circular Economy Act is a defining step in Europes green and digital transformation. By refining the WEEE framework, enforcing transparency in PRO operations, modernizing product information through digital tools, aligning environmental legislation, and setting ambitious CRM recovery targets, the EU can accelerate circular innovation and strengthen resource sovereignty. Logitech stands ready to collaborate with policymakers to ensure the Act delivers measurable sustainability gains while supporting European competitiveness. Note: Detailed recommendations and supporting evidence are provided in the attached full submission.
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Response to Digital package – digital omnibus

14 Oct 2025

Logitech welcomes the European Commissions Digital Omnibus initiative, particularly to streamline and align digital regulations across the EU. We welcome this effort to reduce complexity, enhance legal clarity, and foster innovationparticularly in areas such as cybersecurity, data governance, and artificial intelligence. As a global leader in computer peripherals and software, we are committed to ensure that Logitechs products have the highest possible cybersecurity and privacy standards. We welcome the adoption of the Cyber Resilience Act (CRA), which represents a major advancement in strengthening cybersecurity standards and harmonizing the EUs digital regulatory landscape. In this regard, we would appreciate further clarification from the Commission regarding the relationship between the CRA and the Radio Equipment Directive (RED). With the cybersecurity requirements under RED having entered into force two months ago, our teams have already undertaken significant work, particularly in relation to recent product launches. The transition period remains uncertain, especially as CRA reporting obligations will begin in 2026, while RED is not set to be formally repealed until December 2027. Clear guidance on how these frameworks will coexist during this interim phase is essential to avoid duplication and ensure legal certainty for manufacturers. The Digital Omnibus offers a timely opportunity to clarify how the CRA will ultimately supersede the cybersecurity provisions of REDand potentially other overlapping regulations. Similarly, we believe the Digital Omnibus should also address the interaction between RED and the AI Act, particularly where AI-enabled products fall under both regulatory regimes. The AI Act introduces specific cybersecurity and risk management requirements for AI systems, which may overlap with obligations under RED and CRA. Therefore, we would appreciate clear alignment in definitions, scopes, and technical requirements to ensure timely compliance. Harmonizing technical descriptions and obligations across these instruments would greatly improve predictability and reduce administrative burden for manufacturers. Furthermore, we strongly recommend the Commission to tackle the critical issue of technical alignment across legislation. Diverging definitions, scopes, and product categorization criteria across EU digital laws can create confusion and inefficiencies for manufacturers. Harmonizing technical descriptions and requirementsparticularly for cybersecurity-related featureswould significantly improve regulatory predictability, facilitate compliance, and support innovation. In this regard, we have recently contributed to the Commissions public consultation on the technical description of the categories of important and critical products with digital elements listed in Annex III and IV to the CRA Logitech remains fully committed to supporting the Commission throughout the implementation process of the above mentioned files, and stands ready to contribute technical expertise and industry insights. Logitech has a strong tradition and expertise in cybersecurity and privacy of digital products. Cybersecurity is indeed embedded in our product development philosophy. We take a lifecycle-based approach, integrating robust security measures from design through end-of-life. This commitment aligns with both the CRA and the Digital Omnibuss objectives of enhancing user safety, promoting sustainability, and supporting a predictable and innovation-friendly regulatory environment.
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Response to Revision of the 'New Legislative Framework'

1 Sept 2025

Logitech welcomes and fully supports the European Commissions initiative to revise the New Legislative Framework (NLF). The framework has delivered significant harmonization across EU product legislation, but it requires urgent modernization to keep pace with market realities, sustainability imperatives, and digitalization. Logitechs comments highlight the need to close regulatory gaps, remove contradictions, and create a compliance system that is both future-proof and consistent. One of the central challenges lies in the growing misalignment between horizontal legislation. In particular, Article 11 of the Batteries Regulation (EU 2023/1542) requires all portable batteries to be user-replaceable by 2027. While well-intentioned, this mandate creates unintended consequences for compact ICT devices such as mice, keyboards, headsets, and webcams. Enabling consumer access to delicate battery systems in these products undermines durability, compromises water- and drop-resistance, reduces power efficiency, complicates recycling and remanufacturing, and raises safety concerns for untrained users. These impacts directly contradict the objectives of the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which prioritizes durability, circularity, and sustainable design. The regulatory inconsistency also risks conflict with international safety standards such as IEC/UL 62368-1 and IEC 62133. Logitech urges the Commission to use the NLF revision to resolve these contradictions. A differentiated, risk-based approach to battery replaceability is neededone that considers the specific design and performance requirements of different product categories. This approach would better align with the EUs broader sustainability goals, while maintaining safety, durability, and consumer trust. Beyond this issue, Logitech recommends that the revised NLF strengthen the coherence of EU product law, integrate digital tools such as the mandatory Digital Product Passport, modernize conformity assessment processes, align definitions across newer legislation, and improve the oversight and responsiveness of notified bodies and market surveillance authorities. These measures will ensure greater clarity for businesses, more consistent enforcement across Member States, and stronger protection against unsafe or non-compliant products. In sum, Logitech believes the revision of the NLF is a critical opportunity to reduce legal uncertainty, reinforce consumer protection, and enable more sustainable innovation. A future-ready, digitally integrated, and coherent framework will allow companies to deliver durable, safe, and circular products while advancing the EUs broader environmental and economic objectives. The full comments are attached for consideration.
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

5 Jun 2025 · Exchange of views on ESPR and recommendations for Ecodesign

Meeting with Sergey Lagodinsky (Member of the European Parliament)

3 Jun 2025 · Exchange of Views

Meeting with Michael Mcnamara (Member of the European Parliament) and Atlassian

2 Jun 2025 · AI Act

Response to Update of EU rules on radio equipment for reconfigurable radio systems

27 May 2025

Logitech welcomes the Commissions initiative to ensure continued compliance of radio equipment throughout its lifecycle. We support efforts that uphold safety, prevent harmful interference, and strengthen the Single Marketparticularly where they align with environmental goals like extending device life and reducing electronic waste. However, we caution against introducing rigid regulatory frameworks prematurely. The risks posed by software updates to radio compliance are acknowledged, but the current assessment remains incomplete. Until the Commissions ongoing study is finalized, we recommend a proportionate, flexible, and evidence-based approach. We support both: Option 1: Industry self-regulation Option 2: A delegated act under Article 4 of the Radio Equipment Directive (RED) We believe these options can be complementary, provided that Option 2 avoids unnecessary burdens and reflects the technical realities of software development. Below are our specific recommendations for implementing Option 2 in a balanced and practical way: 1. Scope Limitation Based on Radio Impact Not all firmware updates affect radio frequency, power, or other parameters relevant to RED compliance. Updates limited to UI enhancements, bug fixes, or security patches should not trigger full compliance procedures. We propose that regulatory obligations apply only when updates materially impact radio behavior. 2. Self-Declarations for Non-Radio Updates Manufacturers should be allowed to self-certify software updates that do not alter radio characteristics. This would streamline compliance, preserve accountability, and avoid overburdening both companies and regulators. 3. Development of Practical Implementation Tools We support the creation of: A centralized public database of compliant software-radio configurations A standardized declaration of conformity template Clear technical guidance on what constitutes a radio-relevant software change 4. Complementarity with Industry Self-Regulation A Memorandum of Understanding among industry stakeholders could support the implementation of Option 2 by promoting best practices, transparency, and coordination. This dual-track approach would help accommodate the wide variety of update types across the ecosystem. Conclusion: Logitech appreciates the opportunity to contribute to this early-stage consultation. We support the Commissions goals and encourage a framework that safeguards compliance without stifling innovation or imposing disproportionate burdens. We remain committed to engaging further and contributing to the development of pragmatic tools to support these objectives.
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Response to Technical description of important and critical products with digital elements

17 Apr 2025

Logitech welcomes the Commissions proposal for the Cyber Resilience Act (CRA) and supports its goal to enhance cybersecurity across the EU. As a leading global manufacturer of digital products, we strongly support risk-based, horizontal requirements to improve consumer trust, product security, and industry accountability. We particularly endorse integrating cybersecurity into the CE marking, a familiar and trusted signal to EU consumers. This will help make security a visible, accessible feature of purchasing decisions. Logitech designs products with security embedded throughout the lifecycle. Our Product Security Review Board (PSRB) conducts rigorous internal reviews before product launch. We engage external researchers via our HackerOne program to ensure ongoing resilience, and we integrate protections such as encryption, authentication, and secure update mechanisms. We appreciate the opportunity to comment on Annexes III and IV. We recommend: Focusing Important Product classification on high-risk use cases. For example, wireless peripherals (e.g. keyboards, mice) using standardized low-power protocols should not be scoped in unless they impact system control or data integrity. Clarifying that only dedicated password managers fall under credential storage provisions, not incidental storage functions. Aligning CRA and existing EU frameworks (e.g., RED-D, AI Act) to ensure proportionality and legal clarity. We also urge the Commission to provide implementation guidance and ensure transition timelines align with product development cycles. Logitech remains committed to working with EU institutions to promote a secure and sustainable digital ecosystem. Contact: Tom Tarantino, Global Head of Public Policy (ttarantino@logitech.com)
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Response to Evaluation of the Public Procurement Directives

4 Mar 2025

Logitech sees the upcoming review of the Public Procurement Directives as yet another opportunity to promote responsible sustainable consumption in Europe. Accounting for around 14% of GDP in the EU, public procurement is an important force which can influence market trends and can promote the uptake of green and innovative technologies and products and support the twin transition, while also supporting sustainable industries. Article 67 in the Public Procurement Directive provides for contracting authorities to base the award of public contracts on the most economically advantageous tender. Public authorities may assess tenders on the basis of other criteria, which may include the best price-quality ratio and other criteria such as social, environmental and innovative characteristics. This provision is not sufficient to encourage uptake of sustainable technologies and products, and more can be done to stimulate demand for such products. Logitech echoes Mario Draghis recommendation in his report on the future of European competitiveness, to stimulate demand for green products by introducing standardised low-carbon and environmental sustainability criteria for public procurement. To ensure harmonisation of rules and alignment with different pieces of EU legislation, Logitech urges the Commission to align the Public Procurement Directives with the Green Public Procurement provisions in the Ecodesign for Sustainable Products Regulation. Article 65 of the ESPR empowers the European Commission to introduce mandatory Green Public Procurement (GPP) criteria for EU public authorities when purchasing products covered by the ESPR. These criteria, established through delegated acts and aligned with the Public Procurement Directives, will specify technical standards, award criteria, performance requirements, and ambitious targets. They will focus on promoting the highest environmental performance standards for relevant product groups. Incorporating Green Public Procurement (GPP) criteria, as mandated by the ESPR, into the Public Procurement Directive would effectively promote the uptake of sustainable products in public procurement and would require public authorities to prioritize environmental sustainability in their procurement processes. This would also create a predictable legislative framework for the benefit of companies and citizens across the EU, avoiding unnecessary complexities and uncertainties of which rules take precedence. Moreover, it is central that the revised directives safeguard, or increase, competition in public bidding, ensuring equal treatment of bidders from different countries and safeguarding market access of companies from non-EU countries. Logitech acknowledges the Commissions ambition to introduce a European preference in public procurement for certain strategic sectors, as recommended in the Draghi report and specified in the Competitiveness Compass. At the same time, it is important that this logic is not applied to additional sectors that do not compromise the EUs strategic autonomy and resilience. In general, competition must be safeguarded, and the benefits of non-EU companies to higher innovation and sustainability standards in public and private markets should be acknowledged. The EU should take advantage of its partnerships with trusted partners to reinforce its resilience, to ensure public contracts are awarded to the companies that provide the most sustainable and innovative products and services, alongside price criteria. We urge the Commission to ensure a balanced approach that ensures that non-EU European companies can contribute equally to setting high sustainability and innovation standards in private and public markets alike.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager) and Weber Shandwick

18 Apr 2024 · Ecodesign for Sustainable Products Regulation, the Green Claims Directive, and the Right to Repair Directive, EU Batteries Regulation,

Response to Environmental claims based on environmental footprint methods

28 Jun 2023

The Commissions initiative to reduce greenwashing by mandating the substantiation of voluntary green claims (the Green Claims Directive) is a fundamental piece to empower consumers by ensuring that the products environmental information they receive is accurate and transparent. As a leading company in the design for sustainability space, Logitech supports the Commissions ambition to empower consumers to make informed decisions based on their real-world impact, through the substantiated communication on green claims. We fully support ambitious legislation at EU level on sustainable product design, product circularity, consumer transparency and green claims verification. We call on EU legislators to adopt even more ambitious policies to extend consumers product experience with sustainable designs and transparent communication of the products environmental impact, aspects and performance. Logitech particularly believes that by being open and transparent about the products carbon impact, such as through a product carbon footprint label, consumers are better informed to make purchasing decisions that match their environmental actions and ambitions. Logitech further calls upon the EU to set methodologies for the substantiation and communication requirements of claims appropriate and relevant to specific product categories. This will allow the EU, industry and consumers to visualize their respective impact and meaningfully inform policies and consumer choice based on the individual products they purchase. While horizontal measures have the potential to improve transparency, Logitech cautions against relying heavily on a one-size-fits-all approach to horizontal measures covering several product groups, as product materials, specifications and improvements differ per product. Logitech commends the Commission for its approach on substantiation of claims. The proposal allows for clear validation methodologies and advocates for strong substantiation and communication requirements across Europe. Logitech also believes that different internationally recognized methods should be allowed alongside PEF, as put forward by the Commission in its proposal. Logitech supports that green claims should be substantiated based on verifiable third-party standards. To further empower consumer choice and reliability on sustainability claims, Logitech communicates the products carbon footprint visibly to consumers ahead of purchase, on the product packaging, and shares the calculation methodology and protocol applied (to meet ISO 14067 and ISO 14026 standards and relevant Product Category Rules), which are publicly accessible on our website. Logitech welcomes the proposals Article 3 on carbon offsetting. We agree that greenhouse gas emissions offsets should be transparently reported, and claims should specify whether those offsets relate to emission reductions or removals, while offsetting claims should be of high integrity and accounted for correctly. This will allow economic actors to minimize their carbon footprint using the best technology available and fully transition to climate-neutral operations. Additionally, offsetting claims should be verifiable by third parties to ensure the high integrity of calculations. Adding third-party verification of such claims contributes to more accountability and trust in the green transition. We were the first consumer electronics company to commit to carbon labeling of all our products. To support the integrity of carbon calculations, we worked with iPoint Group to develop our calculation methodology and DEKRA to independently verify our Product Carbon Footprints. Logitech hopes to further work with the EU institutions to elevate the Directives ambition, and to galvanize an industry-wide shift to carbon labeling by opening up our carbon impact methodology for others in the tech sector to use. For any questions, contact our Global Head of Public Policy Tom Tarantino (ttarantino@logitech.com).
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Response to Promoting sustainability in consumer after-sales

23 May 2023

Logitech welcomes the European Commissions initiative to facilitate and make the repair of goods more cost-effective for consumers. We welcome the EUs efforts to further incentivize the demand for repair and boost circular business models. The Right to Repair obligations should be interpreted under durable and sustainable product design principles. Under the current Right to Repair proposal, however, the obligation of replaceability of parts that affect the original product design could drive up instead of dropping products carbon footprints, i.e. by undermining durable and sustainable product design. As a company that designs its products for sustainability, implementing the replaceability obligations for parts such as batteries could significantly harm its sustainable design and increase its life cycle carbon footprint. Therefore, Logitech calls on the Commission to bring further alignment between the desired impacts on sustainability and circularity between the Right to Repair proposal, the newly proposed Ecodesign rules and the Batteries Regulation. As a company that has been significantly investing and benefiting from a circular business model, offering an effective right to repair to consumers is at the core of our strategy. For instance, we launched in May 2023 a partnership with global repair community iFixit to facilitate the availability of spare parts, support beyond-warranty repair on select products, and develop relevant repair guides to support this strategy. For more information see: https://ir.logitech.com/press-releases/press-release- details/2023/Logitech-Partners-with-iFixit-to-Advance-Circularity-Goals/ We fully endorse ambitious legislation at the EU level on sustainable product design, product circularity, repairability, consumer transparency and green claims verification. In fact, we call on EU legislators to adopt even more ambitious policies to extend consumers product experience with durable and energy- efficient designs, and Logitech-supported repairability, including opportunities to access spare parts, battery replacements, supporting repair guides and software, and content updates to support extended life. In fact, we are developing new business models and reverse logistics capabilities to support the extended lifetime of our products, enable the refurbishment of products for resale, enable the recovery and reuse of component parts and ensure the recycling of end-of-life materials For instance, Logitech offers trade- in programs for product returns, to refurbish them to like-new condition for sale on e-commerce platforms and warranty support while exploring opportunities for component recovery and reuse. Logitech looks forward to collaborating with the EU institutions to ensure that the future Directive harnesses circular business models while also preserving durable and designed for sustainability product designs. For any questions please contact our Global Head of Public Policy Tom Tarantino (ttarantino@logitech.com)
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Meeting with Nils Torvalds (Member of the European Parliament)

12 May 2023 · ecodesign for sustainable products regulation

Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

Logitechs comments on the new product priorities for Ecodesign for Sustainable Products Logitech sees the Commissions proposal for Ecodesign for Sustainable Products Regulation (the Ecodesign Regulation) as an excellent starting point for creating a global sustainability standard, while giving consumers the information on the sustainability implications of products. In this regard, Logitech welcomes the extension of the scope of the Regulation to include new product categories. When deciding on the new product categories, Logitech invites the Commission to consider developing standards for consumer electronics. The consumer electronics sector can play an important role in the development of the ecodesign requirements, given that a record 53.6 million metric tonnes (Mt) of electronic waste was generated worldwide in 2019, up 21 per cent in just five years, according to the UNs Global E-waste Monitor 2020. The sector is committed to continuous innovation, which is manifested in the notable efforts that many brands are already making to improve the sustainability of their products. When it comes to setting appropriate requirements for the different product groups, Logitech asks the Commission to consider setting specific requirements for small consumer electronics separate from other ICT products. PCs and other large appliances have several characteristics that set them apart from computer peripherals, which means that best practices for improving sustainability are also different for these categories. In addition to well-defined product groups, the ecodesign requirements should be determined for each specific product based on real-life information, rather than based on a proxy or representative model. In Logitechs view, setting specific requirements for well-defined product groups is the most appropriate way to develop effective ecodesign requirements. While recognizing the potential of horizontal measures in improving durability, recyclability and recycled content use, Logitech would caution against relying too heavily on a harmonized or one size fits all approach to horizontal measures covering several product groups. When it comes to horizontal durability requirements, Logitech would particularly support a scoring mechanism allowing the consumer to understand the durability of the product, as well as incentivizing design for durability to achieve a higher score. Similarly, Logitech welcomes ratings for recyclability in a way that allows consumers to understand the potential for materials to be reprocessed into new products. Logitech encourages the Commission to align any requirements with existing and new recycling utilities established in Member States to support recovery and closed-loop reprocessing and reuse of materials in cooperation with industry. On post-consumer recycled (PCR) content, Logitech would welcome guidance and calculation mechanisms for the determination of such content, in order to determine the benefits of the requirements and the progress made to achieve maximum PCR. At the same time, Logitech wishes to underline that not all current materials can be included in PCR content requirements due to technological, compliance and regulatory requirements. This should also be acknowledged in determining PCR content requirements. Logitech looks forward to collaborating with the EU institutions to ensure that the future Regulation harnesses all the potential of ecodesign requirements. For any questions please contact our Global Head of Public Policy Tom Tarantino (ttarantino@logitech.com)
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