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Orgalim – Europe's Technology Industries

Orgalim

Orgalim represents Europe's technology industries, including 770,000 innovative companies in mechanical engineering, electrical engineering, electronics, ICT and metal technology.

Lobbying Activity

Meeting with Dan Nica (Member of the European Parliament, Rapporteur)

29 Jan 2026 · ECF

Meeting with Yvan Verougstraete (Member of the European Parliament, Shadow rapporteur) and European Chemical Industry Council and

27 Jan 2026 · European Competitiveness Fund

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur) and Climate Strategy

15 Jan 2026 · European Competitiveness Fund

Meeting with Elisa Roller (Director Secretariat-General) and

19 Dec 2025 · Discussion on recent and upcoming Commission initiatives

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

15 Dec 2025 · Exchange of views on the Industrial Accelerator Act (IAA) and reform of Public Procurement Directives

Meeting with Bruno Tobback (Member of the European Parliament)

15 Dec 2025 · Circular Economy Act

Orgalim seeks clearer chemical criteria for electronics in Taxonomy

4 Dec 2025
Topic — This initiative updates technical screening criteria for the EU taxonomy environmental delegated act.
Message — Orgalim requests aligning substance tracking with existing chemical laws to ensure technical feasibility. They advocate for accepting all standard electronics exemptions to avoid penalizing green technologies. Finally, they propose using industry-standard definitions for halogen-free products.12345
Why — This would provide regulatory certainty and eliminate the burden of tracking unlisted chemicals.6
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Meeting with Guillaume Roty (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

4 Dec 2025 · Revision of the standardisation Regulation

Meeting with Martine Kemp (Member of the European Parliament, Shadow rapporteur) and Metal Packaging Europe External Affairs ASBL

2 Dec 2025 · Steel Safeguards

Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur) and ANIMA CONFINDUSTRIA MECCANICA VARIA

28 Nov 2025 · Steel safeguards

European tech industries urge strategic Chips Act 2.0 for global competitiveness

27 Nov 2025
Topic — Revision of EU Chips Act to strengthen semiconductor ecosystem and value chains.
Message — Orgalim requests the EU broaden support beyond manufacturing to include materials, equipment, design, and SMEs. They call for faster funding approvals, dedicated EU budget, improved taxation and depreciation, competitive electricity prices, streamlined permits, and stronger industry participation in governance.12345
Why — This would reduce compliance costs, accelerate project timelines, and strengthen their competitive position in global semiconductor markets.678
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Response to EU Design Delegated Regulation

26 Nov 2025

Orgalim welcomes the possibility to provide feedback on this draft. The draft is generally welcome, but adjustments are needed. Please refer to the attached document for the details.
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Meeting with Kathleen Van Brempt (Member of the European Parliament)

19 Nov 2025 · Steel trade measure

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur) and Metal Packaging Europe External Affairs ASBL

17 Nov 2025 · Stålmarknaden

Meeting with Caroline Vandierendonck (Head of Unit Budget)

13 Nov 2025 · Caroline Vandierendonck met on 13.11 in Brussels with Orgalim board and members (EU technologies) to present the future MFF, at their request, with a focus on the European Competitiveness Fund and Horizon Europe.

Meeting with Ana Xavier (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 Nov 2025 · Introduction of Orgalim organisation and their activities

Meeting with Wojciech Saryusz-Wolski (Head of Unit (Ad interim) Communications Networks, Content and Technology)

7 Nov 2025 · Exchange of views on the Digital Omnibus, the Data Act, the GDPR, the AI Act with an emphasis on simplification and harmonisation of digital legislation.

Meeting with Carsten Schierenbeck (Head of Unit Research and Innovation)

6 Nov 2025 · Exchange of views on the future Horizon Europe and the importance of Advanced Manufacturing R&I

Meeting with Felicia Stoica (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

6 Nov 2025 · Upcoming proposal for the European Product Act (EPA)

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Andreas Glück (Member of the European Parliament)

28 Oct 2025 · Climate and Energy Policy / CBAM

Meeting with Hildegard Bentele (Member of the European Parliament)

16 Oct 2025 · EU Water Policy

Meeting with Arba Kokalari (Member of the European Parliament)

15 Oct 2025 · Digital simplification

Orgalim Urges EU to Simplify Complex Digital Regulatory Framework

14 Oct 2025
Topic — The European Commission is proposing a digital omnibus to simplify technology regulations.
Message — Orgalim recommends delaying AI Act requirements until technical standards are finalized and simplifying how high-risk systems are classified. They also advocate for excluding trade secrets from data-sharing rules and creating a single portal for reporting cybersecurity incidents.123
Why — The industry would see lower costs through streamlined certifications and fewer technical reporting requirements.4
Impact — Surveillance authorities lose oversight as they are barred from accessing proprietary software source code.5
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Meeting with Philippe Lamberts (Principal Adviser Inspire, Debate, Engage and Accelerate Action)

14 Oct 2025 · Keynote speech for opening of new offices in Brussels

Meeting with Vicente Hurtado Roa (Head of Unit Taxation and Customs Union) and ASOCIACIÓN ESPAÑOLA DEL ALUMINIO Y TRATAMIENTOS DE SUPERFICIE

1 Oct 2025 · Exchange between Members of the European Parliament, Commission and industry representatives on the revision of the Carbon Border Adjustment Mechanism (CBAM) and its impact on the aluminium sector.

Meeting with Sebastian Kruis (Member of the European Parliament)

1 Oct 2025 · International Trade Agreements

Meeting with Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné) and Tetra Pak Group and Food Manufacturing Technologies Europe

1 Oct 2025 · Biotechnology; PFAS; food contact materials; water resilience

Meeting with Peter Liese (Member of the European Parliament) and Volkswagen Aktiengesellschaft and Germanwatch

1 Oct 2025 · Austausch

Orgalim urges urgent simplification of flawed EU carbon rules

25 Sept 2025
Topic — Methodology for calculating embedded emissions during the CBAM definitive period.
Message — Orgalim requests unrestricted use of default emission values and less paperwork. They also demand technical rules be published early to assist business planning.12
Why — These measures would provide immediate relief from the significant administrative and financial burdens.34
Impact — Climate goals are at risk if carbon leakage is merely shifted further downstream.5
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Meeting with Niels Flemming Hansen (Member of the European Parliament, Rapporteur)

18 Sept 2025 · Small Mid-Caps

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

15 Sept 2025 · Exchange of views on practical implementation of the AI Act

Orgalim backs 90% climate target while demanding industrial competitiveness

10 Sept 2025
Topic — The initiative proposes amending the European Climate Law to include a 2040 target.
Message — Orgalim supports the 90% target to provide a predictable regulatory framework for investments. They call for a technology-neutral approach that incorporates verifiable carbon removals and international credits. Finally, they urge the Commission to reduce regulatory burdens to maintain industrial competitiveness.123
Why — A predictable framework would help attract investment and create competitive advantages globally.45
Impact — Environmental advocates lose out if carbon credits dilute investments needed for direct decarbonization.6
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Orgalim warns new steel trade measures threaten manufacturing competitiveness

18 Aug 2025
Topic — Proposed trade measures to address global steel overcapacity and industry sustainability.
Message — The organization opposes the planned trade measure and urges the Commission to refrain from its introduction. They recommend excluding partner countries and replacing country-specific quotas with global ones if the measure proceeds.123
Why — This would lower input costs and reduce administrative burdens for manufacturers.4
Impact — European steel producers would face increased competition from highly subsidized global imports.5
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Orgalim Urges Data Act Delay to Protect Tech Industry

18 Jul 2025
Topic — The European Data Union Strategy aims to streamline rules for industrial data sharing.
Message — Orgalim requests delaying the Data Act until September 2026 for technical adaptations. They also call for targeted GDPR simplification to reduce industrial data burdens.12
Why — These changes would lower compliance burdens and safeguard sensitive manufacturing know-how from competitors.3
Impact — Public authorities would face greater difficulty accessing private data for non-emergency policy objectives.4
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Meeting with Matej Tonin (Member of the European Parliament)

15 Jul 2025 · Topics on CBAM

Meeting with Pietro Fiocchi (Member of the European Parliament)

11 Jul 2025 · Tematiche ambientali

Meeting with Cristina Miranda Gozalvez (Head of Unit Trade)

9 Jul 2025 · Orgalim Trade Policy Working Group meeting

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

2 Jul 2025 · CBAM

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

1 Jul 2025 · Revision of the Standardisation Regulation

Meeting with Stéphane Séjourné (Executive Vice-President) and

30 Jun 2025 · Roundtable discussion

Orgalim urges voluntary cybersecurity certification and simplified reporting

20 Jun 2025
Topic — This consultation evaluates the EU Cybersecurity Act and ENISA’s framework for certification.
Message — Orgalim requests that cybersecurity certification schemes remain voluntary and opposes their mandatory application under recent EU laws. They propose a one-stop-shop mechanism to streamline overlapping incident reporting requirements and urge ENISA to focus on current tasks rather than expanding its mandate.1234
Why — This would reduce administrative burdens and lower compliance costs for European technology manufacturers.5
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Orgalim Urges EU to Allow Digital-Only Product Information

13 Jun 2025
Topic — The consultation explores updating EU rules to allow digital alternatives to paper-based product information.
Message — Orgalim requests an omnibus regulation to permit providing product manuals via digital links or QR codes. They argue manufacturers should choose the format based on the product and end-user needs.12
Why — Manufacturers would drastically reduce their expenses by eliminating the need for bulky paper documentation.3
Impact — Customers lacking internet access may find it harder to view essential safety and assembly instructions.4
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Orgalim Urges EU to Digitalise All Product Information Rules

13 Jun 2025
Topic — EU consultation on updating product laws to allow digital instead of paper-based information.
Message — Orgalim calls for an omnibus regulation allowing digital product information across all harmonised legislation. Manufacturers should determine the format based on the nature of the product.12
Why — Manufacturers would save billions of euros by removing the requirement for printed manuals.3
Impact — Non-professional users lacking digital tools could lose immediate access to essential safety information.4
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Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

10 Jun 2025 · Simplification

Orgalim demands simpler rules to accelerate European industrial AI

4 Jun 2025
Topic — A strategy to accelerate industrial AI adoption and boost European manufacturing competitiveness.
Message — Orgalim seeks to simplify the AI Act by removing redundant classifications and aligning rules with existing machinery safety laws. They also request delaying enforcement until technical standards are fully finalized.12
Why — Reducing regulatory overlap would significantly lower compliance costs and administrative burdens for manufacturers.3
Impact — Market surveillance authorities would lose power to inspect software source code during oversight activities.4
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Meeting with Sophie Mueller (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs), Pauline Weinzierl (Head of Unit Trade)

3 Jun 2025 · EU-US relationships

Meeting with Christian Ehler (Member of the European Parliament)

2 Jun 2025 · CBAM

Orgalim urges self-regulation for radio equipment software updates

27 May 2025
Topic — This initiative updates EU rules regarding radio equipment software and hardware compliance.
Message — Orgalim supports industry self-regulation and non-legislative guidance for device compliance. They argue that most software updates do not affect essential safety requirements. New administrative burdens should be limited only to high-risk product categories.123
Why — Self-regulation would minimize administrative costs and protect the industry's competitive innovation.45
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Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

27 May 2025 · Exchange of views on CBAM and regulatory simplification

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

27 May 2025 · to follow

Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

12 May 2025 · Exchange of views on Directorate H initiatives of interest to Orgalim.

Response to Correcting act of Commission Regulation (EU) 2023/1670 laying down ecodesign requirements for smartphones and tablets

6 May 2025

Equipment falling under the scope of the ATEX Directive (2014/34/EU), also known as Ex Products, are equipment and protective systems intended for use in potentially explosive atmospheres. Ex Products are primarily designed to ensure the health and safety of users. Ex Products are found in various industries, ranging from the energy sector and foodstuff to pharmaceutical manufacturing. These products typically use standardised means and design methods, which are based on European harmonised standards, to comply with the essential health and safety requirements of the ATEX Directive (2014/34/EU). Ex Products are intended only for professional users in explosive environments. Explosion-proof applications require special safety-related requirements, some of which contradict the requirements under the Ecodesign Regulation (EU) 2023/1670 on smartphones and tablets. For example, Regulation (EU) 2023/1670 imposes, among other things, requirements for repairability (e.g. Annex II, B, point 1.1) , which are in direct contradiction to product safety requirements. In particular, certain established Types of Protection used under ATEX are often by design not repairable. One prime example being the equipment protection by encapsulation ("Ex m") as described by the harmonised standard EN 60079-18. Furthermore, this Ecodesign Regulation requires removability of parts by simple tools, or no tools at all, by laymen or generalists in in-use environments (e.g. Annex II, B, point 1.1, 5). This conflicts with the ATEX Directive that requires the use of special fasteners or special tools, by applying the state of the art described by the harmonised standard EN IEC 60079-0:2018. In addition, further ATEX equipment falls within the scope of Directive 1999/92/EC. As such employers must take all measures necessary to ensure that work equipment is suitable and safe, including consideration of the necessary skill and competence of the involved repair personnel. Consequently, imposing those Ecodesign requirements to Ex Products potentially jeopardizes the safe use of these products and, by extension, the industries relying on this equipment. Although products falling under the ATEX Directive are not intended for the consumer market, Ex products are not exempted from the Ecodesign Regulation (EU) 2023/1670 on smartphones and tablets. As a result, manufacturers will largely be unable to comply simultaneously with the Essential Health and Safety Requirements of the ATEX Directive and ecodesign requirements, leading to either unsafe products, non-compliance against ecodesign legislation or a decline in products and manufacturers in the ATEX Sector. Therefore, Orgalim suggests amending the Ecodesign Regulation (EU) 2023/1670 on smartphones and tablets to exclude products covered by ATEX Directive (2014/34/EU).
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Meeting with Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

29 Apr 2025 · Exchange of views on the Carbon Border Adjustment Mechanism (CBAM)

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

18 Apr 2025

Orgalim represents Europes technology industries, comprised of 770 000 innovative companies spanning the mechanical engineering, electrical engineering, electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector.
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Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

15 Apr 2025 · Omnibus / Taxonomy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

10 Apr 2025 · Impact of US tariffs

Meeting with Stéphane Séjourné (Executive Vice-President) and

10 Apr 2025 · Impact of US tariffs

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

31 Mar 2025 · Exchange of views on challenges for the sector

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

26 Mar 2025

Orgalim represents Europes technology industries. Our industries are global leaders in the carbon-neutral energy, electrification, alternative fuels and clean manufacturing technologies needed to achieve net-zero, and we are committed to playing our part to deliver the net-zero transformation and the green transition. We appreciate the European Commission's initiative in launching this call for stakeholder input, as well as the proposed amendments to Appendix C of the EU Taxonomy which accompanies the omnibus package for sustainability. We also welcome the Commissions recognition of the challenges industry faces in implementing this crucial legislation for private investment. In this context, Orgalim supports the EU taxonomy framework as a tool to bridge the huge investment gaps that currently exist. The EU Taxonomy Regulation (EU/2020/852), at the heart of the EUs sustainable finance agenda, can further incentivise financial flows towards economic sectors and activities in line with the climate change and environmental objectives. However, our industries have identified that Appendix C Generic criteria for do no significant harm (DNSH) to pollution prevention and control regarding use and presence of chemicals is preventing them from fully benefiting from the EU taxonomy and attracting much-needed investments to their technologies. Our members, who are REACH and RoHS compliant and provide key technologies for the green transition, are unable to achieve full alignment because of the requirements. The burden of badly designed regulation is holding back Europes high-tech manufacturing companies in their race to produce the technology solutions required for Europe to reach net zero. The main challenges of Appendix C relate to: Usability: the text is ambiguous and uses different terminology from other existing chemical regulations, leading to different scopes and conflicting interpretations. Furthermore, the lack of transparent information on substances in articles in complex and global supply chains, particularly according to paragraph f) bis, makes compliance impossible. Proportionality: the requirements of the current text are disproportionate and open the door to different assessments of whether a substance meets the criteria of Article 57 of REACH, which will be unmanageable for enforcement authorities. Different scopes: the introductory part of Appendix C states, the activity does not lead to the manufacture, placing on the market and the use of From a legal standpoint this causes confusion as the regulations and directives referred to in Appendix C have different scopes. REACH covers the use of substances, mixtures, placing on the market of substances and/or mixtures, and placing on the market of articles. RoHS only applies to the initial placing of electrical and electronic equipment on the EU market and does not cover the use of the regulated substances and mixtures in the manufacturing process. Appendix C does apply the provisions of regulations/directives referenced in the Appendix but also widens the scope of the provisions beyond the range of the referenced regulations/directives. To tackle these issues, we have gathered concrete recommendations to facilitate compliance by companies, bring clarity to auditors and allow for high quality disclosures that are comparable with the aim of making the EU taxonomy an effective decision-making tool for investors. We thank you in advance for considering the attached recommendations on how to improve the usability of Appendix C as well as other chemical-related provisions of the EU taxonomy. Including the support the amendment to paragraph d), Option 1 for paragraph f) bis and some persistent usability issues we have identified.
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

21 Mar 2025 · Clean Industrial Deal, Steel and Metals Action Plan

Response to List of net-zero technology final products and their main specific components

20 Feb 2025

Orgalim represents Europes technology industries. Our members provide the high-tech solutions that will enable a more sustainable, circular and decarbonised economy in Europe. We have welcomed the EUs ambition for the Net-Zero Industry Act (NZIA) to scale up domestic manufacturing of clean technology to boost the net-zero transition. We wish to provide our members views on the draft Implementing act on main specific components with the objective of ensuring a pragmatic approach for the assessment of the resilience criteria in public procurement contracts. Please kindly refer to the attached document for our recommendations for addition or removal on the draft list of main specific components in net zero technologies.
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Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Orgalim represents Europes technology industries. Our members provide the high-tech solutions that will enable a more sustainable, circular and decarbonised economy in Europe. We have welcomed the EUs ambition for the Net-Zero Industry Act (NZIA) to scale up domestic manufacturing of clean technology to boost the net-zero transition. General comment: The value chain approach in NZIA is of major importance to achieve the regulations objectives. Our sector supports the net zero technologies definition that encompasses final products, specific components or specific machinery primarily used for the production of those products (article 3 (1)). We strongly advise the Commission to take a holistic view on value chains when drafting the Annex on net-zero technologies primarily used components. Indeed, given the current political instability experienced in several EU Member States and the significant challenges faced by the industry in Europe, it is crucial to support the entire value chains of net-zero technologies. As an illustration, the latest Orgalim Economic & Statistics report shows second year of economic decline in 2024 with a combined downturn of 4.8% across the metal technology, electrical engineering, electronics, and ICT and mechanical engineering sectors. These technologies rely on complex and sometimes fragile value chains, especially within the European economic area. NZIA implementation should actively contribute to increasing manufacturing capacity of these value chains by qualifying a wide range of components as primarily used. Comment on net-zero technologies components: The draft list presents inconsistencies on components related to sealing (which have only been considered for hydrogen) or to pumps and valves that are particularly used in the hydropower and nuclear technologies and are specific to these sectors. The components under Transformative industrial technologies for decarbonisation » only consider technologies for the energy-intensive industry. There is a wide untapped potential in advanced manufacturing technologies that can be applied in a range of industry sectors and should feature on the list. Please kindly refer to the attached document for our detailed comments on the draft list of net-zero technologies' primarily used components.
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Meeting with Maria Guzenina (Member of the European Parliament, Shadow rapporteur) and Toy Industries of Europe

12 Feb 2025 · E-commerce

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva), Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

30 Jan 2025 · Exchange of views on EU research and innovation framework programme Horizon Europe

Meeting with Massimiliano Esposito (Head of Unit Research and Innovation)

30 Jan 2025 · Exchange of views on the Orgalim Position Paper ‘Proposals for FP10‘

Meeting with Ivars Ijabs (Member of the European Parliament)

29 Jan 2025 · Horizon Europe

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

29 Jan 2025 · Renew Europe Stakeholder Roundtable: “Elevator Pitch for Better Single Market Rules”

Meeting with Radan Kanev (Member of the European Parliament) and Siemens AG and

28 Jan 2025 · European Forum for Manufacturing Dinner- Decarbonisation through a technology neutral approach

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

22 Jan 2025 · E-commerce

Meeting with Sophie Mueller (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

16 Jan 2025 · To inform the Commission’s Standards Policy Unit about technical developments and hurdles in the work on harmonised standard.

Orgalim calls for stronger market surveillance and enforcement

14 Jan 2025
Topic — The Commission is consulting on a strategy to strengthen the single market.
Message — Orgalim demands better enforcement of existing rules rather than new administrative requirements. They propose a Chief Enforcement Officer and increased inspections in Member States.12
Why — Effective enforcement protects technology industries from unfair competition and non-compliant imported products.3
Impact — Irresponsible online operators and producers of non-compliant products will face stricter scrutiny.4
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Meeting with Elisa Roller (Director Secretariat-General)

14 Jan 2025 · Exchange of views on declining investments in Europe's technology industries

Meeting with Bernd Lange (Member of the European Parliament, Committee chair)

11 Dec 2024 · General exchange of views

Response to Digital Product Passport (DPP) service providers

9 Dec 2024

Please refer to the attached paper.
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Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

4 Dec 2024 · Public procurement

Meeting with Kathleen Van Brempt (Member of the European Parliament)

21 Oct 2024 · EU trade

Meeting with Kurt Vandenberghe (Director-General Climate Action)

26 Sept 2024 · Priorities for the coming mandate on delivering the green deal and net-zero transformation; CBAM and its competitiveness implications in downstream industries; Perspectives for a more comprehensive global climate deal; Regaining global leadership

Meeting with Tsvetelina Penkova (Member of the European Parliament) and WindEurope

25 Sept 2024 · Future priorities

Meeting with Tomas Tobé (Member of the European Parliament) and Confederation of Swedish Enterprise and Alfa Laval Corporate AB

24 Sept 2024 · Industrial and Transport Policy

Meeting with Laura Ballarín Cereza (Member of the European Parliament)

18 Sept 2024 · Industrial Policy

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

16 Sept 2024 · Digital policy

Meeting with Christian Ehler (Member of the European Parliament) and European Association of Research and Technology Organisations and

4 Sept 2024 · Implementation of Horizon Europe

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Sept 2024 · recommendations on energy and climate policies

Meeting with Eleonora Ocello (Cabinet of Commissioner Thierry Breton), Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

3 Sept 2024 · EU digital policy

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

25 Jul 2024

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering and electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of 2,835 billion, manufacturing one third of all European exports and providing 11.7 million direct jobs. The European manufacturing industry plays a pivotal role in producing a wide range of digital products which represent a significant part of the supply chain. With the increasing prevalence of cyber threats, it is imperative to strengthen cybersecurity measures, safeguard our critical infrastructures and ensure the continuity and security of operations. Orgalim is supportive of the main objectives stipulated in the revised Network and Information Systems (NIS2) Directive which aim to enhance cybersecurity requirements across Europe, including in its technology industries, and to address the growing threat of cyberattacks. The NIS2 Directive is expanding its scope to cover a broader range of sectors compared to its predecessor, the current Network and Information Security (NIS) Directive. Therefore, it is crucial to address several shortcomings in the draft implementing act on cybersecurity risk management and reporting obligations, as these can significantly impact Europes industries. We recommend to: Clarify and narrow down the criteria for classifying an incident as significant (feedback on reporting obligations). Assess the interplay between the draft implementing regulation and other existing standards, schemes and the national transposition of the NIS2 Directive (feedback on cybersecurity risk management measures). Please find our detailed feedback in attachment.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

11 Jun 2024 · New ideas for next mandate on circular economy

Response to Implementing Regulation setting out the template for the collection of data under Regulation (EU) 2023/1230

30 May 2024

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering, electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of over 2,819 billion, manufacturing one-third of all European exports and providing 11.9 million direct jobs. We welcomed the European Commissions standardised template for reporting machinery-related accident data, in accordance with Article 6 of Regulation (EU) 2023/1230 on machinery. It is our view that the purpose of Article 6 is to ensure that the categories of products listed in Annex I of the EU Regulation remain up to date. This can imply either adding or removing product categories from Annex I. Given the implication of adding or removing product categories for manufacturers in terms of third-party assessment, it is imperative that the data collected provides a clear and comprehensive picture. We therefore propose several modifications to the draft template. For further details, please refer to our attached paper.
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Meeting with Ilan De Basso (Member of the European Parliament)

16 Apr 2024 · Panelsamtal - Att bygga ett motståndskraftigt högteknologiskt Europa

Meeting with Christian Ehler (Member of the European Parliament)

15 Mar 2024 · Research policy

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

14 Mar 2024 · green industrial policy

Meeting with Valdis Dombrovskis (Executive Vice-President)

22 Feb 2024 · - Economic outlook for industries - EU-US Trade relations, TTC - Economic Security - Steel safeguard

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

4 Dec 2023 · Echanges sur le rôle de l’industrie des technologies pour faire avancer la double transition, sur son potentiel d’exportation et sur les moyens de soutenir les efforts de cette industrie, notamment en termes de standardisation

Orgalim urges EU to slash technology industry's regulatory burdens

1 Dec 2023
Topic — This initiative aims to identify and eliminate reporting requirements originating in EU legislation.
Message — Orgalim requests a reduction in overlapping rules and more coherent legislative implementation. They advocate for longer transition periods and simpler reporting criteria for mid-sized manufacturers.12
Why — Lowering these administrative requirements would reduce compliance costs and boost global manufacturing competitiveness.3
Impact — Consumers and environmental groups lose broad legal protections and detailed corporate oversight.45
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

14 Nov 2023 · Standardisation policy

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

27 Sept 2023

Regulation 1025/2012 is a core pillar of the New Approach; it is an integral part of the New Legislative Framework (NLF) and its evaluation is therefore of great importance for Orgalim. We are fully convinced that Regulation 1025/2012 is fit for purpose, and we are committed to contributing to the evaluation process and all its activities, supported by the extensive expertise of our membership on standardisation matters. On the occasion of the Call for Evidence, we wish to reiterate some key elements that shape our views on the European Standardisation System (ESS). Harmonised European Standards (hENs) play a critical role within the New Approach framework; they represent years of work and cooperation among various stakeholders to reach consensus, and they are pivotal to the effectiveness and efficiency of the New Approach. In this regard, we firmly believe that Regulation 1025/2012 remains well-suited for its intended purpose. If anything, we advocate for the strengthening of the public-private partnership, which is the foundation of the ESS and is essential for ensuring the continued success of the NLF. For this reason, we remain convinced that hENs are, and must remain, the preferred tool to provide presumption of conformity. The utilisation of common specifications or other certification schemes (such as in the European Commission proposal for the Cyber Resilience Act) should only be considered under extraordinary circumstances and be introduced consistently across new legislation. Comprehensive guidelines should establish stringent criteria, such as a thorough preliminary impact assessment and the necessary consultation and direct collaboration of industry stakeholders. As we are convinced that Regulation 1025/2012 is fit for purpose, we believe it is crucial to weigh any proposed improvements against the risks associated with altering a well-established system. In our view, rather than changing the Regulation, it is more important to have a more practicable interpretation of certain Articles, e.g. Article 10 (5), to streamline the processes in the European standardisation system Finally, we would like to emphasise that harmonised standards, despite their consensual development process, are fundamentally market-driven technical specifications representing the state of the art, which are developed and maintained by market actors. As such, they are part of a healthy competitive dynamic, which makes them more than just honorary documents. For this reason, we have concerns regarding the recently published Advocate General Opinion on the ECJ case on the free availability of standards , as it shows a lack of understanding of how the NLF system works. A court ruling following this opinion has the potential to undermine the foundation of the European Standardisation System (ESS) and jeopardise the overall functionality of the NLF. We look forward to continuing to contribute to the evaluation and to an effective and efficient ESS.
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Response to Evaluation of the European Union Agency for Cybersecurity (ENISA) and the European Cybersecurity Certification Framework

15 Sept 2023

Orgalim is supportive of the main objectives stipulated by the entry into force of the Cybersecurity Act (CSA), notably the permanent establishment of ENISA as the EU cybersecurity agency, and we also see the benefit of having a European cybersecurity certification framework as a way to harmonise cybersecurity certification in Europe. However, as the evaluation deadline of 2024 approaches, we see a number of shortcomings in the CSA: Delays in the publication of the Union Rolling Work Programme (URWP) while long promised, it is still uncertain when the URWP will be presented. This leaves the industry without any transparency or sense of which future schemes are coming, and when. The Stakeholder Cybersecurity Certification Groups (SCCG) role despite the fact that the SCCG should have an advisory function, we regret that it offers very little insight into the development of the schemes, a process which remains opaque. It seems that this group has been reduced to a disclosure group informing of the development stage at which the schemes find themselves, but offering little information on their content while the valuable technical expertise available within the group remains deliberately unexploited. Voluntary vs. Mandatory use of CSA schemes in our understanding, the CSA schemes were established with the intention of being voluntary. However, we see this voluntary use being limited through NIS2, while in the Cyber Resilience Act, they are mandatorily required for the categories of highly critical products with digital elements. We are against such mandatory use of the CSA schemes as a way to demonstrate conformity. The role of ENISA with the increasing amount of cybersecurity legislation, ENISAs role is essential in guiding, supporting and coordinating, especially regarding the responsibilities given to it under the NIS2 and the Cyber Resilience Act. Please find attached a detailed overview of our feedback to the European Commissions consultation.
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Orgalim Demands Maximum EU Harmonization for Environmental Product Claims

20 Jul 2023
Topic — The consultation addresses a proposed Directive on substantiating and communicating explicit environmental claims.
Message — The group supports common criteria against greenwashing but requests a Regulation to ensure uniform implementation. They urge the Commission to avoid double regulation and simplify documentation requirements.123
Why — Maximum harmonization would reduce compliance costs and prevent legal fragmentation across the internal market.45
Impact — Private labeling schemes face new restrictions that could stifle innovation in emerging sustainability areas.6
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

5 Jul 2023 · standardisation

Response to European Critical Raw Materials Act

27 Jun 2023

Orgalim represents Europes technology industries, comprised of 770,000 innovative companies spanning the mechanical engineering, electrical engineering and electronics, ICT and metal technology branches. Together they represent the EUs largest manufacturing sector, generating annual turnover of 2,906 billion, manufacturing one-third of all European exports and providing 11.19 million direct jobs. Our industries need unfettered access to raw materials in order to continue to provide the clean technologies that can support Europes net zero ambition. While we believe that the ECRMA is a step in the right direction, we would like to raise specific issues concerning some key provisions of the ECRMA, to ensure that this important piece of legislation fully achieves its objectives. Our recommendations can be found in the position paper attached.
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Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

20 Jun 2023

Orgalim, Europes Technology Industries, welcomes the opportunity to contribute to the consultation regarding the amendment of the RED Delegated Regulation on article 3.3 (d,e,f). We fully support the concrete proposal to extend the date of applicability of this RED Delegated Act, by 12 months. The impacted manufacturers must be given sufficient time to redesign their products in accordance with the harmonised standards and complete the necessary conformity assessment procedure before the Delegated Act becomes applicable. We believe that it is important for the proposed extension of the implementation date to be aligned with a revised standardisation request giving the necessary additional time for the development and delivery of the relevant harmonised standards, to ensure that the implementation period is safeguarded after the harmonised standards have been adopted and cited.
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Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and

14 Jun 2023 · EU Green Deal Industrial Plan

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

14 Jun 2023 · economic security, competitiveness, data sharing

Meeting with Tsvetelina Penkova (Member of the European Parliament, Shadow rapporteur)

5 Jun 2023 · Meeting with Orgalim on NZIA

Response to Promoting sustainability in consumer after-sales

25 May 2023

Orgalim represents Europes technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. Europes technology industries welcome the proposal from the European Commission for a Directive laying down common rules promoting the repair of goods purchased by consumers with a view to contributing to the proper functioning of the internal market, while providing for a high level of consumer and environmental protection. This paper sets out our views and concrete recommendations on this new proposal. What we support: That this proposal for a Directive will make it easier and more cost-effective for consumers to repair as opposed to replace goods. The ambition of the proposal to increase the knowledge of consumers and to facilitate their access to repair. The objective of the proposal contributing to the proper functioning of the internal market and the proposed maximum level harmonisation Directive. The scope, and that the proposed Directive will cover finished consumer goods. That the European Repair Information Form will provide standardised and harmonised key information on the conditions and price of the repair service. However, we also have several concerns. The proposed online platform for repair and goods subject to refurbishment. The development of a voluntary European quality standard for repair services. What concerns us: Different national initiatives adopted by various Member States to promote the repair of goods because they fragment the internal market. Overlaps, duplication of efforts and double regulation between the three different initiatives from the Commission which together will jointly deliver on the right to repair; the proposal for Ecodesign for Sustainable Products Regulation (ESPR), the proposal on empowering consumers for the green transition and this new proposal for a Directive on common rules promoting the repair of goods. New rules promoting the repair of goods which are not aligned with the New Legislative Framework (NLF). Not enough time for economic operators to adapt to the new rules. The unnecessary burden created by the proposed European Repair Information Form and the fact that some of the required information may be difficult to provide for this Form as well as for the proposed online platform for repair and goods subject to refurbishment. No distinction between provisions on repair within the legal guarantee period and provisions on repair beyond the legal guarantee period. See our detailed position and recommendations in our Position Paper available here https://orgalim.eu/position-papers/green-transition-orgalim-position-and-recommendations-proposal-directive-laying
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Meeting with Carsten Schierenbeck (Cabinet of Vice-President Maroš Šefčovič), Dimitri Lorenzani (Cabinet of Vice-President Maroš Šefčovič)

23 May 2023 · Exchange on Strategic Foresight and Better Regulation

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur)

23 May 2023 · Exchange of views on the AI Act

Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Orgalim represents Europes technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. To build on the success of the existing Ecodesign Directive and ensure that the Ecodesign for Sustainable Products Regulation (ESPR) will be successful in addition to protecting the competitiveness of our industries, we recommend that the following key principles are respected when developing new ESPR requirements for products: To secure the functioning of the EU internal market, requirements must be harmonised at EU level. A detailed impact assessment must always be conducted. Effective enforcement and market surveillance must be ensured. New ESPR requirements for products must follow the New Legislative Framework (NLF). Requirements must be based on scientific assessment methods through recognised European or ISO /IEC/ITU international standards and must be reliable and verifiable. Requirements should be technology-neutral. Ecodesign requirements must continue to be set on a product-by-product basis. Unnecessary and burdensome duplication of efforts and double regulation both at horizontal and product levels should be avoided and consistency with other legislation ensured. ESPR requirements should make products more circular, be meaningful, easy to understand, comparable and verifiable. The scope of the ESPR delegated acts should be limited to the product properties that are the most decisive to the environmental performance of a product/product group. More in-depth studies of potential energy savings should be conducted. The European Commission should develop a ten year ESPR Working Plan instead of the current three year plan. The industry should be involved as early and as fully as possible in the process. Economic operators should be provided with sufficient time to prepare for the implementation of new ESPR requirements to ensure legal certainty and predictability. Last but not least, start small and simple to encourage political support for further measures. Regarding end-use products, it is important that producers in the value chain of these products are aware of what kind of information and data they are expected to share through the value chain and how the data flow might work in practice. In relation to intermediate products, we welcome that data will be requested from manufacturers of these products as it will help our industries to access data from these manufacturers. However, we are critical of the proposal to regulate intermediate products under the future ESPR for the reasons explained in our position paper. We believe that horizontal product sustainability criteria will be ambitious on paper, but will not actually lead to correspondingly ambitious circular products as there is no one-size-fits-all solution. To build on the success of the Ecodesign Directive and ensure that ESPR will be successful, we strongly recommend that the Commission continues to set ecodesign requirements product-by-product to take into account individual characteristics and specificities of products. For more details, please see Orgalim Position Paper available here https://orgalim.eu/position-papers/green-transition-orgalim-comments-draft-working-plan-proposed-new-espr
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Meeting with Thierry Breton (Commissioner) and

12 May 2023 · EU-US TTC and engineering industries

Orgalim calls for practical engineering standards in EU Taxonomy

3 May 2023
Topic — Establishing technical screening criteria for sustainable activities contributing to EU environmental objectives.
Message — Orgalim requests that technical screening criteria be quantifiable, product-specific, and aligned with existing EU legislation like the Ecodesign Directive. They advocate for more flexible application of design rules and suggest lowering construction waste recycling targets to ensure they are realistic.123
Why — This would prevent unworkable design requirements and reduce engineering complexity for technology manufacturers.45
Impact — Environmental objectives for the circular economy could be weakened by lower recycling thresholds and relaxed chemical restrictions.6
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Meeting with Ilan De Basso (Member of the European Parliament)

25 Apr 2023 · Möte

Orgalim Urges Realistic Recycled Content Rules and Harmonisation

24 Apr 2023
Topic — The European Commission is revising rules on packaging waste and design.
Message — Orgalim calls for harmonised EU requirements and realistic targets for recycled content based on availability. They demand sufficient transition periods and the removal of unnecessary administrative burdens like the Declaration of Conformity.123
Why — Harmonised rules and lower administrative requirements would reduce compliance costs and prevent market fragmentation.45
Impact — National governments lose the power to implement stricter or unique local environmental labelling schemes.67
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Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

12 Apr 2023 · Revision of the Product Liability Directive

Meeting with René Repasi (Member of the European Parliament, Shadow rapporteur) and Business Software Alliance

5 Apr 2023 · Exchange of views on the Product Liability Directive/ Produkthaftungsrichtlinie (PLD) - Staff Level

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

31 Mar 2023 · preparatory/organisational meeting for a meeting with EVP Vestager

Meeting with Kurt Vandenberghe (Director-General Climate Action)

23 Mar 2023 · EU’s transition to a net-zero economy

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

10 Mar 2023 · Data Act

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

Meeting with Karen Melchior (Member of the European Parliament)

3 Feb 2023 · Request for early availability of guidance and recognizable standards in CSDDD

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

2 Feb 2023 · Single market, competitiveness

Orgalim warns of certification bottlenecks in EU cybersecurity rules

19 Jan 2023
Topic — This consultation addresses proposed cybersecurity requirements for digital products sold on the EU market.
Message — Orgalim calls for a narrower scope to include only components vulnerable to cyberattacks. They advocate reducing the list of critical products requiring third-party testing to avoid market delays.12
Why — This would prevent regulatory bottlenecks and preserve the global competitiveness of European technology manufacturers.3
Impact — European citizens may face higher security risks if fewer digital products undergo strict third-party assessments.4
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Response to European Critical Raw Materials Act

25 Nov 2022

Europes technology industries are committed to providing high-tech solutions to enable the EUs twin digital and green transitions. However, in recent years they have experienced huge challenges in accessing raw materials at competitive prices, which in the long term could impair their ability to continue to innovate and drive Europes transition towards a more sustainable economy. The future European Critical Raw Materials Act (ECRMA) will provide the opportunity and potential to secure a stable supply of critical raw materials (CRMs) for Europes technology industries. To achieve this objective, Orgalim wishes to put forward the following priorities for the ECRMA: - The EU should leverage trade policy to diversify and increase the resilience of international supply chains for CRMs, including via Free Trade Agreements and other international partnerships. Also, appropriate action should be taken to ensure that trade defence measures do not excessively hinder technology companies in accessing raw materials like steel and aluminium. - The EU should revise the existing 2020 CRMs list to include aluminium, copper, nickel and high-purity manganese. In addition, it should assess the criticality of steel and/or specific steel products. Finally, the CRM list should feature a sub-category of high-priority CRMs that are essential for the EUs twin transitions, including for example borates, cobalt, germanium, lithium, LREEs, and silicon metal. - The EU should promote a well-functioning market for secondary raw materials, primarily by boosting the development of a high-quality collection, sorting and recycling infrastructure across Europe. - The EU should take measures to incentivise and de-risk private investment in CRMs value chains. Extraction of CRMs in Europe should be facilitated, mainly by streamlining permitting procedures for CRM mining projects and by revising the relevant regulatory framework at EU level (e.g. the Habitats Directive). - The EU should avoid excessive state intervention in industrial value chains and unnecessary distortions of the single market, with measures such as binding targets for domestic production of certain CRMs or mandatory provisions on the creation/redistribution of strategic CRMs reserves. For more information, see our position paper providing recommendations on the future ECRMA in attachment.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

25 Nov 2022 · Discussion with HL executives on industrial data, financing and standardisation

Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

14 Nov 2022 · ESPR (Staff Level)

Meeting with Maria-Manuel Leitão-Marques (Member of the European Parliament, Rapporteur for opinion)

7 Nov 2022 · Chips Act

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager) and Confederation of Danish Industry

28 Oct 2022 · EU Chips Act, SMEI, Data Act.

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

17 Oct 2022 · Corporate Sustainability Due Diligence

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur) and Siemens Healthineers AG

23 Sept 2022 · Data Act

Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur for opinion) and Business Software Alliance

31 Aug 2022 · Data Act

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

31 Aug 2022 · AI Act

Response to Review of the Construction Products Regulation

12 Jul 2022

Orgalim, representing Europe’s technology industries, welcomes the opportunity to comment on the European Commission’s proposal for a Regulation on Construction Products. Within the Construction sector many of our 29 national industry associations and 19 European sector associations represent a variety of large, small and micro-industries that manufacture structural metal products, metal windows and doors, small fixing elements, fire detection systems and fire protective products, domestic heating appliances, pipes and products in contact with water and electrotechnical products such as cables. This input into the Commission’s consultation addresses key points for our industry.
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Meeting with Alin Mituța (Member of the European Parliament, Shadow rapporteur)

1 Jul 2022 · Data Act

Meeting with Ibán García Del Blanco (Member of the European Parliament, Shadow rapporteur for opinion) and Banco Santander, S.A. and

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

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur)

16 Jun 2022 · AI Act

Meeting with Ivan Štefanec (Member of the European Parliament, Rapporteur)

14 Jun 2022 · Machinery Regulation

Response to Sustainable Products Initiative

13 Jun 2022

Orgalim represents Europe’s technology industries, providing innovative technology solutions which are underpinning the twin green and digital transitions and can unlock a greener, healthier and more prosperous future for the European Union and its citizens. Our industries welcome the Ecodesign for Sustainable Products Regulation as a key measure to further optimise the way resources are used throughout the economy and society as well as bringing new business opportunities – a win-win for the environment and the economy, making the most of new digital solutions. What we support: the principles - The contribution to the circular economy, a functioning internal market, a level playing field and ensuring effective enforcement and market surveillance system - The approach and the legal framework: the Ecodesign instrument, product by product rules, harmonised EU requirements, industry involvement and harmonised standards - The potential benefits of the Digital Product Passport, economic incentives for circularity and the principle of a ban on the destruction of unsold durable goods What concerns us: how it will work in practice - Protection of confidential business data, data within the scope of the Digital Product Passport and interplay with other legislation - Duplication of efforts and double regulation, in particular for chemicals - Implementation with a disproportionate impact on the competitiveness of economic actors (third party verification, regulation of components and non-enforceable requirements) To read our position and recommendations in full, please download the attached document.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Jun 2022 · Taxonomy of environmentally sustainable economic activities

Response to Cyber Resilience Act

25 May 2022

We appreciate and welcome the initiative of the Commission to put forward its upcoming Cyber Resilience Act. Orgalim is convinced that a coherent regulatory framework is of the highest importance, especially in the context of the smooth functioning of Europe’s Single Market. On the objectives of the call: We fully support the three objectives of the call for evidence: 1.) High level of security 2.) User information 3.) And level playing field With respect to the second objective, we would nevertheless caution that information in itself, only creates value if it is of help to the recipient. Therefore, particular care should be taken in order to not overstretch information requirements. Too much information can be confusing and can lead to a waste of resources on both sides – for the creator and also the recipient. On the Policy Options In accordance with Orgalim’s longstanding position, we support a horizontal legislation for cybersecurity of products. However, neither the proposed potential options 4 nor 5 fully meet our position (for more information see the attached position paper). Concretely we support: A horizontal regulatory intervention introducing cybersecurity requirements for ‘connected products’, which are products intended to communicate by themselves over the internet, regardless of whether they communicate directly or via other equipment. With regard to the conformity assessment procedure, we strongly advocate for conformity self-assessment by default, where manufacturers and other “vendors” may opt for a notified body conformity assessment when deemed appropriate, for example in a high-risk scenario. Usually, the third party is the notified body as per the NLF. Any conformity assessment regardless of whether self-assessment or by a third party should be governed by a risk-based approach, taking into account the intended use and the nature of potential harm. Moreover, some responsibilities of hardware manufacturers and software developers after placing a product in the market may occur. But here a carefully balanced approach is needed, as those responsibilities will have limits. It is impossible to consider all future malicious threats for the manufacturer. Besides, operators or end users of a product need to be considered as well as they are ultimately accountable for a secure operation. At the end of the day, it is about shared responsibility. On the likely impact We concur with the Commission that the CRA has the potential to create an overall positive impact on all economic operators and the society as a whole. However, it must be acknowledged that 100% cyber security is factually impossible. As such, while we do not challenge the precautionary principle, we advocate to balance it against the concept of acceptable risk in order to not lose the inherent benefit/effort advantage that horizontal legislation can offer. We thank the Commission for the opportunity to express our views on this matter, and remain at your disposal should you have any questions.
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Meeting with Pilar Del Castillo Vera (Member of the European Parliament, Rapporteur) and Apple Inc. and

24 May 2022 · Data Act

Orgalim Warns EU Data Act Risks Harming Industrial Competitiveness

12 May 2022
Topic — Proposed EU Regulation on harmonised rules for fair access to and use of data.
Message — The industry calls for mandatory data sharing to be limited to clear market failures while maintaining freedom of contract as the guiding principle. They request extending exemptions to include medium-sized enterprises and lengthening the implementation period to 36 months.123
Why — These changes would protect proprietary trade secrets and significantly reduce administrative and technical compliance costs for manufacturers.45
Impact — Public bodies and third-party service providers would face more restricted access to valuable industrial data.67
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Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton)

12 May 2022 · Implementation of the EU Standardisation Strategy

Response to A New European Innovation Agenda

10 May 2022

Orgalim represents Europe’s technology industries – key players in the innovation of Europe’s economy and essential drivers of the continent’s twin green and digital transitions. This position paper is Orgalim’s contribution to the shaping of the European Innovation Agenda. Our recommendations: Easier access to finance: confronted by the massive investment challenges related to the twin transitions, availability of risk capital for technology industries is crucial. Cooperation between government and private venture capital is particularly welcome as they are complementary. The European Commission should support the participation of businesses, especially SMEs, in EU programmes, and a roadmap is needed to ensure that the target of 3% of EU GDP in R&D spending will be reached at the latest by 2025. Pro-innovation regulation: a deepened Single Market will facilitate investment growth, scaling-up of innovations and businesses throughout Europe, and will increase the chances of creating European unicorns. Avoiding extra administrative burdens, particularly for SMEs, is essential to support investment, including incremental innovations based on mature technology. Rules must be technology-neutral, flexible and ensure long-term stability and legal certainty. Regulatory sandboxes and technology infrastructures: more and better sandboxes are needed in Europe to ensure companies have the means to innovate. An EU framework for sandboxes would increase transparency for businesses and strengthen the Internal Market. The availability of technology infrastructures is crucial to test, validate and upscale new and more complex products before they can be placed on the market. Innovation ecosystems: the connections between Research & Innovation (R&I) and industrial policies should be strengthened, and innovation in advanced manufacturing should be better supported to maintain Europe’s position as a global leader, with the potential for an additional funding programme for advanced manufacturing. International collaboration: the goal of innovation policy must be to ensure EU technological leadership, to reduce strategic dependencies, and to make the European Union the leading location for the world’s best researchers, innovative companies and start-ups. This objective will require better protection of intellectual property rights (IPR) and know-how in some areas. Skilled workforce: action should be taken to provide for collaboration opportunities between businesses, research institutes and education and training institutes, and to design education and training systems which can flexibly respond to new market needs. Please refer to our attached file for additional details, available also at: https://orgalim.eu/position-papers/rd-and-innovation-orgalim-contribution-call-evidence-new-eu-innovation-agenda
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Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and ACCIS

27 Apr 2022 · Artificial Intelligence Act (AIA)

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

21 Apr 2022 · - EU-US Trade and Technology Council - Resilience of supply chains and the Single Market - Taxonomy

Meeting with Mariya Gabriel (Commissioner)

19 Oct 2021 · Low carbon tech roadmap, Industry 5.0, Innovation eco-system & Skills

Meeting with David Cormand (Member of the European Parliament, Shadow rapporteur) and The European Consumer Voice in Standardisation and

5 Oct 2021 · Machinery regulation

Response to Smartwatches and connected toys

24 Aug 2021

Orgalim - Europe’s Technology Industries, welcomes the opportunity to provide its feedback on the Draft Delegated Regulation on internet-connected radio equipment. We would particularly like to draw attention to the proposed application period in Article 3. The essential requirements of Article 3.3 are new requirements for radio equipment which need to be considered and implemented in the product planning, design and production. This process usually takes between 10 and 12 months for manufacturers. The proposed 30-month transitional period would leave an unrealistic 18-month period for the development of appropriate standards. Furthermore, European Notified Bodies report that they do not have the expertise or the capacity to perform a cybersecurity assessment, especially without any standard as a reference. Therefore, to avoid a bottleneck or even an obstruction of the EU market, including possible unnecessary costs, Orgalim asks for a longer transitional period amounting to minimum 36 months.
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Response to Revision of the Machinery Directive

16 Aug 2021

Executive summary Orgalim represents Europe’s technology industries, a dynamic and highly competitive sector that relies on European Union harmonisation legislation for its success. Orgalim also acts as an industry platform (our Machinery Task Force includes stakeholders from outside our membership) and adviser to the European Commission on the machinery topic. Our industries welcome the Commission’s proposal for a Regulation on machinery products (hereafter “the Regulation”), but also have a number of concerns. This input into the Commission’s consultation addresses key points for our industry. We welcome:  Alignment to the New Legislative Framework (NLF) and transposition into a Regulation  Digitalisation of instructions, EU Declaration of Conformity and technical documentation We call for changes on the following points:  Preserve module A for Annex I machinery manufactured in accordance with harmonised standards  Remove the misleading description “high-risk machinery” in favour of a more neutral term and better rules for the amendment of the list in Annex I  Ensure coherence between the AI and Machinery Regulations for conformity assessment  Clarify the characteristics of substantial modification  Ensure essential health and safety requirements that are technology-neutral  Remove the Commission’s power to develop technical specifications via implementing acts instead of relying on harmonised standards  Extend the use of digital formats to the declaration of incorporation and assembly instructions  Amend provisions for entry into force and the transition period
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Response to Standardisation Strategy

26 Jul 2021

Attached file
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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

Orgalim supports the facilitation of data access and use in business-to-business (B2B) and business-to-government (B2G) situations. Orgalim believes that the role of the legislator in this field should be limited only to measures that would encourage and foster B2B and B2G data sharing. Freedom of contract as the guiding principle should be at the heart of any new initiative. In addition, the intellectual property rights of companies need to be protected. Orgalim sees the untapped potential in smart contracts to facilitate automated data sharing and pooling at scale, while enforcing usage restrictions. Last but not least, we need to continue to facilitate international data transfers that are very important in an interconnected digital economy. Please find enclosed our detailed views on these topics.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Jun 2021 · Preparation of the EU industrial forum

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

8 Jun 2021 · Industrial Strategy, AI

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Orgalim appreciates the opportunity offered by the European Commission to provide its views on the draft delegated act (DA) on Article 8 of the EU Taxonomy Regulation, which further specifies disclosure obligations for companies . Orgalim supports a a closer link between financial and sustainability reporting. For companies, it is important that the reporting obligations linked to the EU Taxonomy Regulation serve as a real driver for sustainable development without creating an unnecessary administrative burden and additional costs. We outline our main concerns and recommendations in the attached paper.
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Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

Orgalim, representing Europe’s technology industries, welcomes the opportunity to comment on the Ecodesign and Energy Labelling Working Plan 2020-2024. Europe’s technology industries strongly support the Ecodesign instrument which has delivered for the consumer, the industry and the planet. To carry forward the success of the Ecodesign Directive, we recommend that the following key principles are respected when developing new sustainability requirements for products:  An impact assessment must always be conducted;  Effective enforcement and market surveillance must be secured to ensure a level playing field;  New requirements for products must follow the New Legislative Framework;  Ecodesign requirements must continue to be addressed on a product-by-product basis. There is no one-size-fits-all solution due to the huge variety of products, different types of uses of the products, etc;  The industry should be involved as early and as fully as possible in the process;  The “SMERC" principle must be applied: requirements must be Specific, Measurable, Enforceable, Relevant and not harm the industry’s Competitiveness;  Requirements must be based on scientific assessment methods through recognised European or ISO /IEC/ITU international standards;  Double regulation both at horizontal and product levels must be avoided;  Product requirements should be technology-neutral. As to the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024:  Lightweighting of products is one of the best options for effective design strategy regarding material efficiency. However, there are several limitations to lightweight design.  We support the good intention of recycled content but we have several concerns and recommendations. As long as the price of primary raw materials is significantly lower and the quality and quantities higher than that of secondary materials, we oppose a mandatory use of recycled content in products because there is no market incentive for their use. Recycled content should only focus on a few materials in the products.  As to the proposed ecological profile, data used to measure against this ecological profile must be harmonised at EU level, comparable, available, updated, verifiable and enforceable. Data may vary by product or by sector. There are still open questions about how this will work in practice. We agree that applying Annex I gives the possibility of a more flexible treatment.  Regarding durability, we support the principle of countering “planned obsolescence” on the condition that “planned obsolescence” is defined and that EU standards and guidelines are applied. The durability of a product is a complex concept. Increased product durability means conflicts with other aspects of the product. There is currently no methodology available that would allow a reliable assessment of the durability of products.  As to firmware and software, double regulation must be avoided, the definition of a software clarified, and the responsibilities of the different actors addressed.  We recommend only having information requirements for recycling activities concerning scarce materials and critical raw materials, and double regulation must be avoided. . View more details in our enclosed Position Paper on the cross-cutting aspects of the Ecodesign and Energy Labelling Working Plan 2020-2024.
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Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

31 May 2021 · EU-US relations, WTO reform

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

28 May 2021 · Digital & industrial policy, convergence of digital & physical technology, scope of high-risk AI categories in industrial settings, costs of certification (for AI under Machinery Directive, for cybersecurity under NIS2).

Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis) and Association des Constructeurs Européens d'Automobiles and

29 Apr 2021 · Steel safeguard review

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

31 Mar 2021 · - review of industry strategy - European Green Deal - follow-up to the Industry Forum

Meeting with Virginijus Sinkevičius (Commissioner) and

24 Mar 2021 · To discuss the Circular Economy Action Plan, with a focus on the Sustainable Products Initiative, and exchange views on ways to support businesses in becoming champions of circularity.

Response to Revision of the guidelines for trans-European Energy infrastructure

4 Mar 2021

Europe’s technology industries, represented by Orgalim, welcome the revision of the TEN-E regulation as an opportunity to make the regulatory framework fit for purpose. In the future, projects benefitting from a Projects of Common Interest (PCIs) status should contribute to meeting the EU’s decarbonisation objectives. Furthermore, only those projects that are fully in line with the climate neutrality goal should receive funding from the Connecting Europe Facility (CEF). To make the regulatory framework fit for purpose we have identified the following key recommendations. 1. Change the scale and scope requirements for smart grid projects and redesign the qualification criteria of cross-border impact. 2. Establish a separate category for non-regulated infrastructure which provides flexibility and storage. 3. Add a thematic area on energy system integration. 4. Set up a Union-wide distribution network development plan.
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

Orgalim, Europe’s Technology Industries, welcomes the opportunity provided by the European Commission to offer suggestions with regard to a new proposal for a Regulation for Batteries and Waste Batteries. Key messages from our industries on the new proposal for batteries, which are also relevant for any similar future legislative initiative considered within the new Sustainable Products Initiative are as follows: • Turning a Directive into a Regulation ensures harmonization, yet some parts of the proposal represent a step away from the New Legislative Framework; • Standards must be developed by standardisation committees and not by the Commission; • Reduce the number of secondary acts and involve the industry as early as possible in their development; • Duplication of labelling and information systems must be avoided; • Use of third-party verification must be proportionate, workable and contribute to circular economy; • Market surveillance to protect the EU battery industry from unfair competition and EU citizens from non-compliant products is of high importance; • Legislative fragmentation and double regulation must be avoided; • Recycling requirements should be flexible in relation to market developments; • Empower SMEs with adequate support; • Definitions in all circular economy related measures should be coherent and based on standards; • Reassess numerical targets once calculation methodologies will be available; • Rules on incorporating management system should consider different challenges.
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Feb 2021 · China - CAI, Industrial Strategy

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

29 Jan 2021

Orgalim in principle welcomes the proposal of the European Commission for a Regulation on European data governance (Data Governance Act – DGA) . Data access is essential for any successful data-driven business model. We share the Commission’s overall objective to foster the availability of data both by increasing trust and by strengthening data sharing mechanisms across the EU Member States. Orgalim strongly believes that the development of trust in data sharing will contribute to unlocking the full potential of the industrial data economy. We welcome the fact that the DGA creates a regulatory framework for the governance of special categories of public data. Increasing access to, and re-use of, public data will be important to encourage innovation and growth. This initiative also draws up rules for common European data spaces. We believe that having clearer rules will pave the way for the creation of ‘sectorial European data spaces’ and aid voluntary data sharing in different sectors and domains of public interest, while respecting IPR, data privacy and security requirements. In addition, we would like to stress that contracts in business-to-business (B2B) are crucial, and freedom of contract needs to be a foundational aspect of any European data space. Orgalim would like to put forward some amendments to Chapter III on requirements applicable to data sharing services; 1) Scope: Recital 22 of the proposal mentions that the Regulation does not cover objects and devices connected to the Internet-of-Things, which have as their main objective to ensure functionalities of the connected object or device and allow value-added services. This exemption should also be mentioned in Chapter III, together with the scope and other exemptions, to prevent legal uncertainty and additional bureaucracy for Europe’s technology industries; Respect for existing contractual arrangements; there are already many well-functioning data sharing models in the manufacturing industry that are based on contractual arrangements between companies. These mutual arrangements between companies should remain outside the scope. The required amount of trust already exists in these arrangements and needs no interference from the regulator. Therefore, we would support an additional paragraph in Article 9, clarifying that this chapter is not applicable to data sharing in the context of industry arrangements or services, especially those that are already in place. 2) The Commission also underlines the importance of dialogue with the experts to successfully implement the data governance framework. It is a timely move to propose setting up a forum for this dialogue – a European Data Innovation Board. In this context, it is crucial that industry is involved in the functioning of this structure. Moreover, we would like to see the technology industries included in the specific sectors listed in the Recital 40 and Article 26, as manufacturing is the backbone of the economy and creates around 14% of the European Union’s GDP (2019) . We propose to formulate the Recital 40 as follows: “In order to successfully implement the data governance framework, a European Data Innovation Board should be established, in the form of an expert group. The Board should consist of representatives of the Member States, the Commission and representatives of the industry, e.g., relevant data spaces and specific sectors (such as health, agriculture, manufacturing, transport and statistics) (...)”. Article 26 should also be changed accordingly. 3) Finally, we believe that the incentives to share data must be defined more clearly in the proposal in order to encourage industry to take part in the new ecosystem created by the DGA. Orgalim believes that sharing data can help address some of society’s biggest challenges, while driving innovation and productivity. We support a coordinated European approach to data governance, data access and use in the context of the European data spaces.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

28 Jan 2021 · Industrial strategy

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

26 Jan 2021 · discuss the Industrial Strategy ‘Update’ and the Industrial Forum

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

European technology manufacturers offer innovative technology solutions that hold enormous potential to help the transition to a more competitive, resource efficient economy and climate-neutral economy by 2050 – key goals of the European Green Deal. To achieve this transition, a substantial amount of financing is needed to back up greening of different sectors of the economy. In this context, Orgalim, representing Europe’s technology industries, welcomes the European Commission’s efforts in shaping the EU taxonomy legislation to help bridge the huge investment gaps that currently exist. A first delegated act on climate change sustainable activities, which will supplement the EU Taxonomy Regulation (EU/2020/852), can further incentivise financial flows towards economic sectors and activities compliant with the climate change mitigation and adaptation objectives, provided the act is properly designed. To ensure European technology leadership and innovation, we call upon the Commission when fine-tuning the first delegated act to consider a wide range of technologies as well as diversity of companies’ available resources, which makes a ‘one-size-fits-all’ approach truly challenging. The technical screening criteria set by the draft act should be flexible to accommodate different energy efficient and circular technology solutions and related maintenance and service activities, while rewarding innovation and competitiveness. More specifically, we call upon the Commission to: 1. Allow flexibility for tailor made low carbon technologies, ICT and emerging technologies 2. Consider low carbon technologies at the manufacturing phase and not only at their end-use phase 3. Include all maintenance and services activities that are required to support enabling technologies 4. Consider the higher energy efficiency impact of newly installed technologies 5. Build up policy coherence on transitional activities with key energy legislation 6. Enable further growth of hydrogen manufacturing 7. Ensure equal treatment of all types of renewable electricity generation 8. Assess further specific proposals. For more information about our recommendations, please see the attached document.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

Orgalim thanks the European Commission for the opportunity to comment on the Commission’s roadmap for the evaluation of the new legislative framework. As already indicated in our response to the Blue Guide revision, we remain convinced that the New Approach and the New Legislative Framework are the best tools to support the proper functioning of the European Single Market for Goods. Thus, we believe that changes should be made only in response to clear needs and we therefore welcome this initiative to evaluate the NLF after 10 years of application, insofar as it will identify the areas in which more clarity is needed. Bearing in mind the ultimate objective of the NLF, which is to strengthen the Single Market by applying the same rules for conformity assessment, market surveillance, CE marking, etc., we are convinced that such rules should not become too cumbersome when applied concretely. Otherwise, they will risk hindering the very goal of achieving a stronger Single Market. In addition, we would like the Commission to promote the NLF principles when developing new legislation (e.g. use of essential requirements in annex, application of harmonised standards, applications of the modules for conformity assessment etc.) as a means to facilitate companies’ compliance. While we look forward to contributing to the upcoming official consultations, we believe it is relevant for us to provide our views on certain elements that should remain key throughout the evaluation. Please find the full submission in the attached document.
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Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Nov 2020 · - Trade policy review - Industrial policy and its review - Mercosur

Response to Revision of lists of pollutants affecting surface and groundwaters

18 Nov 2020

Nowadays, only 40% of Europe’s waters are in good ecological health. Climate change, and competing water uses closely linked to population growth and insufficient water treatment, have been some of the main challenges determining the current status of Europe’s freshwaters. To alleviate these persisting environmental pressures and increase the percentage of good water quality, Orgalim, Europe’s Technology Industries, advocates for the sustainable use and management of water in Europe. European technology manufacturers offer innovative water technology solutions that hold enormous potential to help protect water quality and quantity: the main goal of the Water Framework Directive (WFD, 2000/60/EC) - the European Union (EU)’s key water legislation. Orgalim welcomes the European Commission (EC)’s recent Fitness Check of the WFD, its associated directives, and the Flood Directive, in light of progress achieved and their potential to address new societal challenges. We agree with the Fitness Check’s finding that the Directive is fit for purpose, with scope to improve. With regard to priority substances, we call upon the Commission to consider the impact of updating the list of priority substances under the EQSD to the non-deterioration and the one-out-all-out principles as well as to the overall goal of achieving good ecological status, which may become more challenging. Before updating the list, we call upon the Commission to conduct further research on possible priority substances and the combined effect of substances. For more information, please see attached our position paper on the Water Framework Directive.
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Response to Sustainable Products Initiative

16 Nov 2020

Orgalim, representing Europe's Technology Industries, welcomes the Commission’s sustainable product policy legislative initiative as a key measure to further optimise the way resources are used throughout the economy and society. Please find attached Orgalim views and recommendations on the Sustainable Products Initiative.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

28 Oct 2020

Nowadays, only 40% of Europe’s waters are in good ecological health. Climate change, and competing water uses closely linked to population growth and insufficient water treatment, have been some of the main challenges determining the current status of Europe’s freshwaters. At the same time, 80% of waste water in the world is currently discarded without sufficient cleaning and proper treatment, further impacting and posing a threat to marine and water ecosystems. To alleviate these persisting environmental pressures and increase the percentage of good water quality, Orgalim, Europe’s Technology Industries, advocates for the sustainable use and management of water in Europe. European technology manufacturers offer innovative water technology solutions that hold enormous potential to help protect water quality and quantity. Our sustainable, energy-efficient, circular and smart water technologies are fit to contribute not only to achieving the objectives of the Water Framework Directive, but also the UN Sustainable Development Agenda and the wider EU policy goals of climate neutrality and adaptation, a circular economy and a zero-polluted environment as enshrined in the European Green Deal. Please see the attached document which sets out our water related recommendations that we would like for the Commission to take into account when formulating the zero-pollution action plan for air, water and soil in 2021.
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Orgalim strongly endorses the overall policy objective of ensuring the development and uptake of trustworthy AI across the Single Market. As this inception impact assessment outlines various options, Orgalim would like to affirm its support for Option 1 of the alternative options to the baseline scenario – i.e. the option of an EU ‘soft law’, a non-legislative approach to facilitate and encourage industry-led intervention (with no EU legislative instrument). In general, Orgalim believes that, before choosing any option, existing regulation needs to be carefully analysed, potential gaps precisely formulated, and the right tools adequately proposed, based on a realistic definition of AI. For the manufacturing sector, the most important aspect to keep in mind is that AI is not a product, but a technology embedded in products (applications), which puts all concerns related to AI into another perspective. There are very diverse applications that might be deemed AI-based or AI-operated systems, ranging from a driverless car to a smart-toothbrush, a robot-companion, or a non-embedded expert system for medical diagnosis. New regulation should be introduced only where it is necessary, and where it delivers clear benefits (e.g. helps to uptake the new technologies by creating a level playing field, ensuring safety etc.), and with a reference to industry standards which reflect the state of the art. It is important for policymakers to differentiate between the varying degrees of risk linked to use of AI technologies in their different applications. Clear criteria should be established for identifying critical areas in a way that is legally certain. In Orgalim’s view, the quality of any future regulation will depend on the ability to identify a common, transparent and easily applicable understanding of ‘high-risk’. High-risk situations should be defined in cooperation with industry, based on risk-benefit considerations and adjusted when necessary. Clear definition of criteria for perceived high-risk applications and the degree of autonomy is crucial, in order to avoid over-regulation of completely harmless automation. When something has been identified as a high-risk application (which we believe will be a minority of industrial AI applications) a targeted approach to risk-management could be the right one. Taking this into account, it can for instance be concluded that most industrial AI application use cases have entirely different ethical implications compared to consumer-oriented AI solutions for end-consumers. It is crucial that the framework for identifying high-risk use cases is predictable and proportionate in order to create a stable environment for investments. From a policy-making perspective, clearly identifying the object to be regulated is essential. In the absence of a precise definition, which is currently the case for AI, the scope of any intended regulation would be uncertain, potentially being either over- or under-inclusive, and triggering litigation. Orgalim would like to highlight a definition of AI, as outlined in our previous position papers and it is similar to the definition given by the Commission’s High-Level Experts Group on AI. More detailed analysis and suggestions, especially when it comes to the safety and liability of AI, can be found in the attached Orgalim position paper.
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Response to Legislative framework for the governance of common European data spaces

31 Jul 2020

Orgalim, Europe’s technology industries see the transition to a data-driven economy as essential for their future growth and competitiveness, as well as inevitable. Our companies are developing and providing sensor-equipped machinery, data-based services, smart production systems and intelligent products. Therefore, we support the development of common European data spaces to facilitate voluntary data sharing in strategic sectors and domains of public interest, while respecting intellectual property rights (IPR) and the know-how of the companies (IPR), data privacy and security requirements. A clear governance would encourage and facilitate B2B data sharing by creating more legal certainty, including on competition law aspects, and technical feasibility, including interoperability. At the same time, political intention to create and oversee the data spaces must be backed up by sufficient funding to ensure their success. Participation in such spaces should remain voluntary, contract based, access should be non-discriminatory and open to all players after having ensured that they comply with existing EU rules. In a B2B context, liability issues related to data can be addressed by contracts that are freely negotiated by the two parties. Therefore, we ask policymakers to refrain from any specific legislation imposing opening-up of industrial and on data liability, respecting the companies’ freedom of contract. Companies need legal certainty and a trusted market environment to share, transfer and access data to enable them to innovate in new data-driven business models. To that end, trade secrets and intellectual property rights of companies shall be protected. The willingness of industry to share data on a voluntary basis could be further encouraged by platforms and data spaces offering data management models that ensure that data is shared in a fair manner, aligned with the business interest of all the stakeholders involved, in particular the most vulnerable ones, like the SMEs. Based on this, Orgalim proposes the following key elements for a European data policy framework: 1. Opening up data: freedom of contract as the guiding principle; 2. Liability. Liability issues can be addressed sufficiently by contracts freely negotiated by the two parties, within the framework of the overall negotiations about data sharing between companies; 3. Protection of data: know-how and intellectual property rights. The intellectual property rights of companies need to be protected from unauthorised access; 4. Cybersecurity. Cybersecurity is a deciding factor to increase trust in sharing data. In order to achieve a high level of cybersecurity for products, solutions and processes circulating in the single market, Europe needs a holistic approach to cybersecurity by minimizing the risk of legal fragmentation towards cybersecurity; 5. Interoperability and portability: key to unlocking data sharing in the EU. European and international standards that enable this interoperability need to serve as a basis; 6. The role of competition law. 7. Unlocking the potential of international data transfers. 8. General Data Protection Regulation (GDPR). 9. Raising awarness. Europe’s technology industries represent companies that innovate at the crossroads of digital and physical technology. As key drivers and beneficiaries of the digitalisation of industry, these industrial sectors play a leading role in the data economy. We believe that data will also have a key place in the economic recovery strategy for the EU, given its potential for innovation and job-creation, as well as its contribution to the efficiency of industries. We therefore call on the Commission to ensure that Europe’s technology industries are closely involved in the further development of clear governance framework for common European data spaces. Please see the attached position paper for more details.
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Response to Sustainable and Smart Mobility Strategy

29 Jul 2020

Orgalim stands for a future sustainable mobility system that is multimodal, climate responsive and clean, safe and efficient, interconnected and integrated, and strengthening EU global technology leadership. Achieving deep emission reductions will require a shift of mobility patterns and an integrated system approach that includes promoting: • Overall efficiency and sustainability of vehicles, fuels and infrastructure; • A switch to alternative and climate neutral fuels for transport; • Increased efficiency of the transport system by making the most of digital technologies: smart charging, smart pricing, smart traffic management systems or further encouraging multi-modal integration and shifts towards more sustainable transport modes all have a role to play; • Smart and sustainable sector integration (between buildings, energy, transport in ever more smart cities), for which digitalisation will be an important enabler and accelerator; • A timely and full implementation of the clean energy package. The EU Strategy for a Sustainable and Smart Mobility should include the following elements: • Promote smart sector integration (building, energy, transport, digital) and synergies between these sectors to enable innovations, such as smart charging, vehicle-to-grid services, and include smart features such as the European Railway Traffic Management System (ERTM). • Strive for a combination of decarbonised, decentralised and digitalised power, more efficient and sustainable batteries, highly efficient electric powertrains, connectivity, autonomous driving and electrification of harbours, short sea shipping and inland waterways. • Swiftly implement article 8 of the amended Directive 2018/844 (EPBD) regarding the installation of recharging points and ducting infrastructure in buildings and facilitate the deployment of smart charging from the outset. • Set in place clear requirements and measurable targets during the upcoming review of Directive 2014/94/EU on the deployment of alternative fuels infrastructure to enhance the use of alternative fuels: in particular, set recommendations on the level of deployment of smart charging and power-to-x technologies and require this information to be included in National Policy Frameworks during the review. Progress reports on the implementation of Directive 2014/94 should also be included under the new Governance of the Energy Union. • Support the acceleration of the deployment of alternative fuels infrastructure in the future EU Multiannual Financial Framework and other investment tools. • Complete the Trans-European core network (TEN-T) by 2030 and the comprehensive network by 2050. • Set an EU raw material policy that ensures easy and fair access to competitive, affordable and quality raw materials (primary and secondary) that satisfy technological needs and safety, that pursues a “proactive international cooperation strategy” and smooth trade relationships and associates the definition of critical raw materials not only with high economic importance and high supply risk, but with resource efficiency efforts in the broadest sense (i.e.: more support for energy and resource management solutions). • Make use of the EU’s energy taxation framework to incentivise the uptake of innovative technologies: the Energy Taxation Directive should be revised and aligned with EU energy and climate directives. It should reflect carbon content. • Set in place an EU data framework that ensures both fair access to data (“data sharing”) and fair protection of data (“data privacy”) in the Business-to-Business sector as much as in the Business-to-Consumer sphere. • Set the first specifications for the short-term deployment of the “Day1 C-ITS services” through article 7 of the ITS Directive 2010/40/EU.
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Response to Revision of the Urban Wastewater Treatment Directive

23 Jul 2020

Orgalim, representing Europe's Technology Industries, calls upon EU policy makers to revise the Urban Waste Water Treatment Directive in a such way as to: • Bring circularity into wastewater by elevating resource efficiency ambition; • Boost energy efficiency in the wastewater sector to contribute accomplishing climate neutrality goal by 2050; • Mainstream digitalisation in the wastewater sector; • Address storm water overflows and urban run-off; • Deal with new contaminants, namely pharmaceuticals, both at the source and the wastewater plants level; • Incentivise full cost recovery of wastewater treatment in accordance with Article 9 of the Water Framework Directive; • Extend the scope to small agglomerations and non-connected dwellings; • Help bridging the existing EUR 253 billion finance need and step up 2021-2027 EU financing; • Benchmark wastewater sector service in the EU, as a follow up measure; • Build up policy coherence. For more details please see "Orgalim’s recommendations for the revision of the Urban Waste Water Treatment Directive" available at: https://www.orgalim.eu/position-papers/environment-wastewater-matters-too-orgalims-recommendations-revision-urban-waste
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

Europe’s technology industries, represented by Orgalim, welcome the revision of the TEN-E regulation as an opportunity to make the regulatory framework fit for purpose to support the ongoing fundamental clean energy and digital transformations. The TEN-E regulation sets the infrastructure priorities for the EU via the identification of Projects of Common Interest (PCIs), but it does not consider the Paris Agreement, the Clean Energy Package and EU 2050 climate neutrality strategy - significant political and policy developments that have happened since its adoption. The TEN-E regulation mainly focuses on transmission projects, which are necessary but do not sufficiently depict the entirety of the future energy system. Innovative electricity infrastructure is needed at both transmission and distribution level as energy transition is mainly taking place at the distribution level where 90-95% of renewable energy sources are, and most likely will continue to be, connected. However, the scale and scope requirements for smart grids in Annex IV of the TEN-E regulation make it very difficult for these projects to be eligible. This is well illustrated by the fourth PCI list which contains 149 projects, among which there are only six smart grid deployment projects, with the Smart Border Initiative project being at the distribution level – the first and only one of its kind since 2013. The Commission should identify the right legislative instrument to further promote the simultaneous deployment of more smart distribution grids, preferably through the adoption of a new distribution grid specific legislative proposal, which addresses the current shortcomings of the TEN-E regulation in this area and its insufficient focus on the combined deployment of smart grids, renewables and energy efficiency. For a successful Clean Energy Package implementation and to ensure consistency with Europe’s climate neutrality objective and the Green Deal ambition, we recommend addressing the following shortcomings of the TEN-E regulation: • Reviewing the eligibility criteria for smart grids projects: the threshold of 10kV and the current “cross border impact” criterion remain important barriers for more smart grid projects at distribution level; • Making the energy efficiency first principle a priority for the selection of PCIs; • Setting up a Union-wide distribution network development plan to complement the existing Ten-Year Network Development Plan (TYNDP) for transmission level. Such a plan should: - set out planned investments for the medium term; - focus on the infrastructure required to connect distributed generation and new loads, including recharging points for electric vehicles; - provide transparency on the flexibility services needed; - include the use of demand response, energy efficiency, and energy storage facilities as an alternative to system expansion. The revision process of the TEN-E regulation should result in support for investments in projects serving the sustainable expansion and modernisation of both transmission and distribution networks. Europe enjoys the benefits of a reliable energy infrastructure. A modern, smart, efficient and connected infrastructure is the backbone of the green and digital transformations that Europe has embarked on – and as such the TEN-E regulation revision will be essential for successfully implementing the Clean Energy Package, the Energy Union, the EU’s 2050 long-term strategy and the Paris Agreement. Europe’s technology industries stand ready to play their part.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

17 Apr 2020 · Introductory meeting requested by Orgalim to present their activities and their priorities for digital and green policy and raise issues in COVID 19 circumstances

Meeting with Christiane Kirketerp De Viron (Cabinet of Commissioner Johannes Hahn)

3 Mar 2020 · Digital strategy

Response to Evaluation of the Electromagnetic Compatibility Directive

19 Feb 2020

Orgalim represents Europe’s technology industries – innovative companies spanning the mechanical engineering, electrical engineering and electronics, and metal technology branches. Orgalim believes that the EMC Directive:  is generally fit for purpose and we see no need for modification or revision at this stage  is not a “safety directive”, meaning that the Directive is not supposed to deal with the safety of equipment  should be kept technology neutral  should not be merged with other NLF Directives (eg RED) Moreover, Orgalim opposes any change to the scope of the Directive, such as the inclusion of cables, as well as any change to the essential requirements. We strongly believe that harmonised standards are the best means for addressing existing, as well as emerging technologies, such as AI, 5G etc. The directive should continue to specify only the high-level essential requirements. Our industry values the EMCD for its legal stability and predictability. We firmly believe that any lack of clarity can be addressed in guidance documents without revising the EMC Directive.
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Meeting with Kadri Simson (Commissioner) and

3 Feb 2020 · Decentralized energy systems, sector integration, smart energy systems

Meeting with Pablo Fabregas Martinez (Cabinet of Commissioner Adina Vălean)

22 Jan 2020 · Transports

Meeting with Ditte Juul-Joergensen (Director-General Energy)

21 Jan 2020 · the role of engireering industry in the context of clean energy transition

Response to A new Circular Economy Action Plan

17 Jan 2020

-A Circular Economy supporting Europe’s Green Deal climate ambition and the implementation of the UN SDGs drives systemic change and the sustainable use of resources throughout the economy (“doing more with less”): Optimising the use of resources throughout the economy makes environmental and economic sense and contributes to climate mitigation. The co-benefits of achieving energy efficiency in a wider resource efficiency agenda should contribute to meeting the goals in a faster and cost-efficient manner. Coupled with the possibilities of digitalisation and data analysis, Circular Economy creates space for new business models and enables the optimisation of energy and resource use throughout the life cycle. It is important that concrete implementation remains open, market driven and globally connectable. -Creating the market through coherent policy objectives coupled with incentives throughout all strands of policies needs to be prioritised since retail markets do not reward for circularity today: Removing existing conflicts between EU waste, product and chemicals policy objectives and public authorities leading by example by buying sustainable products would be important first steps. The life cycle costing principle should be applied in public procurement. Carbon needs a meaningful price that creates the right market signal in a revenue neutral manner targeting high impact areas. Energy taxation should reflect carbon content and industrial symbiosis should be promoted. Further concrete actions should include the following: -Invest in modern EU energy, digital and waste management infrastructures -Substantially increase R&D and investment -Fully tap into the opportunities of digitalisation for resource efficiency: IoT, process monitoring, data capture and analytics and allied services, digital twinning, digital manufacturing, automatisation and monitoring, robotization or 3D printing, all can support Europe in “doing more with less” and becoming more circular.Uphold the Ecodesign Directive 2009/125/EC, its MEErP implementing methodology and the related Energy Labelling Regulation as the sector’s harmonised environmental product policy tool. The given criteria of “minimising life cycle impacts”, “based on scientific evidence”, “at least life cycle cost” and “setting measurable, enforceable requirements case by case” in “big savings areas” are the key criteria for continued implementation success and acceptance, including on circular economy related product parameters. Regarding PEF/OEF, please see https://www.orgalim.eu/ -Base implementation on the newly developed European horizontal material efficiency standards and develop further product specific standards -Secure on the ground market surveillance and enforcement hand in hand with any new implementation measure, especially in the area of product policy. -Apply strict landfill and recycling targets, set minimum quality criteria for secondary raw materials and complete producer responsibility with “shared responsibility obligations” for all actors in all steps of the waste management chain. Promote harmonised EU and international waste treatment standards, establish EU end of waste criteria and waste shipment rules should live up to circular economy objectives. -Align technology, financing and objective – mainstream the EU’s climate ambitions throughout the EU budget, the newly announced green financing strategy, and existing and new innovation, just transition, development and investment funds. -Fully and timely implement the Energy Performance of Buildings Directive 2018/844/EU–support technical buildings systems and further digitally enabled technologies, such as digital twinning or building information modelling for promoting sustainable buildings from a life cycle perspective. -Establish an EU raw material policy for easy, fair access to competitive, affordable and quality raw materials (primary and secondary) that satisfies technological needs and safety.
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Meeting with Yizhou Ren (Cabinet of Commissioner Margrethe Vestager)

23 Jul 2019 · Strategic value chains and competition policy

Response to Evaluation of the effectiveness and policy coherence of the guidelines for trans-European Energy infrastructure

12 Jul 2019

The industries represented by Orgalim provide innovative technologies for the generation, transmission, distribution and end use of energy and at the same time rely on continuous energy supply for its manufacturing activities in the EU, which provide innovative jobs to more than 11 million Europeans. Orgalim is particularly committed to contribute to evolving, upgrading, interconnecting and overall modernising Europe’s energy infrastructure to ensure reliable access to affordable, secure, safe and sustainable energy for all Europeans and to set a global energy technology leadership standard. We share the Commission’s view that a net-zero greenhouse gas emissions economy will be achieved only with an adequate and smart infrastructure and emphasise that innovative electricity infrastructure is needed at both, transmission and distribution level. We welcome the evaluation of the Trans-European Energy Infrastructures Regulation (TEN-E) as an opportunity to screen this existing energy infrastructure framework set in 2013 against the ongoing fundamental clean energy, climate neutrality and digital transformations. It is a welcome opportunity to assess whether the Regulation is fit for tapping into innovative, sustainable technology opportunities and whether it is compatible with the new legislation passed under the Clean Energy package and the proposed Clean Planet For All long-term climate vision. Today, the TEN-E Regulation mostly focuses on high and medium voltage transmission projects, which are necessary but do not sufficiently depict the entirety of the future energy system. Europe is heading fast towards an energy system that is significantly more complex, decentralised, digitalised and decarbonised. The energy transition is mainly taking place at the distribution level where 90-95% of renewables are being connected. The 4th list of candidate PCI projects in the thematic area of smart grids well illustrates this mismatch – there are only six candidate projects out of which only one, the Smart Border Initiative, is a smart grid project at the distribution level. In fact, it is the first project of such kind presented since 2013. The European Commission should therefore identify the right legislative instrument to further promote the simultaneous deployment of more smart distribution grids, preferably through the adoption of a new distribution grid specific legislative proposal, which addresses today’s shortcomings of the TEN-E Regulation in this area and its insufficient focus on the combined deployment of smart grids, renewables and energy efficiency. We provide our specific recommendations in the attached position paper.
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

25 Apr 2019 · EU industrial policy

Response to Smartwatches and connected toys

4 Mar 2019

As stressed in the Commission Communication on “digitising European Industry” (COM(2016)180), digitalisation has become one of the major drivers of industry’s competitiveness and innovation capacity. This is enabled namely through Internet-connected radio equipment which is increasingly incorporated in technological products such as telecommunication equipment, robotics, automation, laser and sensor technologies, electronics for automotive, household appliances, security and energy markets. In this context, Orgalim industries are committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when these are connected to the Internet, under the framework of the Radio Equipment Directive (RED). In Orgalim’s view, the resilience of Internet-connected radio equipment to cyber attacks should be addressed in a consistent way in Europe, without creating overlapping and potentially contradicting existing legislation, including the recently adopted European Cybersecurity Act* or the General Data Protection Regulation (GDPR)**. Addressing cybersecurity requirements in a Delegated Act under the RED, which essentially has to stay within the limits of privacy (Art 3.3 (e)) and fraud (Art 3.3 (f)) would be limited to a subset of products and cybersecurity requirements. <b>Therefore, we deem option ‘0’ (baseline scenario) as the most appropriate policy option under the current RED to prevent overlapping and fragmented legislative requirements on cybersecurity for internet-connected radio equipment.</b> Orgalim remains at the disposal of the European Commission to provide further details on these initial comments. Furthermore, Orgalim expresses its interest and availability to provide additional explanations and evidence during the next steps of the impact assessment, as well as in the Expert Group on Reconfigurable Radio Systems. ________________________________________ * Cybersecurity Act: https://ec.europa.eu/commission/news/cybersecurity-act-2018-dec-11_en ** Regulation (EU) 2016/679 — GDPR: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32016R0679
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Response to Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems

4 Mar 2019

As stressed in the Commission Communication on “digitising European Industry” (COM(2016)180), digitalisation has become one of the major drivers of industry’s competitiveness and innovation capacity. This is enabled namely through radio equipment which are increasingly incorporated in technological products such as telecommunication equipment, robotics, automation, laser and sensor technologies, electronics for automotive, security and energy markets. In this context, Orgalim is pleased to provide its views on the particular issue of embedded and business software, which may be installed in this equipment and products. Our industry is committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when further software updates and reconfigurations are applied to the products, under the framework of the Radio Equipment Directive (RED). In Orgalim’s view, a one-size-fits-all approach is neither realistic nor feasible. Should a delegated act be considered necessary at all, then it should respect the principles of proportionality and better regulation: Additional administrative burdens need to be carefully examined and should be deemed justified and applicable only to those product categories presenting a risk of non-compliance. The impact of such measures on innovation and competitiveness of new products and applications should be carefully examined. Therefore, we deem option ‘1’ (industry self-regulation) as the most appropriate policy option under the current RED. Orgalim remains at the disposal of the European Commission to provide further details on these initial comments. Furthermore, Orgalim expresses its interest and availability to provide additional explanations and evidence during the next steps of the impact assessment, as well as in the Expert Group on Reconfigurable Radio Systems. ________________________________________ [1] Commission Delegated Regulation on the Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems – Inception impact assessment: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=PI_COM:Ares(2019)476957
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Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

15 Feb 2019 · Politique industrielle

Response to Revision of the Machinery Directive

8 Feb 2019

Orgalim’s industries represent a wide variety of sectors in the manufacturing industries, the vast majority of which are small and medium sized enterprises for whom the Machinery Directive is the core piece of legislation. Both the recent publication of the Evaluation report on the Machinery Directive (MD) and the Communication on Artificial Intelligence (AI) respectively underline that the MD is fit for purpose and that the EU safety framework is robust enough to provide for machines embedding AI-driven functions. Nevertheless, both documents suggest some light adaptations to foster coherence with the EU legislative framework.Consequently, Orgalim does not favour Option 0 - the baseline scenario- . Orgalim supports Option 1 which would align the Directive with the NLF without bringing any change to the substance of the current legislative act. Indeed, the MD is a new approach directive which performs well thanks to both the Essential and Health Safety Requirements (EHSRs) of Annex I and the approximately 800 harmonised standards which represent the State of the Art. The alignment to the NLF would help to reduce administrative burdens for our manufacturers who need to apply the Machinery Directive in combination with other EU legislation. It would also help national authorities to simplify their market surveillance activities and improve the effectiveness of their measures. Last but not least, it would significantly reduce the number of non-compliant products on the market. Orgalim does not support Option 2 which foresees the adaptation of the scope and the definitions of the Directive as well as the EHSRs in order to address the particular issues relating to emerging digital technologies. Thanks to the EHSRs and the around 800 harmonised standards which reflect the State of the Art , our industries have already been placing machines embedding new technologies on the market for several decades without any compromise to the safety of both users and consumers. We refer the Commission to our position paper on the issue of AI versus MD for a more detailed discussion.The only sub-option in Option 2 Orgalim would support is allowing manufacturers to provide their documentation in a digital format. This specific sub-option can be integrated in the guide of interpretation to the MD without any modification to the legislation and would allow our manufacturers to reduce the administrative burden, to improve the use of the instructions to reflect the needs of digitalisation, and to remain competitive on the market.Orgalim does not support Option 3 as it entails a modification of the scope (see Option 2) without aligning to the NLF, which we consider important (see Option 1).Orgalim supports Option 4 of turning the Machinery Directive into a Regulation as this would allow a harmonised interpretation of the legal act in all Member States, avoid transposition problems in the Member States, and ultimately contribute to the completion of the internal market of goods.Given the comments expressed above, Orgalim recommends including an Option 5 in the Impact Assessment Study. This Option would incorporate the issues which help to foster the internal market and help our companies to be more competitive. This option 5 should include the following sub-options: The adaptation of the Machinery Directive 2006/42/EC to the New Legislative Framework The possibility for our companies to use digital documentationThe turning of the Machinery Directive into a Regulation. Note: Please note that our Swiss member organization SWISSMEM is – in line with the general Orgalim position – against any revision of the Machinery Directive. However, due to political reasons related to the ongoing interinstitutional framework agreement between Switzerland and the EU, SWISSMEM is further not prepared to support the ‘option 5’ presented in Orgalim’s response to the inception impact assessment. We can provide you with further information should you require
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Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and

15 Nov 2018 · Possible safeguards

Response to Restriction of hazardous substances - evaluation

12 Oct 2018

Orgalime representing the European Technology Industries welcomes the opportunity to comment on the Commission Roadmap to evaluate the performance of RoHS Directive 2011/65/EU on the restriction of certain hazardous substances in electrical and electronic equipment (EEE). Orgalime considers the framework set by the RoHS Directive for setting restrictions of the use of certain substances in EEE as generally efficient, effective, relevant and as providing EU added value. Article 6 RoHS explicitly requires consistency of the Directive with other EU legislation, and the REACH Regulation in particular, which supports coherence of legislation. Finally, the Directive has been successfully amended in 2017 to strengthen the circular economy. Therefore, the affected industry does not see the need for amending the current RoHS Directive. However, we believe that the implementation of the RoHS Directive should be significantly improved, in particular in the following respects: • Improving consistency with other EU legislation, and consistency between the RoHS Directive, REACH Regulation and Ecodesign Directive in particular • Improving the implementation of Article 5 RoHS • Better recognising the differences between B2B and B2C equipment when considering the use of RoHS as risk management option • Better taking into account aspects related to the global trade of EEE More details on these points are available in the attached Orgalime comments. In conclusion: • Orgalime sees the opportunity of improving regulatory consistency when implementing RoHS Directive. • Key implementation challenges include timely decisions on Article 5 RoHS, better recognising the differences between B2B and B2C equipment and better taking into account aspects related to the global trade of EEE. • Finally, timely decisions on filed exemption requests and sufficiently long duration periods of granted exemptions benefit the credibility of the tool and either positively or negatively impact companies’ legal and planning certainty.
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Meeting with Marie Frenay (Cabinet of Vice-President Andrus Ansip)

21 Sept 2018 · Artificial Intelligence

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Sept 2018 · Artificial Intelligence

Response to Strategy for long-term EU greenhouse gas emissions reductions

10 Aug 2018

The European Technology Industries represented by Orgalime welcome the Roadmap on a Strategy for long-term EU GHG emissions reduction in accordance with the Paris Agreement, taking into account Member States’ national plans. This indeed means preparing ourselves on time for a profound transformation of the entire global economy and society and tapping the undisputed, multiple opportunities that such a transformation holds for all of us. It also means managing the challenges arising from it in a fair, inclusive, responsible, socially acceptable and overall sustainable manner. Not acting, however, is no longer an option: the global landscape is undergoing a fundamental, rapid & irreversible change primarily due to decarbonisation, digitisation & decentralisation (“the 3D change”). The scenario of achieving net zero GHG emissions within the Union by 2050 and negative emissions thereafter and related implications on the global and EU carbon budget needs to be included to identify appropriate, cost-efficient EU implementation measures. 1. A strategic review of the 2011 EU Climate and Energy Roadmaps is needed: Living up to the Paris Agreement, implementing the mandate given by EU political leaders & the outcome of negotiations on the clean energy package, as well as accommodating new technology developments (notably their increasing maturity & cost efficiency) all mean that we need a thorough review of the EU’s existing roadmaps. Designing a long-term EU GHG emissions reduction strategy as a vision on how the EU can help creating a modern, clean & competitive economy that not only protects the planet & defends its people, but also empowers its economy & prepares us all for a future that is more electric, more sector-coupled, more resource & energy efficient, more low carbon, significantly more local but interconnected & digitally enabled. A horizontal approach of tackling GHG emissions from all parts of the economy, including buildings, transport, energy, land use/agriculture & industry sectors, should build upon technology neutrality, increased speed of implementation & stakeholder engagement. Social and skills aspects should be looked at as well as how to build an EU ecosystem that fosters EU industrial, economic and political leadership & global competitiveness. 2. Steady, long-term price signals are required to be economically efficient, to allow timely adoption of low-carbon, energy & resource efficiency technologies, often digitally enabled, and to minimise stranded assets. Carbon pricing needs to incentivise innovation and investment into innovative technologies. It also means an EU budget (MFF) that mainstreams climate financing into all areas, as is the Commission’s proposal, & modelling energy efficiency, demand response & other flexibility sources for their actual contribution. 3. The next decade 2020-2030 is critical and the EU needs to ensure that energy investments are made in support of the EU’s clean energy package as follows to avoid stranded assets: • Preparing Europe for successfully managing the coexistence of centralised & decentralised energy production. • Enabling Europeans to manage energy according to real time information with prosumers at the core and resolving pending questions regarding data handling & processing. • Organising an ecosystem with the necessary flexibility to allow this modernisation to happen in Europe. A highly energy efficient and renewables based EU energy system with smart grids at all levels is a no regret action. 4. Member States’ integrated national energy and climate plans (2030 & 2050) should set the same priorities & be the base of a strong EU governance. 5. EU Industry needs a global level playing field: Considering the current EU share of global GHG emissions & given the highly interconnected, complex global supply chains of European technology manufacturers, there needs to be a robust international level playing field, including for trade & carbon dumping.
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Response to MFF: 9th Framework Programme for Research and Innovation and Rules for Participation and Dissemination

3 Aug 2018

Orgalime is a strong supporter of the EU’s research and innovation policy and of the European Research Framework Programmes. EU policy and programmes in this area underpin the broader goal of boosting employment and economic prosperity in Europe. They significantly contribute to the competitiveness of European industry and represent a long-term investment that will benefit European society and its citizens. Without a strong and competitive industrial base in Europe, the EU will not be able to solve the global challenges we are facing. Without industrial participation, the Framework Programmes will simply not be able to achieve the targets of strengthening economic growth and innovation and increasing the impact on competitiveness as foreseen in the EU Treaty; moreover, the related growth in jobs will be hampered. With this in mind, Orgalime is making the following recommendations for the next EU Framework Programme, Horizon Europe. Please see the attached file for the detailed position paper
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Meeting with Miguel Arias Cañete (Commissioner) and European Chemical Industry Council and

8 Jun 2018 · Energy transition and the energy intensive industry

Meeting with Dominique Ristori (Director-General Energy) and European Chemical Industry Council and

8 Jun 2018 · clean energy transition

Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

Please see attached Orgalime Position Paper: "Roadmap For EU Product Policy - Creating a Market for Circularity" (4 June 2018)
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

19 Mar 2018 · Directive 85/374/EEC

Meeting with Dominique Ristori (Director-General Energy)

7 Mar 2018 · clean energy transition

Meeting with Günther Oettinger (Commissioner)

21 Feb 2018 · MFF

Meeting with Jyrki Katainen (Vice-President)

19 Jan 2018 · Research and Innovation Framework Programme 9 (FP9)

Response to Noise emission by outdoor equipment

22 Dec 2017

Orgalime, the European Engineering Industries Association, speaks for 42 trade federations representing the mechanical, electrical, electronic, metalworking & metal articles industries of 23 European countries. It covers a heterogeneous sector that manufactures equipment used outdoors like garden equipment machinery, cranes and lifting equipment, and equipment used in the construction sector. Orgalime believes that in the interest of better regulation European industry needs both a clearer and fully harmonised framework and therefore welcomes the Evaluation of the Outdoor Noise Directive (OND) within the REFIT Programme. Orgalime hopes that the comments below will be duly taken into account in the Evaluation exercise: 1. Alignment of the OND to the New Legislative Framework This alignment would grant legal certainty and guidance to manufacturers as it provides a flexible regulatory framework for the marketing of products. 2. Turn the Directive into a Regulation The adoption of a Regulation would allow a coherent application of the directive throughout the EU, would reduce the administrative burdens and interpretation in the Member States and would foster the competitiveness for our industries. 3. No extension of the Scope of the new piece of legislation Orgalime firmly believes that the scope of the directive should not be extended. Adding new equipment categories under the OND would trigger new financial burdens for the companies concerned. The Machinery Directive already addresses and defines risks related to noise emissions. On the contrary, we believe the Evaluation would be an opportunity to remove some equipment categories from the scope of the OND because they are technologically outdated and gradually disappearing from the market. 4. Enable self-certification for all categories of products In all cases, manufacturers are responsible for the conformity of their products with the OND. They have a longstanding experience in deciding whether a specific limit value is feasible or not. Therefore, manufacturers should be able to benefit from a flexible approach, enabling them to use self-certification for all product categories, which would allow them to remain competitive. 5. Replace the database by another mean to inform the end-user Orgalime believes that the noise database under the current directive has failed to reach its objectives and should be abandoned. Instead, a new mean of information of the end-user on noise limits could be set up and we are open to explore such a possibility together with the European Commission services. 6. Test Code Assessment Orgalime recommends removing all the test methods from the body of the directive and aligning them with international standards in European harmonised standards to provide flexibility in updating these test methods in line with the technological progress. 7. Effective market surveillance A more efficient and effective market surveillance system is necessary to support a better application of any new legislative requirements. Conclusion: We suggest the following answers to the proposed policy options: 1. Orgalime is against the baseline approach which would imply no change in the legislation 2. Orgalime considers that an alignment to the NLF alone, without substantial change in the current directive, is not enough to reach a better and clearer piece of legislation on equipment used outdoors. 3. Orgalime is in favour of a revision of the directive, including some changes in the substantial content with the following sub-options only: a. Adaptation of the conformity assessment procedures, according to the changes introduced in the scope and/or in the noise limits b. Adaption of the scope of the Directive, by removing specific types of equipment. c. Elimination of the requirements on collection of noise data d. Modification of the noise measurement methods/test codes, with a different regime for the standards to be used.
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Response to Evaluation of the Low Voltage Directive 2014/35/EU

27 Nov 2017

Orgalime, the European Engineering Industries Association, welcomes the possibility to comment on the European Commission’s evaluation roadmap of the Low Voltage Directive (2014/35/EU). Our industry values very much that since 1973 the core elements of LVD have remained unchanged, despite the many technological changes in the electric and electronic sector. We value the LVD for its legal stability and predictability and firmly believes that the Directive remains fit for purpose for at least the next decade; identified legal or enforcement problems, if any, can and should, therefore, be addressed without revising the LVD. Therefore, we are confident that this new evaluation exercise will provide further evidence that the LVD remains one of the most reliable pieces of Internal Market legislation, because: 1 – The LVD is ready for the challenges that may arise from the digitalisation of electrical devices and household appliances and their coexistence with the Internet of Things. The essential health and safety requirements listed in Annex I of the LVD are technology neutral and general enough to encompass any new product covered by its scope, regardless of whether the operation of the product is triggered manually or remotely, on specific request or automatically. Digital communications have been used for decades in industrial products, the signal voltages are at a very low level, typically around 5Vdc which does not itself create a hazard. Where the product safety issues could be altered by third parties after the placing of the product on the market due to after-sales, repair, renting to consumers, etc… these issues are not intrinsically linked with the Directive itself and are/can be addressed elsewhere, such as in horizontal application guides. 2 – The LVD scope is fit for placing safe electric products on the market, incl. below 50 V. Any change in the scope to include products with a voltage lower than 50V would not provide further safety and protection of consumers. The products in the so-called “Extra-Low Voltage” (ELV) range are considered harmless to touch (no electrical shock) and other residual risks could be easily mitigated by the user. Where needed, these risks are successfully covered by other EU directives such as Directive 2009/48/EC on “Toy Safety”, Annex II, Section IV Electrical Properties and harmonised standards. Besides, such a scope extension to ELV products would require a major review of the harmonised standards and conformity assessment procedures that would impact a whole industry, especially SMEs. 3 – Safeguard clauses and objections to harmonised standards are not a good reason to call for a revision of the LVD. To our knowledge, the fact that safeguard clauses against a product or formal objections to harmonised standards can and do arise are in themselves proof that the Directive works well. The issues with the four recent formal objections against LVD standards have to do with the standards themselves in relation with a specific product type (household appliance) and not with either the scope, the health and safety requirements or their links with the related conformity assessment procedures of the Directive. Nevertheless, Orgalime is somewhat surprised to learn that there were 306 notifications of safeguard clauses under the LVD in the first 6 months of 2017. Therefore, we call on the EC to disclose further information on the origin country and underlying reasons for this situation, which seems exceptional. 4 – The interface between LVD and other EU Directives does not raise any issue. We have not experienced any interpretation issues in the way the LVD interacts with other pieces of EU legislation, namely Directive 2014/53/EU on "Radio Equipment" and Directive 2006/42/EC on “Machinery”, that could not be solved in the Commission’s specific application Guidelines. Orgalime does not believe this can be sufficient reason to trigger a revision of the law, which overall works well.
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Meeting with Andrus Ansip (Vice-President) and

22 Nov 2017 · Free flow of data and open data

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

21 Nov 2017 · Digitalisation

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

20 Nov 2017 · meeting the new Director General

Meeting with Daniel Calleja Crespo (Director-General Environment)

14 Nov 2017 · Circular Economy

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

13 Nov 2017 · DSM general

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

7 Nov 2017 · Introduction of new CEO and update on economic situation and overview of main policy issues for ORGALIME

Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)

11 Oct 2017 · digitising of European manufacturing, DSM

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

12 Sept 2017 · EU industrial strategy

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

25 Jul 2017

See Orgalime's recently published position paper "Strengthening Trust and Transparency in IoT" on this issue: http://www.orgalime.org/position/orgalime-position-paper-strengthening-trust-and-transparency-iot Executive Summary: The European Engineering Industries which Orgalime represents as a whole, attach considerable importance to achieving a secure cyberspace: as an industry, mainly capital goods industry, supplying technology and systems to all other industries and economic sectors. Orgalime’s members are more and more called upon to provide solutions incorporating systems and technology increasingly reliant on digital technologies. Given the wide coverage of Orgalime’s industry, it is inevitable that a sectoral approach will need to be considered as a one-size-fits-all approach will not be appropriate. We therefore thank the European Commission for its focus on the issue and wish to provide hereafter our first input. We feel that cybersecurity is a core policy issue, best dealt with through a wide consultation of and open, coordinated conversation with all interested stakeholders. Cybersecurity is not only a crucial prerequisite for digitisation of industry. It will also be embedded in industrial value chains and business models. Orgalime therefore requests policy makers to take a comprehensive industrial policy view and abstain from hasty regulatory measures. In particular, it is of utmost importance to firstly define the requirements against which any future scheme could be tested before debating different conformity assessment methods. The cart should not be put before the horse. The industry which Orgalime represents is regulated under the New Legislative Framework (NLF). The NLF defines essential requirements and then leaves it up to companies to carry out the required risk analysis, establish technical files and perform compliance based on manufacturers’ declarations (conformity assessment module A of Decision 768/2008/EC). Internet of Things (IoT) devices and solutions will be used in multiple environments with different security requirements. In addition, cybersecurity is a moving target and any assessment can become obsolete overnight. We therefore find that in this fast-moving and heterogeneous area any rigid approach based on mandatory third party certification or labelling is inappropriate. However, Orgalime recognises the importance of EU wide transparent and comparable security product information for customers and users, especially in B2C markets. In order to increase transparency and trust, we suggest to follow two approaches: • prioritise the definition of the requirements • increase transparency of product capabilities In this context, the use of international standards, such as IEC 62443 for general purposes and ISO/AWI 21434 for road vehicles, is a promising approach to improve cyber security for engineering products. complete download: http://www.orgalime.org/position/orgalime-position-paper-strengthening-trust-and-transparency-iot
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Meeting with Dominique Ristori (Director-General Energy) and European Forum for Manufacturing

28 Feb 2017 · Clean Energy for All Europeans package

Response to Commission Implementing Regulation -information provided for in Article 10 (10) of the RED 2014/53/EU

13 Feb 2017

Answer on behalf of Adrian Harris, Director General of Orgalime, the European engineering industries association: <br> <b>Pictogram</b>: Orgalime appreciates the use of pictograms as an alternative to text. However, we believe the proposed pictogram can be further adapted. The current suggestion it is not symmetric and aligned on a vertical axis (such as similar ISO logos or the wheelie bin logo requested by the WEEE Directive): we believe this could be challenging for label designers to reproduce. If such a proposal is kept, then the Commission should ensure that the pictogram is provided on their website in high resolution and in different formats (such as what is done with the CE mark: https://ec.europa.eu/growth/single-market/ce-marking_en <br> <b>Transitional period</b>: Orgalime suggests a 12 month transitional period in the Commission Implementing Regulation under Art. 3. We believe 6 months is too short a period for companies to liquidate their stock, as items are often produced and packaged a long time in advance. Therefore, companies would need to repackage their existing stock, which is ecologically unsustainable and generates unnecessary cost, this would be especially burdensome to SMEs. <br> <b>Abbreviation EU</b>: Orgalime reiterates its call for the possibility to use the abbreviation “EU” in Annex II for products that have restrictions in all EU-Member states. For example, some frequency bands (such as 5150 – 5350 MHz for Wifi) have a restriction for indoor use in all Member States. We believe this would make it much easier for consumers to understand that the restriction applies everywhere in the EU.
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Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

10 Feb 2017 · Challenges for Industrial Competitiveness

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

6 Feb 2017 · Exchange of views on the competitive situation of the European engineering industries, digitisation, energy transition, standardisation and the Internal Market, and industrial policy.

Meeting with Daniel Calleja Crespo (Director-General Environment)

23 Jan 2017 · Waste

Meeting with Dominique Ristori (Director-General Energy)

23 Jan 2017 · Clean Energy for All Europeans Package

Response to Ecodesign requirements for electronic displays

17 Jan 2017

ORGALIME sees the need to thoroughly revisit the draft Regulation due to conflicts with Better Regulation and Directive 2009/125/EC: 1. Scope Art.1, 10 and recitals 7-16 are confusing and contradictory with each other as well as with Directive 2012/19/EU (WEEE). Art.15.4(b)ED, requires that an implementing measure can only include products that have been subject to prior assessment of the “impact on the environment, consumers and manufacturers (…) innovation, market access and costs and benefits”. This has not been the case for a vast range of products now potentially affected by the scope, notably for displays integrated into other products, such as industrial equipment, machinery, inhome displays connected to smart meters, boilers, heaters, automation and control equipment or domestic household equipment to name but a few. Also, the present wording could be understood as if displays integrated in other non-energy related products were targeted, such as means of transport, despite explicitly excluded from the ED. Therefore, article 1.5 of the draft RE should be amended by a derogation for “all displays integrated into, or intended to be integrated into other products except TVs and computer monitors”. The reference to “intended to be integrated into” is necessary to ensure fair treatment of displays placed on the market in the EU prior to their integration. Similarly, this concern arises in art. 1.4 in its present form. The term “placing on the market” in art.1.1 is not defined. The definition of art.2.4ED should apply to ensure enforceability. Art.15.4(d)ED requires appropriate stakeholder consultations when preparing an implementing measure. The present limited consultation is in our view insufficient. The inclusion of integrated monitors will be harming circular economy in the absence of an exclusion for monitors used to repair old devices. Global movement of equipment, such as spare displays recovered from equipment placed on the market outside the EU, will be negatively impacted to the detriment of repair and remanufacturing of, for example, medical or industrial equipment. Art.15.5(d)ED appears not respected. 2. Appropriateness of the suggested requirements and their compliance dates Annex II - Energy efficiency requirements: considering above mentioned scope uncertainties, their appropriateness remains uncertain, too. Annex III – Resource Efficiency Requirements: Overall, it remains unclear who holds what obligation in the case of displays integrated into other products, and therefore also if the suggested requirements would indeed translate into environmental benefits and overall qualify against art.15ED. Requiring manufacturers not to use welding or gluing techniques other than the use of double-sided adhesive tape is far too intrusive and descriptive and can, in conflict with art.15.5 (a)&(d)ED, negatively impact the functionality of the product and industry’s competitiveness. Also, harmonised WEEE treatment standards exist, that, despite Art.15.4(c)ED, are ignored. Requiring to document the sequence of dismantling operations hampers industry’s competitiveness, as knowing how to disassemble at the same time reveals IPR-sensitive information on how to assemble a product. Art.15.5(d)&(e)ED are at stake. Requiring the marking of “mercury inside” or “cadmium inside” ignores Directive 2011/65/EC (RoHS) despite art.15.4(c)ED. Annex III Information Requirements: The suggested repair and end of life documentation requirements seem ineffective such as for displays in industrial equipment. We question the enforceability of annexes II & III in the absence of standards, and their environment benefits in general considering that 80% of WEEE treatment is mechanical treatment (=shredding). Manufacturers and consumers face the risk of stranded investments. We call upon the Commission to live up to its commitment of setting measurable and enforceable requirements and thereby secure the credibility of the instrument.
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Meeting with Dominique Ristori (Director-General Energy)

23 Nov 2016 · Energy policy

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

25 Oct 2016 · industrial policy

Meeting with Günther Oettinger (Commissioner) and Siemens AG and

15 Sept 2016 · digitising european industry

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

14 Jun 2016 · DSM (especially Data Ownership and Legislatives) - DEI (especially Standardisation, Skills and Platforms) - Cyber Security

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

27 May 2016 · Circular economy

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

27 May 2016 · Circular Economy

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

23 May 2016 · circular economy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

22 Feb 2016 · Circular Economy

Meeting with Carlos Moedas (Commissioner)

22 Feb 2016 · Industry 4.0/ The role of innovation and digital

Meeting with Maroš Šefčovič (Vice-President)

4 Feb 2016 · Energy Union - main initiatives

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

13 Jan 2016 · Opportunities of Energy Union for EU technology manufacturers

Meeting with Jyrki Katainen (Vice-President) and

19 Nov 2015 · Digitalisation of industry - jobs and growth

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

16 Nov 2015 · DSM & Circular Economy

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

12 Nov 2015 · TTIP

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

9 Nov 2015 · DSM & Circular Economy

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

27 Oct 2015 · Energy Union and Innovation, technology solutions

Meeting with Dominique Ristori (Director-General Energy)

29 Sept 2015 · Circular Economy

Meeting with Lowri Evans (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

29 Sept 2015 · Presentation of Orgalime, Digital Single Market, Energy Union, Internal Market Strategy, TTIP, standardisation, circular economy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

16 Jul 2015 · Circular Economy and Energy Union

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

13 Jul 2015 · Engineering industries, Energy Union and CEP policies

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

3 Jul 2015 · Follow-up to meeting with the Commissioner

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

16 Jun 2015 · DSM, standards

Meeting with Alfredo Sousa De Jesus (Cabinet of Commissioner Carlos Moedas)

1 Jun 2015 · Meeting with Adrian Harris, Orgalime

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

21 May 2015 · DSM

Meeting with Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

10 Mar 2015 · Energy Union

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology)

16 Feb 2015 · Digital Single Market, EFIS

Meeting with Eric Mamer (Digital Economy)

16 Jan 2015 · Investment plan

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

15 Jan 2015 · Product safety

Meeting with Eric Mamer (Digital Economy)

16 Dec 2014 · Investment plan