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VDE Verband der Elektrotechnik Elektronik Informationstechnik

VDE

Der gemeinnützige VDE e.V.

Lobbying Activity

Response to Review of EU rules on fluorinated greenhouse gases

28 Jun 2022

In April 2022, the EU Commission presented a draft for the new version of the F-Gas Regulation (EU Regulation 517/2014). VDE FNN, as a national rule maker and recognized platform for grid technology and grid operation, supports the Commission's climate protection goals especially with regard to a climate neutral energy system. As many technical options as possible are needed to restructure the energy system while maintaining a high level of supply reliability. Clear criteria for weighing these options are important. In addition to local and technical requirements (including space requirements and installation situation), availability and price, minimization of the climate impact of the insulating gases used must also be taken into account in the future. At the same time, the planned acceleration of the transformation of the energy system in Germany requires the greatest possible flexibility in the construction and replacement of new Switch gears and thus also in the technical options. The regulation of individual technological aspects planned by the EU Commission to minimize the climate impact of insulating gases must be evaluated in terms of its effects, particularly with regard to the restriction of technologies and availability, and weighed up in advance by the EU Commission against the goal of a rapid transformation. In the sense of the most comprehensive consideration possible, the definition of steps towards climate-neutral grid operation with a commitment to an overall target in a suitable form, as well as additionally the carbon footprint of the entire plant from production through operation to disposal, should be taken into account. The draft regulation provides for a differentiated consideration of the areas of application and voltage levels, which VDE FNN expressly welcomes. Due to the importance of the switchgear for the electrical energy supply and the safe and reliable network operation, VDE FNN sees a need for adjustment in the following points: • Adjustment of the transition times and market availability as a further criterion necessary • The term "Placing on Market" must be defined more broadly for switchgear • Assess the effects of classifying alternative solutions > 52 kV according to GWP limits • It must continue to be possible to carry out repairs and extensions to existing switchgears Please see attached file more details
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

6 Apr 2022

DKE welcomes the recognition of the national delegation principle in the proposed amendment to the EU Regulation 1025/2012 on European standardization, a principle in which we firmly believe in. As a National Committee (NC) of CENELEC and National Standards Organization (NSO) of ETSI, the national delegation principle is at the heart of our core values and working methods, since it ensures that all interested parties are involved. In the light of the EU priorities to safeguard the European values and interests as well as to ensure European technological and digital sovereignty, we understand the concerns of the European Commission that led to the proposed amendment. The national delegation principle is at the heart of CENELEC´s way of working. Therefore, DKE is confident that CENELEC can adapt its governance where it might be necessary in a way that responds to the needs of the European Commission while keeping the CENELEC community unified. The European Standardization Strategy targets to make the EU a “Global standards-setter” as one of its priorities. In this context, it should be considered that also non-EEA Members in the CENELEC community help securing a bigger influence at the international level (e.g. IEC). Their contribution is important for our stakeholders and to the European Standardization System in a whole. They follow the same national delegation and implementation principle, allowing one Harmonized European Standard to replace national standards in their countries. ETSI´s way of working is appreciated by our German stakeholders in the context of the international ICT standardization system, especially as organisational partner within 3GPP. Implementing the national delegation principle would mean a more significative change in their governance. However, the reinforcement of the national delegation principle regards only EU standardization requests for Harmonized Standards, which are a small part of the whole standardization work in ETSI. DKE as German ETSI NSO has the necessary experience and resources to contribute to the discussion with ETSI and the Commission on possible ways of adapting the processes to ensure a good governance for harmonized European Standards. Finding compromises, and consensus stands at the core of our identity and the work we deliver. DKE is ready to engage in a constructive dialogue with the European Commission to find suitable solutions for everyone that fit today’s European and global challenges.
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Response to Review of the general product safety directive

9 Aug 2021

Standardization in support of the EU legislation has become over the decades a strategic tool for the well-being of the European Internal Market and European companies, as well as European consumers and society, a system copied by partners around the world. We appreciate that this also applies for the European Commission proposal for a GPSR even though it is not a harmonization legislation. The GPSR proposes to amend the Regulation 1025/2012 on European standardization. This Regulation is setting the general framework for European standardization and European Union legislation and policies. Therefore, we see no necessity to amend the Regulation 1025/2012 for the specific application of the GPSR and recommend removing all references concerning the adaptation or amending of the Regulation 1025/2012. We welcome the results of ex post evaluations, stakeholder consultations and impact assessment particularly concerning the simplification of the standardization processes. The European commission just published the Roadmap for the standardization strategy in which the standardization and citation of Standards in the Official Journal of the EU (OJEU) plays a major role. We believe that the simplification of the standardization process is an important but more general topic to be addressed in the frame of the Roadmap and not the GPSR. Moreover, a recently created high-level task force between the European Standardization Organizations (the ESOs: CEN, CENELEC and ETSI) and the European Commission is currently already addressing this problematic . Therefore, we recommend deleting any references to the simplification of the standardization process within the GPSR as we think that the high-level task force the right platform for such work is. About the transition Period: According to Article 47 the Regulation is to be applied within 6 months after entry into force with no parallel phase with the previous GPSD is envisaged. We are of the opinion that 6 months is extremely short specially for the introduction of the new labelling and documentation requirements. We recommend an extension to at least one year.
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Response to Standardisation Strategy

5 Aug 2021

DKE, the German Commission for Electrical, Electronic & Information Technologies of DIN and VDE, thanks the EU Commission for conducting the consultation on the EU Roadmap "European Strategy for Standardization". We support the approach to challenge the European Standardization System in order to further develop a robust, resilient and competitive European economy. DKE firmly believes that the European Standardization System is still fit for purpose. We support the current NLF system while recognizing that improvements are necessary and see the Roadmap as a constructive opportunity to find complementary solutions to set the path for the future. Thanks to our long and well-established experience in the field of electrotechnical and information-technology standardization at national, European and international level, we aim through our feedback at contributing to the vision for a European Standardization Strategy. To respond to the main three questions the Roadmap sought to seek, i.e. (1) whether the current European standardisation system is fit for purpose to support European strategic interests; (2) how the EU can leverage and promote global leadership in standards-setting; (3) whether changes in governance and working methods are required to improve the performance of the European standardisation system, in this document we: - Explain and give examples why we believe the European Standardization System is still fit for purpose. - Put forward the European/international relationship model between CENELEC and IEC as an already successful model for the electrotechnical industry from which the European Union could seek inspiration and extend it to other sectors. - Address standards-related education for global leadership and introduce the Next Generation DKE activities as an example to meet the challenge of skills gaps and avoid a lack of standardization experts in Europe in the future. - Expressly welcome the task force set up by the Commission, CEN, CENELEC and ETSI to tackle the bottlenecks in the process of European standardization in support to EU legislation. You will find DKE full position with our set of best practices enclosed.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

DKE, the German Commission for Electrical, Electronic & Information Technologies of DIN and VDE, welcomes the new EU proposal of Regulation on batteries and waste batteries that should allow to position EU industry leadership as frontrunner in terms of green and technologically advanced batteries. However, within the standardization community and the European industry, the proposed Article 16 raises some concerns as the European Commission gives itself the right to draft implementing acts instead of commissioning the European Standardization Organizations (CEN, CENELEC, ETSI) as required by the EU Regulation 1025/2012. The use of Harmonized Standards should be prioritised over delegated and implemented acts (cf. Article 15). This important piece of legislation should follow the New Legislative Framework (NLF). In our view it is a sine qua non to reach the objectives of the Green Deal. As we speak about the EU economic recovery and achieving a circular economy, it is important that the development of standards remains flexible as laid out in the NLF principles, which define the roles of each actor in the process (including the role of technology experts from all around Europe), and whose implementation have proven to be successful all these years. The proposed Regulation shows great standardization potential to be taken into consideration to avoid upcoming fragmentation in the European Single Market for batteries and waste batteries. Under Articles 13, 59, 64 and 65 new standardization areas for labelling and “Battery Passport” or the remanufacturing and repurposing of batteries should be taken on board. The Batterie Regulation is still lacking some important definitions. Specific terms and concepts should be reviewed in a consistent and coherent way or the standardization work to be carried out will suffer of different interpretations and misunderstanding. Article 12 should be revised to better ensure that electrical safety is also taken on board. As should be Article 59 which entails underestimated test requirements for remanufactured and repurposed batteries and should tackle the role of “type tests" to ensure product safety. Our more detailed feedback is to be found in our position paper on the Batteries Regulation in the attached file.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius)

9 Feb 2021 · Revision of the EU Batteries Directive; Sustainable Products, Consumption and Production

Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

1 Dec 2020

DKE, the German Commission for Electrical, Electronic & Information Technologies of DIN and VDE, welcomes the EU Roadmap on "Evaluation of certain aspects of the New Legislative Framework" and the opportunity for stakeholders to give feedback. Being active at European level as the German National Committee of standardization of CENELEC and national standardization organization of ETSI, and at international level, as Member of IEC, as well as counting in its membership representatives from the industry that support and benefit from the NLF, DKE is looking forward to the public consultation that will follow in 2021 to which it intends to participate. Indeed, we are convinced that the success of the European single market is built around the free and safe trade of products and based on the successful implementation of the NLF legislation to which European standardization plays an essential role. Regulation, standardisation - for the technical specification of regulations - and market surveillance play a major role in this system. As a supporting measure, conformity assessment also helps in providing the proof that a product meets the regulatory requirements. This allows the industry to place its products safely on the European market. Hence any improvement to the NLF should be made with the view to further consolidating the application of NLF legislation and ensure its good implementation. European Standards reduce barriers to trade by harmonizing requirements for products, allowing conformity with WTO/TBT Agreement, and influencing international trade activities too. As the market of electrotechnical products (DKE domain of expertise) is international we would like to stress that the NLF could emphasize more the links with the international dimension, which will prove crucial for Europe to strengthen its position as a global leader in topics that are near to its fundamental values, while also ensuring that the consumers safety and interests are also being preserved. For example, the International Electrotechnical Commission (IEC) where European countries are well represented, is both active in international standardization and conformity assessment, which offers a risk-based system approach following a holistic view. It is the only organization in the world that provides an international and standardized approach to testing and conformity assessment, and where international standardization and conformity assessment can be tackled in a concerted effort. If the European Union wants to set the rule, hence the standards, at the global level by fueling European values and needs, CEN, CENELEC with their strong partnership with ISO and IEC, should remain the preferred partners for European policymakers regarding standardization. A well-functioning European Single Market needs an intact framework that should be in our view expanded to other sectors and new technologies to be able to tackle the twin transition and ensure a competitive edge to European industries. This is especially true as we need to cope with the challenges arisen by the COVID situation adding up to the European industry digital transformation, the fierce global competition, and the result of BREXIT. Only by preserving and restoring the foundation of the NLF, as well as expanding its use, will we restore market confidence and ensure that our industry experts keep on board.
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