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Verband Deutscher Maschinen- und Anlagenbau e.V.

VDMA

VDMA represents more than 3600 companies in the European machinery and plant engineering sector.

Lobbying Activity

Meeting with Eric Mamer (Director-General Environment) and

20 Jan 2026 · Exchange of views on the Circular Economy Act and related EU law

Meeting with René Repasi (Member of the European Parliament)

15 Dec 2025 · Lage der Automobilwirtschaft und Automobilpaket

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

10 Dec 2025 · Revision of the Standardisation Regulation 1025

German machinery industry urges pragmatic EU taxonomy reforms

5 Dec 2025
Topic — The European Commission is reviewing technical screening criteria for the EU taxonomy.
Message — VDMA seeks to include circular engineering services and align taxonomy with packaging laws. They also advocate for international standards and removing mandatory third-party verification.123
Why — Machinery companies would avoid high verification costs and simplify their sustainability reporting.45
Impact — Leading technology innovators lose their unique status as the only taxonomy-aligned providers.6
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Meeting with Margareta Djordjevic (Head of Unit Energy)

18 Nov 2025 · Joint Initiative from industry and academia for strong fluid power in EU

Meeting with Alexandre Paquot (Director Climate Action) and

18 Nov 2025 · Discuss the role of Fluid Power technologies in reducing greenhouse gas emissions

Meeting with Lucia Granelli (Head of Unit Taxation and Customs Union)

17 Nov 2025 · Exchange on tariffs

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

9 Nov 2025 · Revision of the New Legislative Framework (NLF)

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

16 Oct 2025 · AI Act implementation and simplification

Meeting with Maroš Šefčovič (Commissioner) and

15 Oct 2025 · EU – US relations

Meeting with Tobias Cremer (Member of the European Parliament)

15 Oct 2025 · European Defense

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

15 Oct 2025 · Meeting with VDMA - minutes

Meeting with Iuliu Winkler (Member of the European Parliament)

14 Oct 2025 · EU agricultural sector

German machinery industry urges technology-neutral approach to EU vehicle emissions

10 Oct 2025
Topic — EU CO2 emission standards for new cars and vans targeting climate goals.
Message — VDMA requests immediate revision of CO2 fleet regulations to allow plug-in hybrids and combustion vehicles using renewable fuels beyond 2035. They argue current battery-only approach is unrealistic and harms European competitiveness. They want well-to-wheel emissions assessment replacing tank-to-wheel metrics.1234
Why — This would protect their members' investments in combustion engine technology and supply chains.56
Impact — Climate goals lose momentum as combustion engines remain eligible longer than planned.7
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Meeting with Felicia Stoica (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

9 Oct 2025 · Revision of the New Legislative Framework (NLF)

German machinery industry calls for sweeping digital regulation overhaul

8 Oct 2025
Topic — EU's Digital Omnibus initiative to simplify digital regulatory framework across multiple acts.
Message — VDMA urges the EU to launch a bold Digital Omnibus covering AI Act, Data Act, CRA, GDPR and NIS 2. They propose concrete simplifications including deleting AI Act provisions that create double regulation with machinery rules, revising Data Act definitions causing legal uncertainty, and implementing risk-based GDPR approach. The association argues current digital regulations burden innovation and competitiveness while requesting 25-35% reduction in administrative requirements.1234
Why — This would reduce compliance burdens and administrative costs for mid-sized machinery manufacturers.56
Impact — Consumer and worker safety protections could be weakened by removing AI Act safeguards.7
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German machinery industry urges process-focused approach over defining innovative companies

2 Oct 2025
Topic — EU framework to strengthen innovation ecosystem and improve market access for innovative companies.
Message — VDMA opposes defining innovative companies, arguing it creates bureaucracy and discrimination. They demand innovation stress tests for all regulations checking impacts on competitiveness, time-to-market, and small-scale production. They want support for IPR development and simplified public procurement access.1234
Why — This would reduce regulatory burdens and compliance costs while avoiding discrimination against established machinery firms.56
Impact — Start-ups and scale-ups lose targeted support measures if Innovation Act takes process-focused rather than actor-centered approach.78
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German Engineering Industry Urges Swift CBAM Rules by Q3 2025

24 Sept 2025
Topic — New EU methodology for calculating embedded emissions under the Carbon Border Adjustment Mechanism.
Message — VDMA requests urgent adoption of all CBAM implementing legislation by Q3 2025, including benchmarks and default values. They want default values to reflect real emission levels rather than artificially inflated figures. The organization also seeks harmonization with existing carbon footprint calculation standards.123
Why — This would enable their member companies to plan business strategies and avoid paying for excessive certificates.45
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Meeting with Jens Geier (Member of the European Parliament)

24 Sept 2025 · Exchange on Clean Industrial Accelerator Act

Meeting with Henning Ehrenstein (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

24 Sept 2025 · Delegation of German machine building companies (large and small) visiting Bxl with their DE umbrella organization VDMA

German machinery industry urges EU corporate framework open to all companies

23 Sept 2025
Topic — EU proposal for uniform corporate legal framework to simplify cross-border business operations.
Message — VDMA requests that the new European private company form be available to all companies, not just innovative startups. They want it designed as an optional instrument with fully European rules avoiding national law references. They emphasize maintaining minimum share capital requirements and insolvency filing obligations.1234
Why — This would reduce bureaucracy and legal costs from navigating 27 different national legal systems.56
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Meeting with Svenja Hahn (Member of the European Parliament)

23 Sept 2025 · EU-US trade relations, tariffs

German machinery industry backs EU 90% emissions cut by 2040

15 Sept 2025
Topic — Amendment to European Climate Law to include 2040 climate target towards 2050 neutrality.
Message — VDMA supports the 90% emissions reduction target and urges timely legislation before COP30. They request a clear EU framework for Carbon Credits that allows industry flexibility and follows technology neutrality principles. Future legislation must avoid bureaucratic burden and ensure competitiveness, especially for SMEs.123
Why — This would create stronger market demand for their green technologies and machinery while providing compliance flexibility.45
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Meeting with Matthias Jorgensen (Acting Director Trade)

5 Sept 2025 · EU-US trade relations

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

5 Sept 2025 · Introduction of VDMA organisation and exchange of views on various machinery and equipment related matters

German machinery industry calls for reformed energy taxation and hydrogen import strategy

4 Sept 2025
Topic — EU strategic framework for renewable fuel investments in transport sector decarbonization.
Message — The association requests reform of the Energy Tax Directive to support climate-neutral fuels, long-term regulatory certainty with grandfathering provisions for early investors, and pragmatic import rules including relaxed additionality criteria for hydrogen production. They emphasize the need for consistency across regulations like RED III, FuelEU Maritime, and RefuelEU Aviation.12345
Why — This would reduce investment risks for their members' hydrogen technology projects with 15-20 year horizons.67
Impact — Third-country producers face stricter CO2 accounting rules than EU competitors during ramp-up phase.8
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VDMA urges strict controls on fallback technical product specifications

3 Sept 2025
Topic — The EU is updating product legislation to create technical rules for digital technologies.
Message — The VDMA insists that Common Specifications remain a fallback option used only when industry standards are missing. They demand expert drafting committees and public consultations to ensure transparency throughout the regulatory process.12
Why — Machine builders would avoid expensive third-party audits by maintaining a presumption of conformity.3
Impact — Third-party testing organizations lose business if companies can bypass mandatory certification using specifications.4
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VDMA demands transparent framework for EU technical product specifications

2 Sept 2025
Topic — The consultation concerns aligning EU product legislation with the digital economy.
Message — VDMA insists that Common Specifications remain a fallback option used only when industry standards face delays. They call for a designated Commission process owner and mandatory public consultations on all drafts.123
Why — This protects industry-led standardisation and helps companies avoid costly third-party conformity assessments.4
Impact — Private consultancy firms lose potential contracts because VDMA wants to prohibit outsourcing development tasks.5
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Response to Revision of the 'New Legislative Framework'

29 Aug 2025

Please find attached the VDMA position paper. Overview of the Needs of the European Manufacturing Industry to Future-Proof the NLF 1. Issues and Challenges with Harmonised Standards and Its Threat to the NLF (Chapter 1) a. The process to obtain harmonised standards from the standardisation request to the listing in the OJEU should be accelerated and simplified. b. Harmonised standards should be able to be based on international standards from ISO and IEC. 2. Digital Integration of the Internal Market and the Proportional Introduction of the Digital Product Passport (DPP) (Chapter 2) a. The digitisation of documentation is a pragmatic first step. It is important that any system put in place remains interoperable with the DPP under the Ecodesign for Sustainable Products Regulation (ESPR), without duplicating efforts or creating new burdens for businesses. The DPP should act solely as a digital container for existing documentation such as the EU Declaration of Conformity and user instructions enabling competent authorities to perform more effective market surveillance. 3. Revision of Conformity Assessment by Strengthening Module A (Chapter 3) a. The Commission should strengthen the application of Article 4(1d) of Decision 768/2008/EC and prioritize the possibility to use Module A wherever the product risk allows, ensuring proportionality and preserving innovation capacity in European industry. b. The trend towards increased mandatory third-party certification should be critically reassessed, as it risks diverting scarce STEM resources from innovation and weakening market surveillance. To amend past regulation, a conformity assessment simplification omnibus should be introduced. 4. Alignment of Definitions and Provisions Across Legislative Acts (Chapter 4) a. Definitions and Provisions should be harmonised and simplified across legislative acts. Furthermore, any deviation to the letter from previously established definitions and provisions should be explained in recitals. 5. Beyond Alignment: Reduction of Administrative Burdens in Product Regulation (Chapter 5) a. Achieving the Commissions ambitious goal of reducing administrative burdens by 25% (35% for SMEs) requires building the capacity and competence to systematically screen existing product legislation and eliminate disproportionate requirements, as alignment with NLF provisions alone will not suffice. 6. Clarifying the Regulatory Framework for Remanufacturing and Refurbishment (Chapter 6) a. Future Delegated Acts under the ESPR should avoid narrowly defining substantial modification and instead provide clear guidance and exemptions to manage overlaps between regulatory frameworks. Only the legal acts actually triggered by a modification should require a new declaration of conformity, while partial remanufacturing or component upgrades should not automatically demand a full CE reassessment. b. Remanufacturers should fully assume manufacturer responsibility, including marking obligations, without requiring original manufacturers to disclose technical documentation, thereby safeguarding intellectual property while ensuring consumer safety. 7. Functioning, Localisation and Oversight of Notified Bodies (Chapter 7) We fully support the Commissions intention to significantly reinforce the oversight of notified bodies, with particular emphasis on outsourcing to third countries, requiring prior disclosure to manufacturers, and ensuring transparency through reporting of subcontracting arrangements in the NANDO database. 8. Timely and Consistent Response to Non-Compliant and Dangerous Products (Chapter 8) a. The Commission should establish a centralized EU market surveillance authority to improve coordination between national and customs authorities. b. Companies with repeated safety violations should be excluded from using Module A and required to undergo third-party conformity assessments by notified bodies.
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German machinery industry warns against extending CBAM scope

26 Aug 2025
Topic — The EU is consulting on extending the carbon border tax to downstream products.
Message — VDMA opposes extending the carbon tax due to high costs and data complexity. They demand a thorough impact assessment and a two-year phase-in period. They also seek realistic default values for calculating emissions of complex parts.123
Why — Avoiding the extension protects the global competitiveness of European machinery exporters.4
Impact — EU climate policy loses as excluding downstream products allows continued carbon leakage.5
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German machinery industry demands broader EU F-gas deregulation

20 Aug 2025
Topic — An EU initiative to reduce administrative burdens and simplify rules for mid-sized companies.
Message — VDMA requests a wider revision to create a business-friendly framework. They propose exempting small-scale gas users from registration requirements. They also seek standardized documentation to reduce legal uncertainty.123
Why — This would protect the competitiveness of European manufacturers against foreign rivals.45
Impact — Regulators would lose oversight of smaller gas flows due to exemptions.6
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Response to Revision of the Standardisation Regulation

17 Jul 2025

VDMA represents >3,600 German and European companies in the mechanical and plant engineering sector. As an umbrella organisation of 36 specialised associations, VDMA covers the full value chain of the capital goods industryfrom components to complete systems, and from machinery to digital logistics. VDMA funds and staffs the Mechanical Engineering Standards Committee (NAM) within DIN, which has led standardisation in mechanical engineering since 1949. NAM is responsible for national, European, and international standardisation and closely cooperates with the DIN Standards Committee for Machine Tools (NWM), also affiliated with VDMA. In 2024, NAM managed 14 CEN/TC and 17 ISO/TC / SC secretariats, with 3,029 experts from 1,725 companies in 329 committees. This ensures high-quality, industry-driven standards and strengthens Europes voice in global standardisation, supporting international competitiveness. Harmonised standards (hEN) must remain the primary tool for presumption of conformity under EU harmonised legislation. Developed through transparent, consensus-based processes, hEN reflect the state of the art and provide legal certainty when cited in OJEU. Their legal role must be clearly defined and consistently applied across all relevant legislation, with Article 20 of the Machinery Regulation (EU) 2023/1230 serving as a harmonisation model. Common Specifications (CS) should only be used in exceptional cases, such as: -when hEN are unavailable due to non-acceptance of SReq by ESOs, -significant delays in hEN development, -or lack of coverage in hEN. Delays in citation or negative HAS assessments alone should not justify CS development. CS must follow clear, horizontal criteria ensuring inclusiveness, coherence, transparency, and alignment with international best practices. CS may offer opportunities to involve other rule-makers, such as ICT consortia. However, such involvement must comply with Annex II of (EU) No. 1025/2012 and be integrated into ESO-led processes to maintain system integrity and international compatibility. To ensure legal certainty and effective governance, the following measures are essential: -Stakeholder involvement must be guaranteed in CS drafting. -The voluntary nature of hENand CS where applicablemust be legally stated. -Clear criteria must be established for when and how CS may be developed, especially when involving other standard-setting bodies. -Characteristics of CS, including review cycles and withdrawal procedures, must be defined. -A dedicated process owner (e.g. a new Agency or Directorate General) should oversee Standardisation Requests and CS development, ensuring compliance with defined criteria. -A uniform template and agreed timelines for SReqs are needed for both hEN and CS. -The role and decision-making criteria of HAS Consultants must be clearly defined in the legal framework to ensure transparency and proportionality. -Early engagement of standardisation bodies should be enabled via preliminary SReq once legislative texts reach a stable stage in trilogue negotiations. -A leaner standardisation process should be explored to reduce hEN drafting time, including parallelisation or reordering of process steps. -The involvement of multiple standard-setting organisations increases complexity and administrative duties. This must be reduced through harmonisation or consolidation of structures and processes. -Given shortage of experts and rise of horizontal topics, consortia must be linked to standardisation without bypassing established processes. Their results should be transferable into standardisation, with low-threshold expert participation. VDMA strongly supports a revision of (EU) No. 1025/2012 to address these challenges and ensure the European standardisation system remains efficient, inclusive, and internationally aligned. Harmonised standards must continue to be the backbone of EU product legislation, with Common Specifications serving only as a carefully governed exception.
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Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

17 Jul 2025 · EU’s machinery equipment industry

Meeting with Eva Valle Lagares (Head of Unit Trade)

17 Jul 2025 · Presentation VDMA’s new Position Paper on China

German engineering association VDMA demands EU Data Act revisions

15 Jul 2025
Topic — The consultation explores options to streamline existing data rules and infrastructure investments.
Message — VDMA requests declaring mandatory data sharing rules for industrial business to be inapplicable. They further propose that the Data Act application be postponed by 2 years.12
Why — This would lower administrative costs and protect manufacturers' proprietary trade secrets.34
Impact — Industrial data users lose mandatory access to information and automated sharing rights.56
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German machinery industry opposes costly audits for unsold products

10 Jul 2025
Topic — EU rules specifying how companies must disclose information on discarded unsold consumer products.
Message — VDMA opposes mandatory third-party auditing for discarded unsold consumer products. They recommend keeping product-level reporting separate from corporate sustainability frameworks to avoid duplicative processes.12
Why — This would reduce administrative costs and prevent procedural complexity for engineering firms.34
Impact — Transparency groups lose access to independently verified technical data on product destruction.56
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

18 Jun 2025 · Current and planned Commission initiatives

Meeting with Andreas Glück (Member of the European Parliament)

11 Jun 2025 · Energy Performance of Buildings Directive

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

2 Jun 2025 · Industrial and trade policy

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

28 May 2025 · Discussion about the state of play of the Data Act implementation in the German machinery industry

Meeting with Hildegard Bentele (Member of the European Parliament) and Hansgrohe and Wetlands International - European Association

14 May 2025 · Water Policy

Meeting with Sabine Weyand (Director-General Trade)

13 May 2025 · Development of the transatlantic relations in the context of tariffs escalation

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

7 May 2025 · Discussion about VDMA’s position on the Data Union Strategy

Meeting with Pascal Arimont (Member of the European Parliament, Shadow rapporteur)

6 May 2025 · eDeclaration for the posting of workers

Meeting with Raphaël Glucksmann (Member of the European Parliament)

6 May 2025 · International Trade

Meeting with Svenja Hahn (Member of the European Parliament)

30 Apr 2025 · New Legislative Framework

Meeting with Brigitte Van Den Berg (Member of the European Parliament, Shadow rapporteur)

28 Apr 2025 · Edeclaration posting of workers

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

16 Apr 2025

Please find the feedback of the VDMA e.V. in the attached file.
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Meeting with Andreas Schwab (Member of the European Parliament, Rapporteur)

14 Apr 2025 · eDeclaration on the posting of workers

Response to Ecodesign requirements for circulators (review)

10 Apr 2025

The VDMA Association Pumps + Systems supports the call for evidence for an impact assessment - Ecodesign requirements for circulators (review). VDMA Pumps + Systems represents more than 110 manufacturers of pumps and pump units in Germany and Europe with a production volume of around 7 billion and more than 25,000 employees. ** VDMA Pumps + Systems supports the call for an impact assessment on Ecodesign requirements for circulators under the Ecodesign Directive 2009/125 by the end of 2026. ** VDMA Pumps + Systems do not recommend stricter requirements for circulators within the current scope of the Regulation (Objective B.1) to achieve additional energy and financial savings, following a similar conclusion in the review study (page 7). ** VDMA Pumps + Systems welcomes the EU Commission's approach to include "drinking water circulators" in the revision (Objective B.2). We recommend following the Europump formula which leads to an energy efficiency index for "drinking water circulators" from EEI(DW)<=1.1 based on a simple calculation with P1 and P1_ref. ** VDMA Pumps + Systems would like to ask the EU Commission to reconsider the need to extend the information requirements of objective B.3 (including head, flow rate, hydraulic power and electric power at full and part load), as this information doesn't add value and will mainly increase costs, as well as it doesn't help market surveillance to enforce the EEI requirements. ** With regard to the Green Deal, VDMA Pumps + Systems supports the circular economy and therefore the EU Commission proposed requirements for repairability and availability of spare parts for circulators in general (Objective B.4). However, for reasons of economy, safety and reliability, we would like to emphasize that small circulators (P1<=150W) should be excluded from these requirements. Thank you (Please note: There is a typo in the call for evidence in paragraph B, first objective. The stated EEI of 2.0s should be 0.2# - otherwise circulators would produce free energy).
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Meeting with Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné), Valentina Schaumburger (Cabinet of Executive Vice-President Stéphane Séjourné)

9 Apr 2025 · Single Market eDeclaration

Meeting with Eva Valle Lagares (Head of Unit Trade)

4 Apr 2025 · EU-China relations

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

17 Mar 2025 · Sustainability Omnibus

VDMA urges EU focus on water-efficient technology in buildings

4 Mar 2025
Topic — The EU is developing a strategy to ensure water resilience and sustainable management across sectors.
Message — The VDMA recommends making water-efficient technology an integral part of EU building regulations. They advocate for a water efficiency principle and a label for water-saving products. Finally, they call for a dedicated fund to support research and development in water resilience.123
Why — These measures would boost the market for advanced sanitary products and strengthen European competitiveness.45
Impact — Building owners may face higher costs when investing in new infrastructure and management systems.6
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Meeting with Andrea Wechsler (Member of the European Parliament)

28 Feb 2025 · EU Energy and industry policy

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

20 Feb 2025 · Simplification

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

13 Feb 2025 · Clean Industrial Deal and Circular Economy Act

Meeting with Paolo Garzotti (Acting Director Trade)

13 Feb 2025 · Exchange of views on the EU-Mercosur FTA

Meeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

12 Feb 2025 · Introductory meeting / general trade policy

Meeting with Mehdi Hocine (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 Feb 2025 · Discussion with VDMA on EU trade relations

Meeting with Bonifacio Garcia Porras (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

11 Feb 2025 · Discussions related to the upcoming omnibus package related to Corporate Sustainability (CSRD, CSDD, EU Taxonomy)

Meeting with Sander Smit (Member of the European Parliament)

7 Feb 2025 · ENVI-general

Response to Agricultural and forestry vehicles - amendments of requirements for vehicle braking and vehicle functional safety

5 Feb 2025

Die Vorschläge sind ausgewogen und entsprechen dem Stand der Technik. Eine zügige Umsetzung und Anwendung wird begrüßt. Es existiert weiterer Bedarf an der Anpassung der Vorschriften für landwirtschaftliche Fahrzeuge an den technischen Fortschritt. Vorschläge hierfür sind bereits verfügbar. Die Kommission wird gebeten, weitere Änderungsvorschläge baldmöglichst mit den Experten der Mitgliedstaaten und der interessierten Kreise zu diskutieren und umzusetzen.
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Meeting with Andrea Wechsler (Member of the European Parliament) and FuelsEurope and

4 Feb 2025 · EU Energy and industry policy

Meeting with Gabriele Bischoff (Member of the European Parliament, Shadow rapporteur) and Bayer AG and

24 Jan 2025 · Austausch mit dem Wirtschaftsforum der SPD e.V. zur Revision Eurobetriebsräte

Meeting with Mehdi Hocine (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

21 Jan 2025 · Discussion on VDMA position paper “Fast tracks to simplification”

Meeting with Christian Ehler (Member of the European Parliament, Rapporteur) and European Factories of the Future Research Association

16 Jan 2025 · FP10

Meeting with Svenja Hahn (Member of the European Parliament, Rapporteur for opinion) and American Chamber of Commerce to the European Union and

11 Dec 2024 · Revision of the EUs Foreign Direct Investment Screening mechanism

Response to Digital Product Passport (DPP) service providers

8 Dec 2024

Essential requirements for DPP Service Providers from a Machinery and Equipment Manufacturer persepctive: 1. Data security and integrity: DPP service providers must adhere to strict data security standards to protect sensitive product information. This includes in particular; the use of the harmonised standards being currently created for the DPP system. 2. Compliance assessment scheme: A lean assessment scheme as a minimum entry barrier will be essential to verify that DPP service providers meet the essential requirements set out in the framework for those service provider. This scheme should assess the provider's compliance with e.g. data security and technical requirements. To avoid bottlenecks, delays and unnecessary costs, this assessment scheme should remain lean and rely on a self-assessment of providers and a notification to monitoring authorities, following the idea under the Data Governance Act. This should be regularly renewed to ensure that service providers continue to meet the evolving needs of the market. On the long term, the Commission should evaluate the possibility of a harmonised standard on the assessment scheme. In any case, providers must comply with existing and upcoming EU-regulations in the field of Cybersecurity, Data governance and platform regulation. 3. Business Continuity Management approach instead of pure financial viability: To ensure long-term access to DPPs, service providers must demonstrate data security, technical capability, and financial stability. Given that many mechanical products have long lifespans (over 20 years), DPP service providers must guarantee that product data remains accessible for decades. It should also be noted that if a DPP is not correctly implemented by the service provider, and the market authority identifies inconsistencies and withdraws the product from the market, the economic operator will incur a loss of revenue.The Commission should therefore establish clear requirements in the event of a complete discontinuation of a service provider. The economic operator must be guaranteed that their data will be transferred to another service provider without any loss or security issues. We believe that a Business Continuity Management (BCM) approach is more practical than merely proving financial viability. A BCM approach would be a comprehensive strategy to ensure that a company can continue operating during and after a disruption of service. It should involve planning, preparation, and the implementation of strategies to protect critical business functions while minimizing the impact of potential threats or crises on the companys operations. This may include outlining how service providers should collaborate and integrate in the event of a disruption. 4. Interoperability: As DPPs must be accessible across different platforms and industries, service providers should adhere to standardized data formats, exchange protocols, and be able to interlink also cross-sectoral. This will ensure that DPP data can be easily shared and accessed across different sectors. 5. Transparency and accountability: Service providers must offer transparency regarding how product data is managed, including clear data retention policies, data access protocols, and a guarantee that product information will be accessible throughout the products lifecycle. 6. Support for SMEs: The regulatory framework must ensure that the assessment and operational requirements for DPP service providers are not overly burdensome for SMEs. This includes clear guidelines on data storage options and customer support services, ensuring that SMEs can affordably comply with ESPR regulations without undue complexity. 7. International perspective: This international aspect must be considered when designing the framework for service providers. It is crucial to ensure independence from large IT companies in order to maintain a free market. Companies should be able to use DPP service providers outside the EU.
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Response to Negotiations with Bahrain, Kuwait, Oman, Qatar, Saudi-Arabia and United Arab Emirates

11 Sept 2024

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, welcomes the call for evidence in relation to EU-Gulf relations bilateral strategic partnership agreements (authorisation to open negotiations). Below you will be able to find our non-exhaustive feedback: - VDMA views the Gulf as an important region. The region is the EUs sixth largest export market and is an important investment destination for the 27 EU Member States. In addition, the region is gaining geopolitical importance due to high energy prices as a result of the ongoing war in Ukraine. Moreover, these countries have their own Customs Union and are working towards the objective of completing an Internal Market. However, VDMA member companies face in Bahrain, Kuwait, Oman, Qatar, Saudi Arabia and the United Arab Emirates trade barriers. - Firstly, many private and State-owned companies in the Gulf region have so-called localisation requirements to achieve more investments in their countries, e.g. in the area of public procurement. An example is the programme In-Kingdom Total Value Add (IKTVA) of Saudi Aramco or the In Country Value (ICV) programme of ADNOC in the United Arab Emirates. - Secondly, there are necessary certifications for exporting machines, especially to Saudi Arabia. Almost every machine and every spare part needs such certification in Saudi Arabia. Certification is especially problematic for spare parts deliveries. Here, the costs for certification are often higher than the costs for the product. - Thirdly, there is a considerable amount of bureaucracy with trade documents that often have to be legalised, e.g. invoices. - VDMA is calling for the elimination of these trade barriers, which represent a high entry hurdle for medium-sized companies in particular. This can in our view be best achieved through bilateral Free Trade Agreements, e.g. Saudi Arabia and the United Arab Emirates. These Free Trade Agreements can at a later stage be part of a regional Free Trade Agreement between the EU and the Golf Cooperation Council.
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Meeting with Jens Gieseke (Member of the European Parliament) and Verband der Automobilindustrie

16 Jul 2024 · Austausch zu Umwelt- und Verkehrspolitik

Response to Evaluation of the Pressure Equipment Directive (PED) and the Simple Pressure Vessels Directive (SPVD)

17 Jun 2024

Both the Pressure Equipment Directive and the Simple Pressure Vessels Directive have proven valuable and reliable legislation supporting European companies coping with their business challenges. Any change of the Directives would create questions within their daily business. Therefore, I strongly recommend to leave the Directives unchanged except legal or formal adaptions if necessary. Thank you very much Kind regards Hartmut Tembrink VDMA Valves Department
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Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

24 Apr 2024

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, is critical towards the proposal of the Commission for a new Regulation on the screening of foreign investments. Below you will be able to find our non-exhaustive feedback: - VDMA believes that foreign direct investments are beneficial to the EU and its Member States, as they support the economy, employment and competitiveness in the EU. The EU needs to remain open to these investments and the EU needs to avoid any legal uncertainty and bureaucracy in this area. Moreover, we are of the opinion that the proposal comes too soon; more time is needed to evaluate the effectiveness of the current framework. - The proposal identifies a minimum sectoral scope where all Member States must screen foreign investments. This includes for example a common list of dual-use items subject to export controls and additive manufacturing. Such sectoral scope will increase in our view the number of notifications and the corresponding administrative burden and legal uncertainty for machinery companies producing dual-use-items this is quite opposite to the goal of the Commission, to support a European dual-use-industry. - The proposal lays down deadlines and procedures for providing comments and opinions on notified foreign investments. Many of these deadlines are too long and, therefore, need to be shortened so that our companies will have legal certainty. One deadline is for example 45 calendar days. - The proposal foresees an own-initiative procedure for cases of foreign direct investments, which have not been notified to the cooperation mechanism. Member States and the Commission shall be granted at least 15 months, after the foreign investment has been completed, the right to open this procedure. This leads as well to legal uncertainty, as it concerns an ex-post review procedure.
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Response to Recommendation to monitor outbound investments for further risk assessment

17 Apr 2024

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, is critical towards the Recommendation to monitor outbound investments for further risk assessment. Below you will be able to find our non-exhaustive feedback: - VDMA believes that European investments abroad do not jeopardize public security and order in the EU. Insofar as they are linked to technology transfer, the EU's security interests are already protected by export controls on sensitive technology. In addition, European foreign investments are necessary to improve the international competitive position of European investors. Regulatory measures to monitor outbound investments will only lead to additional administrative costs for our member companies. - The proposal to monitor investments of any kind by natural or legal persons creates a massive administrative burden to potential investors, without any perceptible utility. This broad measure could potentially restrict economic freedom and negatively impact the competitive advantage of EU investors. - The geographic coverage for monitoring outbound investments should not exclude any country, and no countries should be treated on favorable terms. The mentioning of Member States should best prioritize their monitoring activities based on their assessment of the risk profiles of certain countries seems to suggest that there are certain third countries to be targeted by the monitoring.
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Meeting with Jutta Paulus (Member of the European Parliament)

16 Apr 2024 · Umweltpolitische Themen

Meeting with Elina Laurinen (Cabinet of Commissioner Thierry Breton)

29 Feb 2024 · European machinery industry

VDMA urges EU to cut GDPR red tape for SMEs

7 Feb 2024
Topic — The Commission is evaluating the application of the GDPR six years after its entry.
Message — The organization calls for a pragmatic application of rules to reduce burdens on smaller industrial companies. They advocate for abolishing excessive documentation requirements and providing better support through better-resourced regional authorities.123
Why — Lowering administrative overhead would reduce compliance costs and prevent innovation-inhibiting effects in mechanical engineering.45
Impact — Transparency advocates may find it harder to monitor compliance if documentation requirements are eased.6
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Response to Measures to reduce microplastic pollution

17 Jan 2024

The VDMA rejects the proposal published by the EU Commission in the present version for a regulation on preventing plastic pellet losses to reduce microplastic pollution for the following reasons. The companies concerned are already applying extensive measures to prevent the release of plastic pellets. A current study confirms low overall releases of plastic granulate into the environment. The proposed regulation establishes further reporting and documentation obligations for companies, thereby increasing the bureaucratic burden. The EU Commission only recently committed to simplifying reporting obligations for companies. The proposed regulation lacks clarity and concretisation in many areas. This leads to planning uncertainties for all stakeholders. Many small and medium-sized companies that use granulate in small quantities are directly affected by the requirements of the regulation. For these small and medium-sized companies in particular, further requirements (including reporting obligations, preparation of a declaration of conformity, etc.) are associated with high personnel and financial costs and are therefore disproportionate. The full contribution to the consultation can be found in the attachment.
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Meeting with Hildegard Bentele (Member of the European Parliament) and DHL Group and

15 Nov 2023 · “Ramp-Up of Green Fuels for Aviation and Shipping - An Opportunity for Climate Protection, Industrial Policy and International Cooperation” - Panelist

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

27 Oct 2023 · AI Civil Liability

Meeting with Matthias Ecke (Member of the European Parliament, Shadow rapporteur for opinion)

18 Jul 2023 · Kennenlernen; Net Zero Industry Act

Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

12 Jul 2023

VDMA represents 3,600 German and European machinery and equipment manufacturing companies. The industry stands for innovation, export orientation and SMEs. Below you will be able to find our non-exhaustive feedback: - VDMA believes that foreign direct investments are beneficial to the EU and its Member States, as they support the economy, employment and competitiveness in the EU. The EU needs to remain open to these investments and the EU needs to avoid any legal uncertainty and bureaucracy in this area. - VDMA is of the opinion that the European Commission must first evaluate the investment screening mechanisms at Member States and EU level before revising the FDI Screening Regulation. - VDMA does not see security risks by outbound investments of EU companies. Outbound investments of machinery producers are driven by technological necessities, or strategically to reach a competitive market share in the country concerned.
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German Engineering Association Urges Slimmer EU Sustainability Reporting Rules

6 Jul 2023
Topic — A consultation on the first set of European Sustainability Reporting Standards.
Message — The organization calls for a further reduction in reporting granularity to match the Commission's target for cutting administrative burdens. They also demand full interoperability with global standards to avoid duplicative requirements for European companies.12
Why — Reducing reporting complexity would lower compliance costs and free up internal capacities for actual sustainability measures.34
Impact — Investors and stakeholders lose clarity because excessive detail makes it harder to find useful information.5
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Meeting with Raphaël Glucksmann (Member of the European Parliament)

14 Jun 2023 · International Trade

VDMA Urges Flexible EU Taxonomy for German Machinery Sector

3 May 2023
Topic — The initiative establishes a classification system for sustainable economic activities to guide investment decisions.
Message — The VDMA calls for a framework for enabling activities and a three-year chemical reporting lag. They also want technical criteria expanded to include more energy-efficient motor technologies.123
Why — This would ensure engineering firms keep access to green funding while avoiding unmanageable reporting timelines.4
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Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

2 May 2023 · AI Liability

German engineering association VDMA warns against EU packaging bans

24 Apr 2023
Topic — The EU Commission is reviewing packaging rules to improve recyclability and reduce waste.
Message — VDMA requests harmonized EU regulations to replace national rules and opposes bans on specific packaging formats. They advocate for gradual recycled content targets and reusability exceptions for custom industrial transport packaging.123
Why — Uniform standards and exemptions would protect established business models and maintain industry jobs.45
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Meeting with Pascal Arimont (Member of the European Parliament, Rapporteur)

9 Mar 2023 · Revision of the Product Liability Directive

Response to Revision of EU Ambient Air Quality legislation

3 Mar 2023

VDMA expressly supports the efforts of the EU Commission to further improve air quality in the EU. Updating the EU air quality directives makes sense but must be carried out with the appropriate sense of proportion. Within the framework of this position paper, we have outlined various aspects and issues that must definitely be taken into account when drafting the legislative text. First of all, a comparable and reliable database on air quality in the EU must be created. An EU-wide comparability of measurement data is a basic prerequisite for effective measures to improve air quality. Furthermore, sufficient time must be allowed for the development of such a complex law with far-reaching effects. Likewise, the time until 2030 is too short to implement effective and efficient air pollution control plans at the national level. Finally, the relevance of this new regulation for subsequent source emission legislations should not be underestimated at all. These would presumably have to be massively tightened to avoid possible immission limit value exceedances, but without clear quantification of their respective contribution to the immission situation itself. If the regulations now presented were to come into force unchanged, cities, municipalities and regions would be required to take appropriate measures within the shortest possible time in order to be able to comply with the new limit values. These would be, for example, stricter entry bans for motor vehicles, the reduction of opportunities to set up industrial production, as well as more extensive regulations for already existing production facilities and, associa-ted with this, the real risk of production relocations to non-EU countries. In detail, it might be immensely difficult or impossible to decide which of the potential sources is actually responsible for identified limit value exceedances. The revision of the EU air quality directives should therefore be carefully considered and » reflect the technical-economic realisation/feasibility, » not slow down the transformation of industry through highly ambitious limit values, » build on a broad and comparable database (e.g. standardise locations of measuring stations across the EU, take topographies into account), » include the technical limitations of the measurement equipment (e.g. measurement uncertainties/drift), » take into account the scope and limits of the source emission regulations, » identify natural emission sources and their contribution to the immission situation and take this into account when designing limit values, and » identify and ensure fair burden sharing between the different emission sources.
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Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and Bureau Européen des Unions de Consommateurs and

27 Feb 2023 · Stakeholder consultation on the Cyber Resilience Act

Response to Development of Euro 7 emission standards for cars, vans, lorries and buses

9 Feb 2023

The VDMA represents more than 3,500 German and European mechanical and plant engineering companies. The industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany. In the European Union, it represents a turnover volume of an estimated 770 billion euros. Around 80 percent of the machinery sold in the EU comes from a manufacturing plant in the domestic market. Overall, the VDMA welcomes the goal of clean ambient air for all EU citizens. For effective improvement of air quality, a common understanding of this topic, including a comparable and broad data basis, is mandatory. The introduction of a new emissions stage for passenger cars and light commercial vehicles makes sense, especially with the background of technological openness regarding drive systems we have repeatedly called for. The current design of the Euro 7 standard lacks planning and investment security for companies (decisive parts of the legislation are only defined by delegated acts), a clear commitment to climate protection (climate-neutral eFuels must be explicitly favored) and - within the given time - technical-ecological feasibility. The Euro 7 proposal thus jeopardises jobs as well as healthy and innovative companies along the entire value chain for combustion engines without any time constraints.
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Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis)

8 Feb 2023 · GCC trade barriers for EU machine exports

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

8 Feb 2023 · preferential trade agreements; transatlantic trade relations; importance of conformity assessments for machinery sector

Meeting with Svenja Hahn (Member of the European Parliament)

18 Jan 2023 · Transatlantic trade, Inflation Reduction Act, Due Diligence

Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Bundesverband der Deutschen Industrie e.V. and ZVEI e.V. - Verband der Elektro- und Digitalindustrie

13 Jan 2023 · Standardisation Strategy

Response to Single Market Emergency Instrument (SMEI)

16 Dec 2022

The Mechanical Engineering Industry Association (VDMA) represents over 3.500 mechanical engineering companies in Germany and Europe. Below you will be able to find the non-exhaustive feedback of VDMA to the Commission proposal of 19 September 2022 for a Regulation establishing a Single Market Emergency Instrument and repealing Council Regulation 2679/98/EC: VDMA welcomes the provisions proposed in Articles 16 and 17, which ensure the free movement of goods and persons in the Single Market. Posted workers are for example needed during a crisis to install, operationalize, service and maintain key machines, such as pharmaceutical machinery. VDMA believes that many definitions are too broad and too vague. One can for example think of the definition of crisis as laid down in Article 3 (1), the wording significant impacts of a crisis on the functioning of the Single Market and its supply chains as mentioned in Article 2 (1) and the definition of Single Market emergency in Article 3 (3). VDMA is of the opinion that businesses should be more involved, e.g. as a fixed member in the advisory group; Article 4 (3) only mentions that representatives of economic operators or stakeholder organizations can attend the meetings of an advisory group as observers. VDMA worries about the provisions that economic operators have to provide confidential information. One can think of the provisions of Article 24. Providing information is an additional burden for companies that might hinder measures to adjust business operations for overcoming the crisis. Furthermore, the Commission is able to impose a fine to operators for failures to comply with the obligation to reply to mandatory information requests. VDMA is in principle against any interventions in relation to decisions on the supply chains of companies. This is against the entrepreneurial freedom. We are of the opinion that resilience should be based on a market economy, price signals and competition. Primary responsibility for finding ways out of supply chain disruptions lies with the industry. Article 27 foresees for example priority rated orders and Article 33 even goes further: The Commission may recommend that Member States implement measures to ensure the re-organisation of supply chains and production lines and to use existing stocks to increase the availability and supply of crisis-relevant goods and services. VDMA believes that, if the legislator is enforcing intervention in markets and business decisions of this depth, measures must be subject to a time limit, clear criteria, and an ex-post impact assessment. VDMA, therefore, welcomes the maximum period of 6 months as proposed in Article 14 (3). Moreover, Article 13 proposes qualitive indicators to be considered when assessing if a crisis is a Single Market Emergency. For example, we support that firstly, economic operators must be asked for solutions as described in Article 13 (1) (e). We are of the opinion, however, that the set of indicators should be further sharpened, for example by proposing quantitative thresholds or indicators. We also suggest that, after the deactivation of the Single market emergency, a mandatory ex-post impact assessment must be conducted to assess the proportionality and effectiveness of the measures and to analyse what has caused the crisis situation and which lessons can be learned for future situations. VDMA is convinced that the Single Market is essential but not sufficient for the resilience of the EU. Resilience can also be improved by the diversification and solidification of the global supply chains. The EU and its Member States should focus on putting in place the right framework conditions, which, for example, can be laid down via access to markets of third countries through an ambitious and open EU trade and investment policy.
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VDMA warns against excessive liability rules for machinery manufacturers

9 Dec 2022
Topic — The EU is updating liability rules for digital products and circular economies.
Message — VDMA requests excluding software and digital files from the new product definition. They also want to restrict liability to physical damage and maintain shorter limitation periods.12
Why — Limiting liability periods and evidence disclosure would reduce legal costs and risks.3
Impact — Consumers would find it harder to obtain evidence and claim compensation for injuries.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

11 Nov 2022 · Meeting with President Haeusgen to discuss Conformity assessment

Meeting with Cristina Rueda Catry (Cabinet of Executive Vice-President Valdis Dombrovskis)

19 Jul 2022 · Trade relations with Mercosur and with India

Meeting with Elina Melngaile (Cabinet of Executive Vice-President Valdis Dombrovskis)

23 Jun 2022 · EU-US trade relations

VDMA Demands Precise Definitions for Industrial Refrigeration Equipment

22 Jun 2022
Topic — The EU is revising legislation to limit climate-harming fluorinated greenhouse gas emissions.
Message — VDMA requests a clear definition of self-contained equipment to ensure correct product categorization. They also seek guidance on leak check requirements for complex refrigerant blends.12
Why — Clearer definitions would prevent immediate regulatory shifts and provide legal certainty for manufacturers.3
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Meeting with Jens Gieseke (Member of the European Parliament) and Siemens Energy AG

15 Jun 2022 · Austausch zur Industriepolitik

German mechanical engineering association VDMA urges narrower supply chain rules

18 May 2022
Topic — The EU is consulting on a directive regarding corporate sustainability due diligence obligations.
Message — VDMA proposes limiting the scope to direct suppliers and internationally recognized human rights standards. They also call for higher employee thresholds and the removal of civil liability for indirect business partners.123
Why — This would reduce legal liability risks and lower administrative monitoring costs for exporters.45
Impact — Environmental groups and people in the wider supply chain lose legal protections and accountability.67
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VDMA warns EU Data Act threatens industrial innovation

12 May 2022
Topic — New EU legislation governing the access and usage of industrial data.
Message — Data sharing should remain voluntary and based on private contractual freedom. The industry seeks exemptions for medium-sized companies to prevent excessive burdens. Proprietary trade secrets and industry-driven standards must be legally protected.12
Why — Exemptions would prevent smaller manufacturers from facing unscalable costs and legal risks.34
Impact — Independent service providers lose the right to access data for machine maintenance.5
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Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager)

3 May 2022 · Industrial and digital policy, digitisation, green transition

Response to Instrument to deter and counteract coercive actions by third countries

30 Mar 2022

The Mechanical Engineering Industry Association (VDMA) is in principle supporting the proposed „Anti-Coercion Instrument“ (ACI) of the EU under the condition, that this ACI is an integrative part of and coordinated with further EU legislative and non-legislative action to deter and counter foreign economic coercion. Coercive measures often start with low-level actions by coercive countries, often indirectly executed via company actions against EU companies (i.e. via boycott declarations). These kinds of coercive behaviour cannot be addressed by the ACI, as this instrument is too strong, not flexible enough and from a time perspective too slow for an adequate reaction at a micro-economic level (company to company). These micro-level actions are a strong burden for EU companies, but also have political consequences for EU Governments. Therefore, micro-level actions are often the main measure of a foreign economic coercion campaign. To deter and counter coercive actions on a micro-level, it is necessary to improve the existing EU Blocking Statute for coercive actions between EU companies. It is further necessary to enhance the EU Blocking Statute with a new instrument („EU Counter Blacklisting Instrument“) to address coercive actions by non-EU companies as well – in parallel to the intra-EU-system. In case EU companies will be attacked by foreign coercive actions, all EU instruments (including the ACI) can be applied, but they do not protect EU companies against negative economic consequences. Short-term financial losses are a big risk, before any counter measure might have a chance to take effect against the coercive measure. Therefore, it is necessary to create an EU instrument supporting EU companies under attack with financial resources to bridge short-term financial shortness („EU Resilience Fund“). Concerning the proposal for an ACI in detail, VDMA would like to comment as follows: - The draft proposal in general: the interaction of the ACI with trade policy instruments, such as the WTO dispute settlement procedure, is unclear. The ACI should clearly stipulate whether simultaneous application of both instruments is allowed, or whether the instruments may only be applied alternatively. - The draft proposal in general: VDMA proposes to adopt a rule according to Article 5 (4) (b) of Regulation 182/2011/EU. If a majority of EU Member States votes against ACI actions, there is not enough support for the instrument to justify a decision of the Commission at its own discretion. - Article 2 of the draft proposal: VDMA calls for integrating extra-territorial behaviour (legislation, non-legislative rules or measures of foreign countries) in the scope of the ACI. Furthermore, the ACI should not be limited to foreign measures, which are intended to influence EU legislative actions. Even without this intention foreign economic coercion can have a very strong influence on the behaviour of EU Member States. Therefore, the conditions of Article 2 (1) should be read as „or“ so that one condition is sufficient to declare foreign measures as „economic coercion“. - Articles 3 and 4 of the draft proposal: VDMA suggests mentioning deadlines for these EU actions. - Annex I of the draft proposal, especially the measures listed in points E, J and K: VDMA calls for not misusing existing restrictions, which were created for other specific reasons, i.a. protection of public health or environmental protection. Using them outside of their subject area will discredit all these measures. Furthermore, this misuse is not necessary to find effective sanctions to counter foreign economic coercion. - Annex I of the draft proposal: as long as it is not clear if and how the ACI will be positioned in a set of several coordinated EU measures against foreign economic coercion, a final evaluation of the sanctions catalogue is not possible. Therefore, VDMA will come up later with further comments on the proposed measures.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

First of all, VDMA thanks the European Commission for initiating this short sounding feedback opportunity. We appreciate the work which has already been done by the Commission so far and will further be invested during this important review process. The mechanical engineering industry would like to underline three main targets, which need to be tackled from while reviewing the RoHS Directive: Increase legal certainty, ensure coherence and maintain effectiveness. Speaking of increasing legal certainty, the following three aspects must be given priority from our point of view: a) The inclusion of assessment criteria for the exceptions listed in Article 2 that are transferable to the mechanical engineering. The legally secure assessment of the company's own products must be easily possible. b) The reduction of the previously high level of detail of the exemptions listed in Annex lll. c) Simplifying the provisions and procedures for granting and/or renewing exemptions and extending the relevant transition periods. By listing this issue we'd like to refer to the feedback of the RoHS Umbrella Industry Project (“the Umbrella Project”). Discussing the aspect that RoHS shoud be coherent with other environmental, chemical, and product-related regulations, VDMA would like to emphase these three importent issues: a) The compliance deadlines granted within related regulations must be much more realistic - as each product might be regulated / affected differently by the different legal texts. b) Regulatory cycles (including maximum validity periods of exemptions for example) must be aligned with typical industry product life and design cycles. c) Substitute availability, relevance of socioeconomic impact and status quo of innovations must be mandatory assessment criteria when granting and/or reviewing product- or substance-related exemptions. For further explanations and industry details, please have a close look at the attached VDMA statement.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

16 Feb 2022 · EU’s digital policy and the role of the mechanical engineering industry in and for the digital transformation

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

12 Jan 2022 · wichtige Rolle des europäischen Maschinenbaus für die digitale und grüne Transformation

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

29 Nov 2021 · EU Data Strategy and Data Act

Meeting with Lucia Bonova (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

29 Nov 2021 · Data Act

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans) and CO2 Value Europe AISBL

22 Oct 2021 · CCUS sector development in Europe

Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová)

18 Oct 2021 · Sustainable Corporate Governance

Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

7 Oct 2021 · Due diligence

Response to Amendment of the Blocking Statute

30 Aug 2021

Below you can find the non-exhaustive feedback of the Mechanical Engineering Industry Association (VDMA) to the combined Evaluation Roadmap and Inception Impact Assessment of the European Commission for the amendment of the Blocking Statute. Economic coercion by third countries against EU companies is a strongly growing problem. Foreign trade will be more and more affected by geo-political conflicts, in particular with China. To navigate successfully under these difficult political circumstances, companies in the EU need a reliable framework from the EU and its Member States. This includes measures against any kind of foreign economic coercion, in particular measures that have an extra-territorial effect (regulatory and non-regulatory nature, with direct or indirect effects). The EU Blocking Statute is important for the following reasons: - A Blocking Statute protects the sovereignty of the EU and its Member States under international law by preventing foreign legislation that aims to undermine the territorial sovereignty of the EU and its Members to legislate exclusively. - A Blocking Statute protects the legal order of the EU and its Member States against measures of foreign States that damage or undermine the credibility and reliability of this legal order. - The actual Blocking Statute protects EU companies from any damaging behaviour of other EU companies, if this behaviour is influenced by foreign sanctions. A future revised EU Blocking Statute should include all kind of foreign measures, which have extra-territorial effects. - A Blocking Statute protects EU companies in the event of legal sanction proceedings in foreign States (e.g. in the USA via the “doctrine of foreign sovereign compulsion”). To achieve this effect, a future revised EU Blocking Statute must – like the actual EU Blocking Statute – have been enacted for overriding political reasons, and EU companies must not have any influence on its scope. - A Blocking Statute provides the legal and political basis for retaliatory measures against non-EU companies, if they assist foreign States in enforcing their sanctions (or other coercive actions) directly or indirectly against EU companies or citizens. - A Blocking Statute reduces the chances of success and, therefore, the political utility of foreign sanctions, as less companies follow the sanctions. If, at the same time, the costs of sanctions are increased through retaliatory measures, the overall effect will be deterrence. The Blocking Statute should be amended as follows: - The scope of existing Blocking Statute does not fit any more to the geo-political situation. It should be extended to all kinds of foreign measures with extra-territorial effects, without the restriction of the actual Annex I. - The Blocking Statute is often perceived as not protecting, unfair and incriminating. The exception provision needs to be improved. Further amendments in detail are necessary. In general, bilateral reciprocal agreements with third countries should be concluded. This would improve the protective effect in favour of companies and increase the deterrent potential against the enactment and implementation of foreign extra-territorial measures. The Blocking Statute cannot achieve sufficient utility on its own. It must be accompanied by additional measures (regulative and non-regulative): - An EU retorsion instrument (counter blacklisting) is necessary to address companies outside the EU, if they act extra-territorial coercive against EU companies. - A financial support instrument is necessary to support companies in the EU, if they are sanctioned by foreign States or by foreign companies because of not following foreign extra-territorial measures. - Additional measures to keep international payment channels open, also in case of foreign economic coercion, should be considered. A European Export Bank can for example discharge existing European banks from payments with coercion risks.
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Response to Addressing distortions caused by foreign subsidies

20 Jul 2021

The Mechanical Engineering Industry Association (VDMA) represents over 3.300 mechanical engineering companies in Germany and Europe. The industry stands for innovation, export orientation, medium-sized businesses and employs around 4 million people in Europe, of which more than 1 million are employed in Germany alone. With 90.000 companies, the mechanical engineering is one of the largest industries in the EU economy. With an estimated 36% share of the world market, Europe is the largest producer and exporter of machinery and equipment. VDMA has been supportive of the European Commission’s efforts to examine subsidies from third countries more closely. Such subsidies distort production costs and thus influence competition in the Internal Market of the EU. They cause thus disadvantages for the European mechanical engineering industry. On the one hand, VDMA is concerned about several elements of the proposal of the European Commission from 5 May 2021 for a Regulation on foreign subsidies distorting the Internal Market. Below you will be able to find a non-exhaustive overview of the main areas of concern: - There are three tools with different thresholds and rules. This will increase the administrative burdens for our companies and legal uncertainty. VDMA has always supported a uniform EU legal instrument. - A foreign subsidy is unlikely to distort the Internal Market if its total amount is below EUR 5 million over a consecutive period of 3 fiscal years. We believe that this threshold should be lower. - There is the possibility of ex officio investigations, but we believe that sanctions in case of non-cooperation of companies must be avoided. - There are long limitation periods. - The Commission has far-reaching powers, e.g. inspections (even outside the EU under certain conditions). - The Commission can impose fines and periodic penalty payments, e.g. incorrect answer. - There is a retroactive application of the Regulation. On the other hand, VDMA supports the fact that the European Commission is solely responsible for the enforcement of this proposed Regulation. Moreover, the division with other current relevant EU instruments is at this stage clear.
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German engineering federation VDMA demands international sustainability reporting standards

13 Jul 2021
Topic — This consultation revises EU rules on how companies report environmental and social impacts.
Message — The VDMA demands alignment with international frameworks instead of unique EU-only standards. They argue mandatory requirements should apply only to capital market-oriented firms. Additionally, they seek delayed deadlines and the right to omit sensitive business information.123
Why — These changes would lower compliance costs and protect the global competitiveness of manufacturers.45
Impact — Environmental groups and investors lose access to standardized data from many industrial suppliers.67
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German engineering association VDMA opposes mandatory B2B data sharing

24 Jun 2021
Topic — EU legislation aiming to facilitate data access and ensure fairness among actors.
Message — VDMA demands that freedom of contract remains the central principle for industrial data exchange. They oppose mandatory sharing rules and suggest the EU adopt voluntary model contract terms.12
Why — This would protect their proprietary industrial knowledge and ensure returns on machinery investments.34
Impact — Technology giants lose a potential legal mechanism to gain access to industrial datasets.5
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 Jun 2021 · Exchange of views on: (1) policy framework conditions to overcome the crisis and ensure digital and green transformation; (2) regulatory issues where mechanical engineering has a specific concern (3) due diligence

Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

Executive summary To carry forward the success of the Ecodesign Directive, we recommend the following key principles to be respected when developing new sustainability requirements for products: • An impact assessment must always be conducted; • Ecodesign requirements must continue to be addressed on a product by product basis. No one fits-all solution. • Double regulation both at horizontal and product levels must be avoided; • The “SMERC" principle must be applied: requirements must be Specific, Measurable, Enforceable, Relevant and not harm the industry’s Competitiveness; • New requirements for products must follow the New Legislative Framework; • Requirements must be based on scientific assessment methods recognised through international standards; • The industry should be involved as early and as much as possible in the process; • Product requirements should be technology neutral; • Effective enforcement and market surveillance must be ensured. As to the cross-cutting aspects of the Ecodesign and energy labelling working plan 2020-2024: • Light-weighting 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 to the proposed ecological profile, data used to measure up against this ecological profile must be harmonized at EU level, comparable, available, updated, verifiable and enforceable. Data may vary by product or by sector. There are still open questions on how this will work on 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 products. 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 having only information requirements for recycling activities about scarce materials and critical raw materials and double regulation must be avoided.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

17 May 2021 · Euro 7

Meeting with Henrik Hololei (Director-General Mobility and Transport)

6 May 2021 · Fit for 55 Package

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

22 Apr 2021 · Sustainable Corporate Governance

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

31 Mar 2021 · ReFuelEU Aviation Initiative

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean) and FuelsEurope and

23 Mar 2021 · Renewable fuels to climate neutrality and economic growth

Response to Instrument to deter and counteract coercive actions by third countries

17 Mar 2021

The German Mechanical Engineering Industry Association (VDMA) is in principle in favour of the EU adopting an EU legal instrument to deter and counteract coercive actions by third countries. Coercive economic actions of third countries are fundamentally unacceptable for the SME-dominated German mechanical engineering sector. Below you will be able to find non-exhaustive feedback of VDMA to the Inception Impact Assessment of the European Commission: - The instrument is largely new territory for the EU. The export-orientated machinery sector highly depends on open markets of third countries and rules-based international trade. Therefore, protectionist measures under the guise of an anti-coercion instrument must not be taken under any circumstances. As the boundaries between anti-coercion and protectionism are fluid, the EU must act clearly with restraint when using this new instrument. - VDMA believes that the instrument must be guided by the principle that the best defence is a high deterrence for the coercive action of a third country. A high deterrence is for example achieved by increasing the cost of coercion as well as by reducing the probability of success of the coercion. The EU must also cooperate with like-minded countries so that the effects of the anti-coercive actions are highly effective. - VDMA suggests giving priority to countermeasures against extra-territorial designed measures of third countries. There is here a clear need for a new deterring instrument, as the EU Blocking Statute has not enough deterrent potential by itself. Concerning the instrument of an anti-coercion framework: VDMA suggests discussing with priority the option of “personal sanctions” against companies, entities and individuals as a reaction to coercive measures of third countries. Conceptionally this would be black-listing against black-listing. This also offers a good range of options to design the countermeasure along the intensity needed for an effective deterrence. - VDMA emphasizes that a regulatory instrument must be accompanied by non-regulatory measures to achieve adequate protection of the economy in the event of coercive measures. For example, EU companies that are directly targeted by extra-territorial sanctions face short-term financial bottlenecks. These should be covered by financial support, for example from a new “Resilience Fund”. To ensure that EU companies targeted by extra-territorial sanctions continue to have access to international payments and receive vital export-related financial services, a new “European Export Bank” could also be helpful. This Bank must have a business concept with a maximum of resilience towards foreign economic coercion. - VDMA also believes that the EU Blocking Statute must be reinforced so that EU companies are better protected from the extra-territorial application of laws of a third country. We have for example seen that this instrument is not working properly vis-à-vis Iran. SWIFT is for example ignoring the EU Blocking Statute. All European banks are ignoring it too, refusing financial services in relation to business with Iran. Moreover, telecommunication companies try to cut down their services to EU-customers with Iranian business relations. Providers of technical services for passenger elevators tried to act in the same way.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and FuelsEurope and

1 Mar 2021 · European Green Deal

Response to EU strategy for sustainable textiles

1 Feb 2021

VDMA and its members welcome the ambitious sustainability and climate policy ambitions of the EU and to focus the aims for the EU textile and apparel industry in a sector specific strategy. The new framework and market conditions should facilitate progress in the sustainable transformation of the textile production and processing industry in the EU as well as supporting competitiveness and resilience of the sector. The circular economy must lead to sustainable economic growth in the EU. Careful and realistic targets, clear planning horizons are prerequisites as support for investments as well as research and innovation. The textile production and processing industry is a global and very competitive market, covering worldwide diversified and fractured value chains and an inexhaustible range of products. The new strategy should take into consideration the system boundaries of the interconnected and multistep value chain of textile production and processing industry. Any new measurements that draw to the future opportunities of a sustainable textile economy have to be checked with scrutiny to avoid conflicts of objectives. The EU must find the right level of legal regulation, a level playing field that sets fair rules for sustainability with which European companies can nevertheless increase competitiveness internationally. The mechanical and plant engineering industry is committed to the described way forward and is an indispensable partner in this transition. VDMA members have been very active in recent years and have shown keen interest and commitment to making the industry more sustainable, focusing on developing and providing more efficient and cutting-edge technologies.
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VDMA seeks exemptions for existing industrial data sharing

28 Jan 2021
Topic — This initiative creates a legislative framework for governance of common European data spaces.
Message — The VDMA requests that current B2B data-sharing arrangements remain outside the regulation's scope. They advocate for specific exemptions for IoT devices and small, closed data networks.123
Why — The industry would avoid new administrative burdens and maintain control over its data.45
Impact — New data-sharing platforms could be blocked from accessing information within closed industrial circles.6
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

22 Jan 2021 · Discussion on upcoming proposals on sustainable fuels, in particular sustainable aviation fuels

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Der VDMA Fachverband Power Systems und seine Arbeitsgemeinschaften vertreten die Hersteller und Zulieferer von Strom- und Wärmeerzeugungsanlagen. Dazu zählen Motorenanlagen, Thermische Turbinen und Kraftwerke, Speicher- und Sektorkopplungstechnologien sowie Wasserkraft- und Windenergieanlagen. VDMA PS bedankt sich für die Gelegenheit zur Stellungnahme. Die EU-Taxonomie stellt einen positiven Ansatz, um ein gemeinsames Verständnis von nachhaltigen Investitionen und wirtschaftlichen Aktivitäten zu definieren. Für den Maschinen- und Anlagenbau ist es entscheidend, dass alle Technologien, die zur Emissionsminderung beitragen können, weiterhin Zugang zu Sustainable Finance haben müssen. Europa braucht eine flexible Taxonomie, die von Unternehmen aller Größenordnungen genutzt werden kann, insbesondere ohne großen bürokratischen Aufwand, und die gleichzeitig klar genug ist, um Greenwashing wirksam zu verhindern. VDMA PS ist besorgt, dass der Vorschlag den Beitrag der Stromerzeugung und der Kraft-Wärme-Kopplung mit gasförmigen Brennstoffen-womit nicht nur Erdgas, sondern auch klimaneutrale und erneuerbare Gase gemeint sind - zum zukünftigen dekarbonisierten und integrierten Energiesystem nicht ausreichend anerkennt. Hier möchten wir folgenden Punkte hervorheben: 1.Stromerzeugung und Kraft-Wärme-Kopplung mit klimaneutralem und erneuerbarem Gas sind nachhaltige Aktivitäten und müssen wie andere erneuerbare Energien als Art10(1) Aktivitäten eingestuft werden. Der Vorschlag ignoriert die Fähigkeit von Gaserzeugungstechnologien, mit verschiedenen Arten von Gasen zu arbeiten, unabhängig von deren fossilem oder erneuerbarem Ursprung, und diskriminiert daher die Nutzung sauberer gasförmiger Brennstoffe gegenüber anderen Arten der sauberen Stromerzeugung und KWK. Dieser Ansatz sollte auch auf die Stromerzeugung und KWK mit Biogas angewendet werden. 2.KWK mit gasförmigen Brennstoffen als Übergangstätigkeiten benötigen einen realistischen Ansatz. Kraft-Wärme-Kopplungs-Anlagen tragen mit ihrer hohen Energieeffizienz zur Abschwächung des Klimawandels bei. Anreize für eine schnelle Umstellung auf saubere Gase lassen sich am besten durch die Definition eines Emissionsziels setzen, das mit einem Durchschnitt über die Lebensdauer der Anlage verbunden ist. Ein realistischer Schwellenwert von 250g CO2e/kWhe im Durchschnitt über die Lebensdauer der Anlage (Aufteilung der Emissionen auf Wärme & Strom über die Wärmebonus-Methode) bietet ein solches ambitioniertes Ziel für den Übergang. Dieser Ansatz steht im Einklang mit der Energiekreditpolitik der Europäischen Investitionsbank. 3.Stromerzeugung und Kraft-Wärme-Kopplung mit gasförmigen Brennstoffen brauchen angemessene "do not significant harm"-Kriterien (DNSH) Der vorgeschlagene Schwellenwert von 270 g CO2e/kWh berücksichtigt weder den Einsatz der besten verfügbaren Technologien (BVT) von reinen Gasverstromungsanlagen und KWK-Anlagen noch die zunehmende Verfügbarkeit von klimaneutralen und erneuerbaren Gasen. Die THG-Emissionen hängen vom CO2-Gehalt des gasförmigen Brennstoffs und dem Wirkungsgrad der Anlage ab. Dementsprechend sollten sich die DNSH-Kriterien auf die Energieeffizienzstufen beziehen, die im Durchführungsbeschluss (EU) 2017/1442 der Kommission als beste verfügbare Techniken definiert sind. 4.Die Herstellung von Mehrzweck-Energietechnologien darf nicht benachteiligt werden. Der Vorschlag erkennt nicht an, dass es Energietechnologien gibt, die eine Vielzahl von Anwendungen haben - sowohl erneuerbare als auch nicht-erneuerbare. Diese dürfen nicht diskriminiert werden, wenn sie in erneuerbaren Anwendungen eingesetzt werden, und ihre Herstellung muss als Ermöglichungstätigkeit angesehen werden. 5.Die Herstellung anderen kohlenstoffarmen Technologien muss auch Technologien für Übergangstätigkeiten umfassen Die Herstellung zukunftssicheren Technologien, die in Übergangstätigkeiten eingesetzt werden, muss als Ermöglichungstätigkeit aufgenommen werden (Artikel 10 Absatz 1 Buchstabe i)).
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis)

9 Nov 2020 · Sustainable finance taxonomy

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

9 Nov 2020 · Taxonomy

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

30 Oct 2020 · AI Civil Liability

Response to Addressing distortions caused by foreign subsidies

29 Oct 2020

The German Mechanical Engineering Industry Association (VDMA) is in favour of the European Commission taking a closer look at subsidies from third countries. These subsidies distort production costs and influence competition in the EU’s Internal Market. They create thus disadvantages for European market players in the mechanical engineering industry. Consequently, VDMA has been calling for more transparency in this area for some time. VDMA believes that efforts to tackle illegal State subsidies should be first and foremost done at the multilateral WTO-level. Therefore, we support the EU proposal on transparency and subsidy notifications at WTO level, including the creation of a general presumption according to which, if a subsidy is not notified to the WTO by the State giving the subsidy, it would be presumed to be an illegal subsidy. In this case, the State concerned would need to prove that the measure is not an illegal subsidy according to the WTO rules. Moreover, retaliatory measures against a State, which does not notify a subsidy, can be introduced. We also support to address the issue of subsidies from third countries via bilateral and regional trade agreements of the EU, e.g. the ongoing negotiations between the EU and China on an investment agreement. Therefore, we are in principle supportive of Option 3 on “addressing foreign subsidies through international rule-making”. VDMA supports the introduction of one uniform legal instrument with which third country's subsidies and aid of EU Member States would be equated. This instrument should not consist of several modules and should intervene in the case of all third-country subsidies which, as a Member State measure, would violate Article 107 (1) TFEU. Moreover, only the European Commission has the responsibility for its enforcement. There should also be a presumption with undertakings from third countries where the State has capital ownership above a certain threshold (for instance 20%) that measures are taken with regard to them which would violate Article 107 (1) TFEU as a Member State measure. This means that VDMA can support under certain conditions Option 2 on “take legislative action at EU level”. Below you will be able to find a non-exhaustive overview of these conditions: • VDMA is of the opinion that this uniform legal instrument should not create red tape for EU companies. At the same time, we would like to underline that the intellectual property rights and the know-how of our mechanical engineering companies need to be protected. Moreover, the investigations must be carried out in a short and pre-set timeframe. • We believe that a new subsidy instrument should not collude with already existing EU instruments, such as the "Foreign Direct Investment Regulation", State aid control and EU Directives on public procurement. We would also like to underline that the EU must remain open to foreign investment from third countries. • VDMA believes that the thresholds of such a uniform instrument should be appropriate. EUR 100 million seems for example quite high for investments in the mechanical engineering industry. This might lead to concentrations or takeovers “below the radar“. • We also question the EU interest test. To our understanding the criteria are often not clear and leave a lot of room for interpretation. • VDMA prefers to have a system whereby an investigation is only launched after a company puts forward a complaint regarding an illegal subsidy of a third country to the competent authority. We are not in favour of ex officio investigations.
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Response to Intellectual Property Action Plan

10 Aug 2020

The German Mechanical Engineering Industry Association (VDMA) represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of EUR 230 billion (2019), the sector is the largest industrial employer and one of Germany’s leading sectors of industry overall. VDMA welcomes the opportunity to provide feedback to the Roadmap of the European Commission on an intellectual property action plan. VDMA supports such an action plan, but more attention should be given to the uptake of intellectual property rights by SMEs and the fight against piracy: Intellectual property improves the competitiveness of SMEs in the machinery sector and forms a possible source of income. However, SMEs need in our view more assistance to understand the complex landscape in the field of intellectual property. Moreover, costs and maintenance of intellectual property should be lowered, access should be easier and proceedings should become faster and of better quality. Intellectual property secures jobs and prosperity. Unfortunately, especially in recent years, the impression has often been created that the protection of intellectual property serves the interests of large companies and restricts the freedom of citizens. It should be a priority of the European Commission to ensure that information is provided on how the protection of inventors, innovative companies, etc. benefits every single citizen in the European Union. The European Commission should also get more involved in general image campaigns that bring the benefits and the need for a strong and functioning IP system closer to EU citizens. According to the VDMA Study Product Piracy 2020, 74% of the companies in mechanical and plant engineering are affected by product piracy. In the case of companies with more than 500 employees, this share is even 90%. Among the infringements of intellectual property rights, unfair copying is according to this study in first place with 58%. The second place is shared by infringements of trademark and patent rights with 39% each. However, companies often do not know what technical options are available, or which measures are appropriate for their machinery or products: about half of all companies affected do not take any action at all. This is particularly true for SMEs, where two out of three companies do not take any measures. Therefore, we need an effective enforcement of intellectual property rights; SME require more support to combat violations of their rights in the EU and in third countries.
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German mechanical engineering industry urges voluntary data sharing framework

20 Jul 2020
Topic — The initiative establishes a legislative framework for governing common European data spaces.
Message — The VDMA argues that companies should decide themselves to what extent and under what conditions they share data. They call for industry-driven standards and the protection of intellectual property rights.12
Why — Maintaining freedom of contract prevents the exposure of sensitive trade secrets and protects investments.3
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Der VDMA sieht in der EU-Taxonomie einen positiven Ansatz, um eine gemeinsame Sprache für nachhaltige Investitionen und Wirtschaftsaktivitäten zu definieren und um Greenwashing zu vermeiden. Für den Maschinen- und Anlagenbau ist bei der Bewertung, ob eine Wirtschaftstätigkeit nachhaltig ist oder nicht von zentraler Bedeutung, dass es zu keiner Ausgrenzung von Technologien kommt. So müssen weiterhin alle Technologien die einen Beitrag zur Reduzierung von Emissionen leisten können, einen Zugang zu nachhaltiger Finanzierung erhalten. In dem bereits vorliegenden Bericht der Technischen Expertengruppe werden Technologien (Positiv-Liste) mit technische Kriterien zur Bewertung aufgeführt. Dabei sind zahlreiche Technologien aus der Investitionsgüterindustrie (Manufacture of Low Carbon Technologies) nicht als nachhaltige Wirtschaftsaktivität gelistet. Der aktuelle Bericht räumt dies auch ein, gibt jedoch keine Hinweise darauf, wie zukünftig damit umgegangen werden soll, eine Abbildung und Einbindung aller Technologien unter den technischen Kriterien zu ermöglichen. Denn unter dem Aspekt „Greening by“ leistet die Investitionsgüterindustrie in vielen Wirtschaftszweigen einen wesentlichen Beitrag zur Erreichung der Klima- und Nachhaltigkeitsziele. Für die Ausgestaltung der technischen Kriterien unter dem geplanten delegierten Rechtsakt muss es daher eine Ausweitung des Geltungsbereich und Einbindung aller emissionsarmen Technologien geben. Es ist der falsche Weg, dass Technologien, die bisher nicht in der Positiv-Liste aufgeführt sind, über aufwendige Produktlebenszyklusanalysen (wie über ISO-Normen oder den PEF) und durch die Zertifizierung Dritter ihre Netto-THG-Emissionsreduktionspotentiale aufzeigen müssen. Dadurch entsteht für Hersteller von klimafreundlichen Technologien, die bisher nicht gelistet sind, ein enormer bürokratischer Nachteil sowie eine zusätzliche wettbewerbsverzerrende Kostenbelastung. Gerade viele klein- und mittelständische Unternehmen können dies nicht leisten. Durch neue Innovationen und technologische Entwicklungssprünge darf es keine abgeschlossenen Technologieliste mit technischen Kriterien geben. Es braucht eine ständige Aktualisierung, um im Bereich der Entwicklungen nachhaltiger Wirtschaftsaktivitäten und emissionsarmen Technologien Schritt halten zu können. Daher spricht sich der VDMA dafür aus, dass die weitere Listung von Technologien permanent und auf unbürokratischem Wege möglich sein muss. Die Umsetzung der Taxonomie in die Praxis wird zu einer zentralen Herausforderung, wenn es zu einer Zunahme der Berichtspflichten kommt. Neben den freiwilligen, marktgerechten Informationen über Nachhaltigkeitsfaktoren legen Unternehmen bereits heute eine Vielzahl von Pflichtangaben im Rahmen ihrer finanziellen und nichtfinanziellen Berichterstattung offen. Insbesondere bei den größeren am Kapitalmarkt tätigen Unternehmen sind daher bereits in ausreichendem Maße Informationen zur Nachhaltigkeit verfügbar. Die EU-Taxonomie sollte daher nicht zu zusätzlichen Berichtspflichten veranlassen, die zu überproportionalen Kostensteigerungen für die Realwirtschaft führen. Dort wo weitere Informationen unabdingbar sind, sollte die EU Kommission über frei verfügbare Tools, Datenbanken und Berechnungssysteme Unternehmen unterstützen. Es besteht zudem die Gefahr, dass eine zusätzliche Hürde für die Finanzierung von Innovationen geschaffen wird und es zu Fehlallokationen kommt. Denn nicht immer lassen sich Innovationen oder Unternehmensgründungen im Frühstadium einer nachhaltigen Wirtschaftstätigkeit zuordnen.
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Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

1 Apr 2020 · Hydrogen and Green Deal

Response to A new Circular Economy Action Plan

20 Jan 2020

The Mechanical Engineering Association believes that the announced Circular Economy Action Plan under the Green Deal, offers the chance to not only prevent environmentally harmful products being placed on the EU market and creating a true secondary market for raw materials but also to foster Circular Economy business models. The European Union has become the global pioneer of Circular Economy approaches, creating a competitive advantage by utilizing circular economy thinking. What is important now is that concrete implementation is open, market-driven and globally connectable. Changing product and production requirements call for technological solutions supplied by the mechanical engineering sector, therefore the focus on sustainable products policy under the Green Deal is a chance. However, before applying any direct product regulation an evaluation of the material efficiency aspects needs be addressed in an holistic approach: • Differentiating consumer and industrial goods in the context of material efficiency is crucial. Incentive structures, customer behavior, customer relations, pricing, material composition and market dynamics distinguish both sectors. Therefore, VDMA strongly advises against any horizontal legislative requirement. To carry forward the success of the Ecodesign Directive, case-by-case assessment remains crucial. • The Ecodesign process offers an opportunity to determine the right approach on the product level with regard to conflicting objectives related to energy efficiency, safety legislation, durability and recyclability. These need to be addressed to avoid stranded investments in R&D and innovation. Companies require clear guidance from politicians about where they should put their emphasis. • Design requirements related to material efficiency deeply affect design choices and can lead to a high degree of standardization, significantly reducing technology options. Pushes for more standardization and legal requirements need to ensure that market opportunities for differentiation remain available. This is particularly significant in new markets such as repair services based on predictive maintenance. Therefore, it is even more important to uphold the basic principle of technology neutrality. • Focus on the full product life cycle to make Circular Economy a profitable and thereby appealing business model for many industries! At this point in time the mechanical engineering sector would benefit most concretely, if the European Commission could direct efforts of improving the availability of environmental information and tools towards gathering and providing free, average data on standard machinery components and parts and their environmental impact. Access to data on components and parts and their respective impacts is one of the highest barriers towards using LCA-based methods and spreading its use. The European Commission could further support improving and extending existing standards most commonly used. A specific focus should be on international standards, thereby ensuring international collaboration and harmonization. In order to increase the circularity of the EU’s economy, a well-functioning secondary material market is essential. One of the approaches discussed, is the option of implementing recycled content requirements to stimulate secondary raw materials markets. VDMA is sceptical that recycled content measures for all product categories are the silver bullet. Instead, reliable quality criteria for recycled content with clearly specified uses should be developed, to stimulate a secondary raw material markets on EU level. A major step in tackling the export of waste is needed. Therefore the VDMA welcomes the announced revision of the waste shipment regulation and supports the ban of exports of plastic waste to countries outside the EU with lower environmental standards.
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Meeting with Eugenia Dumitriu-Segnana (Cabinet of Commissioner Nicolas Schmit)

13 Jan 2020 · posting of workers

VDMA urges turning the Machinery Directive into a Regulation

5 Feb 2019
Topic — This initiative updates EU machinery safety rules to reflect recent technical and digital progress.
Message — VDMA supports aligning rules with the New Legislative Framework and creating a regulation. They oppose changing safety requirements for artificial intelligence. They also request digital product documentation.123
Why — Manufacturers would reduce administrative costs and benefit from uniform legal interpretation across Europe.45
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Meeting with Piet van Nuffel (Cabinet of Commissioner Marianne Thyssen)

25 Sept 2018 · Posting of workers

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

23 Apr 2018 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

VDMA Urges Simplified EU Road Approval for Mobile Machinery

12 Dec 2017
Topic — Uniform EU safety requirements for mobile machinery that occasionally uses public roads.
Message — VDMA calls for a full EU conformity procedure avoiding multiple national approvals. Most safety aspects should be self-tested by manufacturers to minimize administrative costs. High-volume automotive standards should not apply to specialized low-volume machines.123
Why — The industry would avoid redundant testing and significantly lower their compliance expenses.4
Impact — Independent testing bodies lose business as mandatory third-party certification is significantly restricted.5
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Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen)

5 Apr 2017 · Product regulation and market surveillance in the single market

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

10 Jan 2017 · Data localisation, free flow of data

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

23 Jun 2016 · Industry 0.4

Meeting with Markus Schulte (Digital Economy)

11 Apr 2016 · Digitising European Industry

Meeting with Günther Oettinger (Commissioner)

23 Feb 2016 · Telco policies

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

23 Feb 2016 · Dynamics and future challenges for the small and medium sized enterprises, including digitalisation.

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström)

24 Nov 2015 · TTIP

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič) and Bundesverband der Deutschen Industrie e.V. and

11 Sept 2015 · Energy Union Strategy with a forward-looking climate policy

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

3 Jun 2015 · Energy Union; energy efficiency; investment

Meeting with Markus Schulte (Digital Economy)

23 Apr 2015 · Industry 4.0

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

16 Apr 2015 · Introductory meeting

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

16 Apr 2015 · Present the association - intro meeting

Meeting with Karl-Friedrich Falkenberg (Director-General Environment)

19 Mar 2015 · Waste Management and Recycling Technologies

Meeting with Elżbieta Bieńkowska (Commissioner)

9 Mar 2015 · Introductory meeting

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová)

27 Feb 2015 · Digital Single Market

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

25 Feb 2015 · Ongoing Trade Negotiations

Meeting with Günther Oettinger (Commissioner)

25 Feb 2015 · DSM