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ZVEI e.V. - Verband der Elektro- und Digitalindustrie

ZVEI e.V.

ZVEI represents Germany's electrical and digital industry, advocating for innovation and technology solutions across electrification and digitalization.

Lobbying Activity

Meeting with Oliver Schenk (Member of the European Parliament)

29 Jan 2026 · Mikroelektronik und Kommunikationstechnologien in der EU

Meeting with Peter Liese (Member of the European Parliament) and Verband der Chemischen Industrie e.V. and

14 Jan 2026 · Austausch

Meeting with Peter Liese (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

8 Jan 2026 · Austausch

ZVEI seeks unified EU rules for smart TV prominence

18 Dec 2025
Topic — The Commission is evaluating the impact of EU audiovisual media service rules.
Message — ZVEI requests EU-wide harmonisation of functional requirements for prominence to prevent fragmentation. They advocate for software-based implementation that respects user choice and design autonomy.123
Why — Harmonised rules would reduce development costs and remove barriers to free movement.4
Impact — Member states lose the ability to implement divergent national solutions for media prominence.5
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Response to Classes for resistance to fire

17 Dec 2025

Dear Ladies and Gentlemen, please find attached the comments of ZVEI e.V. regarding the published draft of the delegated act. Best regards, Tim Dünnemann
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ZVEI urges simpler EU Taxonomy rules for digital industry

5 Dec 2025
Topic — The Commission is reviewing technical screening criteria for the EU Taxonomy environmental act.
Message — ZVEI requests aligning chemical rules with existing laws and simplifying reporting. They advocate for limiting supply chain data collection to direct suppliers. Additionally, they propose including industrial energy efficiency equipment in the scope.123
Why — These changes would lower administrative burdens and prevent technical products from being disqualified.4
Impact — The energy transition suffers if strict environmental thresholds exclude vital electrification technologies.5
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Meeting with Jens Geier (Member of the European Parliament)

4 Dec 2025 · Exchange on Industrial Accelerator Act and Grids Package

Meeting with Martin Lukas (Director Trade)

11 Nov 2025 · Follow-up meeting between DG TRADE- Directorate G and the German electrical and digital industries association (ZVEI)

Meeting with Peter Liese (Member of the European Parliament)

6 Nov 2025 · Austausch

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič)

17 Oct 2025 · EU – US relations

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

14 Oct 2025 · Simplification

German electrical industry urges major EU digital regulation overhaul

13 Oct 2025
Topic — EU Commission's Digital Omnibus initiative to simplify digital regulations and reduce business burdens.
Message — The organization requests sweeping changes across AI, cybersecurity and data laws. They want the AI Act simplified with sector-specific rules for industrial AI and transition periods tied to standards availability. For cybersecurity, they seek reduced reporting and documentation duties under the CRA. On data policy, they request moving GDPR from prohibition-based to risk-based approach and repealing general data-sharing obligations from the Data Act.1234
Why — This would reduce their compliance costs and accelerate their ability to deploy AI-enabled industrial products.56
Impact — Consumers and smaller businesses lose stronger cybersecurity protections and data access rights.78
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German electrical industry urges maintaining CO₂ fleet targets for 2030 and 2035

10 Oct 2025
Topic — EU regulation setting CO₂ emission standards for new cars and vans.
Message — ZVEI calls for maintaining the CO₂ fleet targets for 2030 and 2035 to provide planning certainty for companies that have invested in zero-emission technologies. They emphasize the need to expand charging infrastructure aligned with fleet limits and reduce electricity costs. The organization advocates for strengthening Europe's battery and semiconductor industries through extended support measures and streamlined approval processes.1234
Why — This would protect their members' investments in electric vehicle components and manufacturing capacity.56
Impact — Weakening targets would harm consumers by delaying climate protection and reducing innovation incentives.7
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Meeting with Jan Hendrik Dopheide (Cabinet of Commissioner Maroš Šefčovič)

23 Sept 2025 · International Trade

Response to Revision of the 'New Legislative Framework'

2 Sept 2025

ZVEI German Electro and Digital Industry Association welcomes the opportunity to provide input to the European Commissions Call for Evidence for a possible revision of the NLF. Please find attached our position paper.
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Meeting with Peter Liese (Member of the European Parliament) and Carbon Market Watch

27 Aug 2025 · Austausch

German industry group demands end to mandatory paper manuals

21 Aug 2025
Topic — An EU initiative to digitise product safety instructions and business contact details.
Message — ZVEI wants digital contact details to suffice instead of mandatory postal addresses. They argue against requiring paper safety instructions for consumer goods to improve sustainability. The group also seeks a wider scope of digital alignment across more EU laws.123
Why — Eliminating paper requirements would significantly reduce printing costs and administrative burdens for manufacturers.4
Impact — Consumers without digital access lose the guarantee of receiving physical safety instructions.5
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German tech industry urges digital-first approach for product information

21 Aug 2025
Topic — The consultation concerns updating EU product laws to allow digital documentation and instructions.
Message — ZVEI supports digital instructions but rejects mandatory paper copies for consumer products. They argue digital contact details should replace physical addresses to modernize communication. Additionally, they insist technical standards must be prioritized over government specifications.123
Why — Electronic-only documentation would reduce administrative burdens and streamline compliance for manufacturers.45
Impact — Consumers without digital access face long delays when requesting mandatory physical safety manuals.6
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ZVEI urges enforcement focus over new consumer regulations

5 Aug 2025
Topic — The EU is setting consumer policy priorities and enforcement strategies for 2025-2030.
Message — ZVEI urges the Commission to prioritize the enforcement of current laws over creating new regulations. They propose making digital consumer information the default standard and warn against legislative duplication in the digital sector.123
Why — This would protect companies from redundant regulations and reduce their administrative costs.4
Impact — Consumers without internet access might find it harder to obtain product information.5
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Response to EU label on product durability and EU notice on consumers’ legal guarantee rights

28 Jul 2025

ZVEI welcomes the opportunity to provide feedback on the draft implementing regulation under Article 22a of Directive 2011/83/EU (hereinafter also Consumer Rights Directive) as introduced by Art. 2 of Directive (EU) 2024/825 (hereinafter also Empowering Consumers Directive). To ensure that the regulation is both effective and practical to implement, and that it achieves its stated objectives, we would like to highlight the following points of concern and propose specific recommendations. Harmonised Notice ZVEI welcomes the inclusion of a QR code in the harmonised notice to offer consumers additional information. This feature has the potential not only to enhance transparency but also to support the principle of the free movement of goods within the European Single Market. However, we note that the draft proposal is very detailed and may risk overwhelming or confusing consum-ers. To improve clarity and usability, we recommend focusing on fewer but more prominent and clearly high-lighted core messages. This approach will help ensure that consumers do not overlook critical information due to excess complexity. In this context, the use of the QR code offers further advantages. It plays a key role in simplifying the notice while maintaining its informative value. Furthermore, we appreciate the inclusion of the producer guarantee of durability and its dedicated icon at the bottom of the notice. This visual element serves as an initial point of orientation for consumers and helps to establish a direct connection between the notice and the corresponding label. Harmonised Label ZVEI supports the harmonised labels EU-wide applicability. We consider the bilingual layout - with a language-neutral upper section and multilingual bottom section - to be effective in addressing the diversity of consumers across the EU. However, there is still a need for adjustment of the label: Design of the label Concerning the design, the icon displaying the letter G surrounded by EU stars is a well-chosen design el-ement, as it visually reinforces the link to the harmonised notice. Nevertheless, we question the use of the tick box icon in the GARAN symbol (symbol indicating that the goods durability is guaranteed), particu-larly because this symbol is also used in the notice where the associated conditions may differ. For the sake of consistency and clarity, we suggest reconsidering the use of this icon in both contexts. Handling small products Another point requiring clarification concerns products that are physically smaller than the minimum dimen-sions required for label placement (9,5cmx10cm). Even using the packaging for label placement may not always be feasible and could result in a disproportionate use of space. We propose that if the size of the product does not allow to place a label on the product, then the label should be placed on an accompanying document. Since the labels QR code directs consumers to a platform containing relevant durability information it would be logical and efficient to include translation and supplementary explanatory content within this digital layer. In this regard, we find the simplified, text-free label variant proposed for online sales particularly suitable and effective.
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ZVEI demands electronic waste exemptions to prevent double regulation

24 Jul 2025
Topic — This consultation defines waste streams with significant potential for critical raw materials recovery.
Message — ZVEI requests that electrical and electronic equipment be exempted from this regulation to avoid redundant rules. They recommend managing material recovery through existing frameworks like the WEEE Directive and the Circular Economy Act.12
Why — Exemptions would reduce administrative burdens and prevent costly, uneconomic requirements for low-concentration materials.34
Impact — The EU's raw material security suffers if electronics are excluded from recovery targets.56
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ZVEI urges repeal of mandatory EU data sharing rules

17 Jul 2025
Topic — A strategy to streamline data sharing rules and boost European digital competitiveness.
Message — ZVEI recommends repealing mandatory data sharing obligations to ensure voluntary exchange remains the standard. They request that industrial products already covered by safety laws be exempt from the AI Act. Additionally, they call for relaxing data protection rules to better support industrial innovation.123
Why — This would lower compliance costs and ensure stronger protection for valuable trade secrets.45
Impact — Smaller competitors and third-party services may lose guaranteed access to industrial data.6
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ZVEI demands regulatory simplification and fair competition in digital networks

11 Jul 2025
Topic — The initiative aims to improve access to secure, fast, and reliable digital connectivity.
Message — ZVEI requests reducing reporting obligations by half and removing unnecessary regulatory burdens. The group opposes a binding EU-wide copper switch-off date to protect technical realities. They demand a level playing field to secure the European industrial base.123
Why — This would lower administrative costs and protect European manufacturers from unfair competition.45
Impact — Non-European suppliers face potential trade barriers to address dumping and subsidy practices.6
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ZVEI rejects mandatory third-party audits for unsold product reporting

9 Jul 2025
Topic — EU initiative requiring businesses to disclose information on unsold consumer products they discard.
Message — ZVEI rejects mandatory third-party verification and requests clearer product definitions for reporting. They also call for extended transition periods to prepare and publish mandatory reports.123
Why — These changes would reduce administrative expenses and prevent excessive reporting burdens on industry.45
Impact — Environmental monitoring loses the accuracy and reliability provided by mandatory independent third-party audits.6
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Response to European Affordable Housing Plan

3 Jun 2025

The ZVEI welcomes the Commission's plan to support Member States and regional governments in overcom-ing the housing crisis in Europe. In addition to the rapid creation of new and renovated housing and the reduc-tion of factors that lead to an increase in housing costs, measures must also focus on the future requirements for buildings in terms of energy efficiency, climate neutrality, safety and life cycle costs. It is essential that new buildings and buildings undergoing extensive renovations are equipped with future-proof technologies. Electrical and digital technologies in buildings make an essential contribution to resolving the aims of affordability and climate neutrality. They enable participation in the energy system of the future and, through intelligent and effi-cient energy use, make an economical contribution to the reduction of costs related to building operation. The Commission's Affordable Housing Plan should therefore: Focus on the life cycle costs of buildings. support Member States and regional governments in equipping buildings with future-proof technology for new construction and extensive renovation and in creating the conditions for low-cost technical upgrades as part of the transition to zero-emission buildings (e.g. by laying empty conduits, e.g. for future broadband expansion). Consider the future role of buildings not only as energy consumers, but also as producers and storage facili-ties for electrical energy. Buildings should therefore enable bidirectional charging of electric vehicles, for example. Promote energy communities to increase participation in the energy transition. Promote quarter-based approaches, as this allows peaks in energy consumption to be better absorbed and sinks to be better utilized. Using the potential of serial and modular construction and the digital building twin to reduce construction site times, make production processes more efficient and utilize resources. Keep an eye on the continuous availability of digital processes (BIM), because this is the most efficient way to make information from the planning stage available throughout the entire production process right up to the construction site. Recognize the central role of standards for affordable housing, uniform safety and quality standards, while at the same time guaranteeing economic efficiency. As a reliable benchmark, standards contribute to the sensible and affordable design of buildings. Support framework conditions for sustainable heating to encourage the switch from fossil fuels to electric heating. The electrical and digital industry provides key technologies for a successful transformation of the building sector. It is important that these technologies are taken into account and considered in new buildings and ren-ovations. All stakeholders must bear in mind that all buildings must be zero-emission buildings by 2050. High costs due to necessary retrofitting and the associated social issues should be avoided as far as possible through a forward-looking approach by all parties involved. The ZVEI will be happy to discuss this in greater depth as the process of developing the Affordable Housing Plan continues.
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Meeting with Marion Walsmann (Member of the European Parliament)

3 Jun 2025 · Omnibus I

ZVEI Demands Phased Compliance and Spare Part Exemptions

13 May 2025
Topic — The European Commission is consulting on updates to the EU Deforestation Regulation.
Message — The association requests a 'stop-the-clock' mechanism to delay compliance until all rules are clarified. They also want exemptions for spare parts and small quantities of natural rubber.123
Why — This would significantly reduce the administrative burden of tracking thousands of minor electronic components.45
Impact — Regulators and environmental groups lose total visibility over all forest-risk materials in electronics.6
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Meeting with Angelika Niebler (Member of the European Parliament)

22 Apr 2025 · Simplification

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

12 Apr 2025

Please find the feeback of the ZVEI e. V. - the German Electro and Digital Industry Association - in the file attached.
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Response to Correcting act of Commission Regulation (EU) 2023/1670 laying down ecodesign requirements for smartphones and tablets

11 Apr 2025

Addition of an exemption for ATEX products Smartphones and tablets for Ex applications are a high technology niche, where European companies are currently leading worldwide manufacturers. Those Ex products are intended only for professional users in Ex environments. They are often used among others features for important communication and locating personnel in large facilities. Explosion-proof applications require special safety-related requirements (e.g. for repairs), some of which contradict the requirements under the Ecodesign Directive 2009/125/EC and now the Ecodesign Regulation (EU) 2023/1670. The regulation (EU) 2023/1670 specifies that the design of smartphones and tablets must enable repairs and that essential repairs can be carried out by generalists using standard tools. In contrast, ATEX equipment according to the corresponding directive (EU) 2014/34 must provide means to prevent the ignition of a potentially explosive atmosphere. This means that for example repairs (if any) may only be carried out by specialists with specific tools. Ex smartphones and tablets are not intended for the consumer market, nevertheless the regulation (EU) 2023/1670 does not exempt Ex products from the scope. As a result, the two laws contain contradicting requirements making it impossible for responsible manufacturers to comply with both simultaneously. Therefore, we suggest including appropriate exemptions under regulation (EU) 2023/1670 for products that fall within the scope of the ATEX directive: Article 1 Subject matter and scope 1. This Regulation establishes ecodesign requirements for the placing on the market of smartphones, other mobile phones, cordless phones and slate tablets. 2. This Regulation does not apply to the following products: (a) mobile phones and tablets with a flexible main display which the user can unroll and roll up partly or fully; (b) smartphones for high security communication (c) smartphones, other mobile phones, cordless phones and slate tablets subject to Directive (EU) 2014/34.
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Meeting with Barbara Bonvissuto (Director Internal Market, Industry, Entrepreneurship and SMEs)

9 Apr 2025 · Exchange on Digital and Innovation Policy

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

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

ZVEI Demands Deeper Cuts to Taxonomy Reporting Burdens

26 Mar 2025
Topic — The initiative updates EU Taxonomy rules to simplify sustainability reporting and reduce administrative costs.
Message — ZVEI requests a complete revision of chemical rules and longer transition periods. They also propose making operating expense reporting voluntary to reduce compliance efforts.1234
Why — This would lower compliance costs and remove technical barriers for digital manufacturers.567
Impact — Regulators lose detailed insights into the use of hazardous substances in industrial articles.89
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Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)

18 Mar 2025

Der ZVEI unterstützt voll und ganz die Ziele der kontinuierlichen Weiterentwicklung und umfassenden Umsetzung des Stockholmer Übereinkommens über POP und damit auch die Einführung eines UTC-Wertes für polychlorierte Biphenyle (PCB) im Rahmen der Anpassung der Anpassung der Verordnung (EU) 2019/1021 über persistente organische Schadstoffe (POP), um Rechtssicherheit auf dem europäischen Markt zu gewährleisten. Weitere Einzelheiten zu unserer Position sind dem beigefügten Dokument zu entnehmen.
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Meeting with Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

14 Mar 2025 · Critical technologies

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

14 Mar 2025 · Competitiveness and simplification

Response to Targeted technical update of EU rules on measuring instruments

3 Mar 2025

We appreciate the opportunity to provide our feedback through the 'Have your Say'-Portal. Please find attached the statement of ZVEI on the proposed amendment made through the text COM(2024)561 and its annexes.
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Meeting with Svenja Hahn (Member of the European Parliament)

19 Feb 2025 · Upcoming IMCO legislation

Meeting with Angelika Niebler (Member of the European Parliament, Delegation chair)

28 Jan 2025 · EU-India Relations

Meeting with Radan Kanev (Member of the European Parliament) and Orgalim – Europe's Technology Industries and

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

Response to Standards for wireless recharging, electric road system and vehicle-to grid-communication of recharging infrastructure

20 Dec 2024

Please find attached the statement of ZVEI on the proposed delegated regulation.
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Response to Review of ecodesign and information requirements for external power supplies (EPS)

16 Dec 2024

Feedback on the draft proposal to ecodesign for external power supplies (EPS) We welcome the opportunity to provide feedback of the final draft regulation laying down ecodesign requirements for external power supplies, wireless chargers, wireless charging pads, battery chargers for portable batteries of general use and USB Type-C cables, released on November 18th, 2024, by the Commission. With our comments, we would like to improve the draft text to achieve a clear understanding of the legal requirements for all parties involved. Please see the attached file for ZVEI amendments.
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Please find attached the feedback of ZVEI - German Electro and Digital Industry Association on the Call for Evidence on DPP Service Providers.
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Meeting with Oliver Schenk (Member of the European Parliament)

25 Nov 2024 · Elektro- und Digitalindustrie in der EU

Response to Targeted technical update of EU rules on measuring instruments

18 Oct 2024

Sehr geehrte Damen und Herren, bitte finden Sie anbei die Kommentierung des ZVEI e.V., Fachverband Energietechnik. Mit freundlichen Grüßen i.A. C. Lorenz
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Meeting with Andreas Glück (Member of the European Parliament)

16 Oct 2024 · PPWR

Meeting with Dóra Dávid (Member of the European Parliament) and European Forum for Manufacturing

4 Sept 2024 · Event: Promoting the Future of European Competitiveness

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Please find attached the feedback of ZVEI on the Waste Shipment Regulation e-waste classification.
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German digital industry warns against mandatory copper network switch-off

28 Jun 2024
Topic — EU consultation on scenarios for future digital infrastructure and connectivity investment needs.
Message — ZVEI calls for a flexible regulatory framework reflecting different technical realities in member states. They recommend a carefully planned migration path instead of a mandatory copper switch-off by 2030. The association seeks legally binding sustainability standards to create a level playing field for manufacturers.123
Why — This would shield European component producers from non-EU competition while reducing pressure on construction capacity.45
Impact — Non-EU manufacturers would lose their cost advantage due to mandatory compliance with European sustainability standards.67
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Meeting with Markus Schulte (Cabinet of Commissioner Iliana Ivanova)

18 Apr 2024 · - European Research and Innovation policy - Industrial competitiveness - Future of internal market

Meeting with Jens Geier (Member of the European Parliament)

16 Apr 2024 · Exchange on Expectations on the new European Parliament and EU Commission (EU Industry Policy, Global Trade, Green Deal, Energy Policy, Digital Agenda)

Response to Recommendation to promote the development of innovative forms of solar energy deployment

2 Apr 2024

Als Verband der Elektro- und Digitalindustrie begrüßt der ZVEI die Initiative zur Reduzierung von Hemmnissen für den Ausbau der Solarenergiegewinnung in Europa. Die lokale Energieerzeugung bietet ein großes Potenzial zur stärkeren Nutzung erneuerbarer Energien und zur damit verbundenen Reduktion von Treibhausgasemissionen. Um die Stromnetze angesichts fortschreitender Elektrifizierung zu entlasten, spielt die gebäudenahe Energieerzeugung eine unverzichtbare Rolle. In ihren Empfehlungen sollte die EU-Kommission sich bzgl. gebäudeintegrierten Fotovoltaikanlagen darauf fokussieren, die Abgabe von Solarstrom an Mieter sowie andere Haushalte im Quartier zu vereinfachen. Zudem sollten Netzentgelte für die Verteilung von lokal erzeugtem Strom im Quartier gestrichen oder stark reduziert werden. In Quartieren und Energiegemeinschaften kann durch Energy Sharing Energie effizient und lokal erzeugt sowie verbraucht werden. Nutzer von Energy Sharing profitieren wirtschaftlich durch Verkauf oder günstigeren Bezug erneuerbaren Stroms. Die Attraktivität der Investition in erneuerbare Erzeugungsanlagen wird erhöht und der Klimaschutz gestärkt. Durch Einführung eines lokalen Leistungshandel könnten eine Überlastung der Netze verhindert und Anreize zur Steigerung der Effizienz gesetzt werden. Zudem ist es wichtig, dass im Rahmen von Sanierungsvorhaben die zukünftige Installation einer PV-Anlage berücksichtigt wird. Die Kommission sollte Mitgliedstaaten dazu anregen, Maßnahmen zur Vorbereitung der Installation von zukunftsfähigen Technologien als festen Bestandteil der individuellen Sanierungsfahrpläne zu verankern. So können Nachrüstungen unter hohem Aufwand vermieden und der Ausbau von Solarenergie sozialverträglich gestaltet werden. Letztlich muss die Sicherheit beim Ausbau der Solarenergiegewinnung in Gebäuden gewährleistet sein. Mitgliedstaaten sollten dafür Sorge tragen, dass die elektrische Infrastruktur in Gebäuden für einen Anstieg der Stromerzeugung (bspw. durch Balkonkraftwerke) geeignet ist. Für einen Austausch zum Einsatz innovativer Technologien zur Gewinnung von erneuerbaren Energien stehen wir gerne zur Verfügung.
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ZVEI calls for technical expertise and longer chemical transition periods

27 Mar 2024
Topic — A proposal to streamline chemical safety assessments through specialized EU agencies.
Message — ZVEI wants ECHA to build technical expertise and requests direct meetings to avoid misinterpretations. They also call for longer transition periods of at least 24 months for rejected exemptions.123
Why — These changes would ensure industry planning security and reduce high costs of material verification.45
Impact — Environmental protection efforts are slowed when companies have more time to phase out hazardous substances.6
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Meeting with Rasmus Andresen (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · socio economic situation

Meeting with Daniel Freund (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · Exchange with economic associations

ZVEI demands recall template strictly follow EU safety law

19 Feb 2024
Topic — This consultation defines the mandatory elements and design of product safety recall notices.
Message — The organization requests that the template strictly aligns with the underlying regulation without adding extra requirements. They propose making instructions for stopping product use conditional and ensuring that incentives for consumers remain optional. They also suggest using more neutral language when asking users to share recall information.123
Why — This provides helpful design support for small businesses while preventing unauthorized compliance costs.4
Impact — Consumers may find recall notices less personal and engaging without direct sharing prompts.5
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ZVEI Urges Comprehensive GDPR Reform to Boost Innovation

8 Feb 2024
Topic — Evaluation of the General Data Protection Regulation six years after its application.
Message — ZVEI calls for a fundamental legislative reform to move toward an enabling data protection framework. They request rethinking the prohibition principle and simplifying rules for international data transfers.12
Why — Proposed changes would significantly reduce bureaucratic burdens and operational costs for businesses.34
Impact — Citizens could face higher privacy risks from looser standards regarding data re-identification.5
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Response to Enhancing research security in Europe

19 Dec 2023

ZVEI acknowledges the European Commissions concerns that the sharing of R&D results concerning sensitive technologies could jeopardize national security if used for military purposes or to suppress fundamental rights. We also welcome the fact that Europes research security is seen as one cornerstone of the European Economic Security Strategy. While the word industry or industrial research does not appear once in the provided Call for Evidence document it is not clear whether also industrial Research and innovation activities are in scope of this initiative. In times when R&D becomes part of the geopolitical realm, both public and private R&D entities need to properly address research security risks, ensuring that research and innovation activities are not misused in ways that affect the EUs security or infringe ethical norms. We must not forget that the success of the EU economy depends largely on its access to our export markets around the world. Any measures or activities driven by the EU which indicate or lead to restrictions related to the EU economys freedom to do business, or to perform research and innovation activities with, or in other countries, might lead to countermeasures taken by the affected countries, i.e. important export markets for European companies. Therefore, protective instruments must never be used to the detriment of European companies and European competitiveness. It is of utmost importance that the EU carefully considers any potential negative effects on EU-based companies. R&D conducting companies are well aware of the potential risk of exposing competitive relevant information in international R&D consortia. A resilient R&D landscape in Europe is best achieved through a strong, competitive, and innovative industry. We therefore recommend the financial expansion of all EU funding programmes that aim to fully exploit the economic and ecological potential and thus improve the competitiveness and resilience of R&D conducting companies on global markets. ZVEI also recommend to ake sure that any recommendations and/or guidelines planned to be developed under this initiative are applied in a harmonized way across all 27 EU Member States (avoiding a patchwork of different national recommendations or guidelines).
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Response to Drinking water - conformity assessment procedure

16 Nov 2023

The comments can be obtained from the attached document.
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Response to Drinking water - procedures and methods for testing and accepting final materials

16 Nov 2023

The comments can be obtained from the attached document.
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Response to Voluntary cybersecurity certification for ICT products, based on a Common Criteria set of security requirements

31 Oct 2023

ZVEI the German Electro and Digital Industry Association welcomes the opportunity to give feedback to the European Commission's public consultation on the implementing regulation for a European Common Criteria-based cybersecurity certification scheme for ICT products (EUCC) under the Cybersecurity Act (CSA), (EU) 2019/881. ZVEI's statement to the public consultation is attached. We remain at your disposal for any further clarification and questions.
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Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

28 Sept 2023

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

10 Aug 2023
Topic — A consultation on creating a framework for fair licensing of standard essential patents.
Message — ZVEI requests a balanced framework that increases transparency and reduces transaction costs. They demand that EUIPO evaluations be fast, transparent, and sufficiently funded.12
Why — Improved transparency helps members reach faster licensing agreements and reduces transaction costs.3
Impact — Patent holders lose revenue from disproportionate bans on back-payments for late registrations.4
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Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

21 Jun 2023

ZVEI, the German Electro and Digital Industry Association, welcomes the opportunity to contribute to the consultation on the amendment of the Delegated Regulation (EU) 2022/30 under Article 3(3) d,e,f of the Radio Equipment Directive (RED). We welcome the proposed extension and the efforts of the European Commission to ensure, that the much needed harmonised standards are developed, assessed and listed in timely manner and that industry has sufficient time to implement the requirements. Further thoughts can be found in the accompanying statement.
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Response to Review of the Broadband Cost Reduction Directive (Directive 2014/61/EU)

16 May 2023

Der ZVEI Verband der Elektro- und Digitalindustrie e.V. vertritt unter anderen die Hersteller der Gigabitnetz-Komponenten, wie Glasfaser- und Koaxialverstärker, Filter, Verteiler und Abzweiger, Glasfaser-, Koaxial- sowie Datenkabel. Als Zulieferer der Netzbetreiber liefern sie daher die Basis für den Gigabitausbau und sind am Prozess der Breitbanderschließung maßgeblich beteiligt. In Gebäuden und Rechenzentren ermöglichen ihre Produkte die Digitalisierung und Anwendungen wie Power over Ethernet. In diesem Zusammenhang treiben sie in Deutschland und Europa Technologien voran, die die Netze gigabitfähig machen. Wir begrüßen die Gelegenheit, zu dem kürzlich veröffentlichten Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates über Maßnahmen zur Verringerung der Kosten des Ausbaus von Gigabit-Kommunikationsnetzen und zur Aufhebung der Richtlinie 2014/61/EU (Gigabit-Infrastrukturverordnung) Stellung zu nehmen. Die Stellungnahme entnehmen Sie bitte der Anlage.
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German tech industry urges clearer EU Taxonomy for electrical equipment

3 May 2023
Topic — EU consultation defines environmental sustainability criteria for economic activities to guide green investment purposes.
Message — ZVEI requests clearer technical definitions for electrical equipment and more flexible software criteria. They argue for aligning chemical restrictions with existing laws to ensure regulatory consistency. Finally, they suggest removing reporting requirements for products sold through complex indirect channels.123
Why — Simplifying these rules would reduce compliance costs and prevent exclusion from green financing.4
Impact — Health and environmental advocates lose protections as industry seeks to maintain hazardous substance exemptions.56
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Meeting with Petra Kammerevert (Member of the European Parliament, Shadow rapporteur)

21 Feb 2023 · APAs - Media Freedom Act

Meeting with Petra Kammerevert (Member of the European Parliament) and Google and

1 Feb 2023 · European Media Freedom Act

Meeting with Birgit Sippel (Member of the European Parliament) and Google and

1 Feb 2023 · European Media Freedom Act (Staff-Level)

ZVEI Urges Centralized Cybersecurity Rules and Staggered Implementation Timelines

22 Jan 2023
Topic — The European Commission's proposal for mandatory cybersecurity requirements for products with digital elements.
Message — ZVEI wants the CRA as the primary reference to avoid overlapping regulations. They request a staggered implementation timeframe and clearer definitions for product criticality.123
Why — A unified framework would lower administrative costs and help manage severe staffing shortages.45
Impact — Consumers face risks from unpatched devices if implementation of security requirements is delayed.67
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Meeting with Svenja Hahn (Member of the European Parliament, Shadow rapporteur) and Bundesverband der Deutschen Industrie e.V. and Verband Deutscher Maschinen- und Anlagenbau e.V.

13 Jan 2023 · Standardisation Strategy

German digital industry warns AI rules will stifle European innovation

28 Nov 2022
Topic — EU proposal to update liability rules for damages caused by AI systems.
Message — ZVEI maintains that existing laws already address liability gaps for AI applications. They claim the proposal de facto constitutes a reversal of the burden of proof. The group warns these rules would massively hinder AI development in Europe.123
Why — Rejecting the proposal avoids a massive expansion of liability proceedings and compliance costs.45
Impact — Victims of AI damage would lose intended relief from their burden of proof.67
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German digital industry urges binding media prominence rules

10 Nov 2022
Topic — EU legislation to ensure media freedom and harmonize the internal market.
Message — The association demands binding rules for media prominence instead of non-binding guidelines. They insist that user interface customization must remain technically feasible for manufacturers. They also oppose regulatory intervention in device hardware and interface design.12
Why — Binding harmonization would prevent the need for costly, country-specific device designs.3
Impact — Member States lose the ability to impose unique national prominence requirements.4
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Response to Review of the Construction Products Regulation

12 Jul 2022

With the attached position paper, the ZVEI - Electro and Digital Industry Association wants to make a contribution to the consultation procedure for the proposal for a Regulation of the European parliament and of the council laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011. The ZVEI in general supports the aim to improve the implementation of requirements on construction products and to achieve a well-functioning single market for construction products. Especially the strengthening of uniform market surveillance and the efforts to improve the functioning of the notified bodies is considered as an important and necessary step towards an improvement of the CPR. We also support the increased focus on sustainability which is an important topic for the electrical and digital industry. However, in the view of the ZVEI, the current draft is too complex and falls short of the Commission’s claim to eliminate open questions and uncertainties that have arisen from today’s CPR. The changes in the definitions cannot eliminate previous misunderstandings and could rather lead to greater uncertainties in the implementation. Some of the points in the draft might lead to a considerable additional effort for all stakeholders in the supply chain, for example with regard to the declaration of performance. The current proposal includes a high amount of empowerments of the Commission. By allowing the Commission to draft delegated acts to implement the requirements of the CPR a high degree of uncertainty and risk is introduced as well as further complexity. Especially economic operators would have to deal with the need to comply to an ever-changing ruleset. The new CPR is much more complex, broadens its scope and does up to now not offer any way to solve the problem of the no-cited harmonised standards.
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ZVEI urges clear transition rules for phasing out SF6 switchgear

28 Jun 2022
Topic — Revision of EU rules to reduce emissions from fluorinated greenhouse gases.
Message — The association calls for clear transition periods and a standardized lifecycle carbon footprint assessment. They request defining 'placing on the market' by contract delivery date to avoid project delays. The industry also seeks to continue exporting systems with SF6 components to non-EU markets.123
Why — These changes would provide manufacturers with investment security and protect their international competitiveness.45
Impact — European system integrators would suffer if prohibited from exporting equipment to global markets.6
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ZVEI demands five-year extension for vehicle lead battery exemptions

27 Jun 2022
Topic — This consultation evaluates exemptions for hazardous heavy metals in end-of-life vehicles.
Message — ZVEI requests maintaining lead battery exemptions for five more years. They reject restrictions on higher voltage batteries citing a lack of alternatives.12
Why — This avoids immediate bans on products and provides time for technical transition.34
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Response to Sustainable Products Initiative

22 Jun 2022

With the attached paper we take the opportunity to comment on the draft Ecodesign Regulation (COM(2022) 142 final) published by the European Commission on 30 March 2022 as part of its Sustainable Product Initiative (SPI). We welcome that the EU Commission continues to pursue the ecodesign approach. The Ecodesign Directive has proven over many years to be a strong instrument for increasing the energy efficiency of energy-related products. Important approaches such as the product group approach, the study and life-cycle based methodology and the involvement of all relevant stakeholders in the process have contributed to this success. Nevertheless, we see difficulties in the implementation of the requirements by companies. We call for full consistency of regulations. There should be no overlaps, duplication of regulations or legal uncertainties. For example, we see a lack of consistency in relation to ingredients Also, regulation will only be successful if the requirements are the same for all market actors in the EU internal market - this includes both those based inside and outside the EU - and their implementation is adequately monitored by market surveillance authorities. Our focal points are: 1. Ensuring full EU harmonisation 2. Implementing product-specific measures 3. Continuing with the eco-design concept 4. Ensuring conformity assessment based on manufacturer's self-declaration 5. Maintaining committee procedure within the framework of Implementing Measures 6. Ensuring that harmonised standards take precedence over common specifications 7. Creating clear framework conditions for the digital product passport 8. Creating consistency in regulations, especially with regard to substances 9. Strengthening market surveillance 10. Considering repair index only under strict requirements 11. Allowing exceptions for destruction of unsold goods 12. Calculating PCF and PEF according to uniform methods 13. Creating a clear framework for the use of recyclates 14. Considering industrial products in green public procurement 15. Ensuring a system approach for industrial applications 16. Ensuring a holistic sustainability discussion 17. Involving all actors
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Response to Cyber Resilience Act

25 May 2022

The German Electro and Digital Industry Association (ZVEI) welcomes the opportunity to provide feedback to the Impact Assessment of the European Commission. Cybersecurity, as a cross-cutting task is a top priority at ZVEI in all its lead markets: Industry 4.0, energy, mobility, components, building, health and consumer electronics. Regarding the three main objectives laid out in the Call for Evidence, we would like to point out some general remarks: 1) “Improve the functioning of the internal market by levelling the playing field for vendors of digital products and ancillary services.” • First and foremost, ZVEI sees the need for action for a harmonised level playing field for all digital products in the single market based on the New Legislative Framework (NLF) to avoid fragmentation of cybersecurity requirements within the EU. But proportionality, appropriateness and a risk-based approach based on the intended use of the product are of essence. 2) “Enhance and ensure a consistently high level of cybersecurity of digital products and ancillary services […] secured throughout their whole lifecycle proportional to the risks” • Risk-based approach: Products, which intended use and operational environment exposes them to higher risk, should be addressed accordingly based on that risk. While it is impossible to secure all product groups against any possible misuse, the manufacturer has the ability of defining the intended use in terms of security (=security context that describes the operating environment and the required security measures in and on site). The use of the NLF and its conformity assessment procedures would allow for such an adequate addressing of those products, as it has already proven in other regulatory contexts. • Lifecycle: The principles of security-by-design and security-by-default should be adhered to as far as possible to ensure secure development, installation, operation and decommission of the product throughout its lifecycle. However, an operator or end user of a product needs to be considered as well as they are ultimately accountable for a secure operation. At the end of the day, it is about shared responsibility. 3) “Enable users to match the security properties of such products against their needs, including by enhancing the transparency of cybersecurity features” • A better understanding of users regarding cybersecurity features and a greater level of transparency is desirable. However, users have heterogenous demands and one needs to differentiate between professional users and amateur users. We would like to point out that cybersecurity requirements should account for the various stakeholders involved in the life cycle of a product (manufacturer, integrator, operator/end user). • Lastly, transparency needs to be limited to information that is of value to the user and that can be released externally. While technical documentation is exclusively provided to market surveillance upon request, the software bill of materials is for internal use only, since its external disclosure risks intellectual property of the manufacturer. Regarding the Policy Options laid out in the Impact Assessment ZVEI strongly advocates for Option 5 (“horizontal regulatory intervention”) together with the procedures described in Option 4 (i) (“self-assessment by default” […] plus “third-party conformity assessment for certain categories of products taking into account of such factors as intended use, functionality and or the nature of potential harm.”). • ZVEI expects self-declaration to be sufficient to demonstrate compliance for a large majority of the cases. But we also see that there may be some clearly distinguishable and defined cases, where a mandatory involvement of a 3rd party in the conformity assessment would be justified – e.g. in a critical application, which involves a higher security risk. But essential for such an involvement must be a clear definition of a critical application and the
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ZVEI Warns Data Act Risks Industrial Trade Secrets

13 May 2022
Topic — This consultation explores a new regulation for sharing and accessing machine-generated data.
Message — The group wants separate rules for business and consumer data. They demand stronger protection for trade secrets and a longer implementation period.12
Why — This would lower compliance costs and protect proprietary research from industrial competitors.34
Impact — Third-party service providers lose easy access to industrial data for new services.5
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Response to European chips act package – Regulation

9 May 2022

ZVEI welcomes the European Chips Act (ECA). Now is the right time for Europe to become globally competitive for investments in semiconductor technologies. The ECA addresses necessary issues regarding strengthening Europe’s competences in the microelectronics ecosystems as well as state aid for capacity building, while also introducing far-reaching and unprecedented market interventions which ZVEI deems to be not helpful. It is necessary that the Chips for Europe Initiative in pillar 1 targets European industry needs in an adequate manner. ZVEI calls on EU institutions to focus on IP design in EU’s key verticals like mobility, industrial automation, telecommunication infrastructure (6G), health, consumer electronics as well as smart home and energy. The Chips JU should allow for innovations across a wide range of technologies since “leading edge” varies strongly based on the application: In short, innovation cannot be measured in nanometres. R&D&I programmes should take rapid market uptake into account. Fast-track and/or ad hoc funding instruments are needed to address well-defined and impactful EU priorities. The definition of “‘first-of-a-kind’ in the Union” is one example for creating a global level playing field for investment in Europe. ZVEI welcomes that the scope is not restricted to certain technologies and/or node sizes, allowing for projects serving the EU economy’s mid- and long-term demands, where “mature node sizes” are key for innovations in EU’s key verticals. However, it is necessary that state-aid under pillar 2 is not limited to specific facility types but is open to the whole microelectronics ecosystem. From processors and memory to power electronics, MEMS, analogue, and sensors – from equipment and materials, over front- and backend to test and packaging. Furthermore, it is also necessary to scale in specific technologies beyond the first approved “first of a kind facility”, because it is highly unlikely that one facility alone will help Europe to reach the 20 percent goal of the EU Commission. Only this will develop the ecosystem in an accelerated manner, enhancing innovation and supply chain resilience. The definition of “crisis”” in pillar 3 is raising questions. The current semiconductor shortage is not caused by a crisis in chip production but is a consequence of rising demand for semiconductors needed during the pandemic response, coupled with significant fluctuations in chip demand of important sectors. It triggered a rippling supply-demand imbalance felt across the world. The current chip shortage, contrary to the Recital (1) of the ECA, is not a symptom of permanent and serious structural deficiencies in the Union’s semiconductor value chain. In fact, the current shortage is a global phenomenon and cannot be solely attributed to one region’s semiconductor ecosystem. The proposed measures of the “toolbox” are not reflecting the complexity and uniqueness of the semiconductor supply chain, the requirements of the users as well as the manyfold reasons why a shortage may occur. The suggested, static measures – priority-rated orders and joint procurement of chips – will not be effective in preventing supply disruptions. Today, an average car comprises approx. 1,000, a smartphone ca. 160 different chips. Chips are not “off-the-shelf” or “one-size-fits-all” products. In addition, chip factories are not homogeneous and only able to manufacture a specific range of node sizes and transistor technologies. New Open EU Foundries and Integrated Production Facilities would only be able to manufacture and supply a very limited number of the chips required. “Just-in-time” supply chains of downstream sectors are increasing the risk of disruptions since they do not reflect the long lead times for chip production (4-6 months). The focus should shift to instruments that can effectively help chip users to enhance their security of business continuity. Therefore, Pillar 3 should be revised entirely.
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Meeting with Axel Voss (Member of the European Parliament) and Konrad-Adenauer-Stiftung

28 Apr 2022 · Artificial Intelligence

Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

6 Apr 2022

General remarks on the European Standardisation System ZVEI welcomes the opportunity to provide feedback on the proposed Amendment to the Regulation (EU) No 1025/2012 European Standardisation. In general, we are of the opinion that the European standardisation system is set up the right way. We strongly believe in the mechanism of the New Legislative Framework and don’t see any necessity for general revision of our standardisation system. The NLF, with its approach of using harmonised standards to concretise abstract statutory requirements, has proven itself as an instrument for placing products on the market. Its outstanding importance also lies in its very broad application, which covers a large proportion of all non-food products. There is, however, an urgent need for a re-organisation of the process for drawing up harmonised standards. The German electro and digital industry need international standards in which Europe's requirements and positions are sufficiently reflected. The international and European standardisation organisations should therefore be the preferred place where standards, and especially horizontal ICT standards, are developed. Broad European consensus and speed should be ensured in this process. This will enable Europe to build a strong competitive position. The European standardisation system must continue to be embedded in the international standardisation system. Recommendations regarding the proposed amendment to the regulation 1025/2012 ZVEI supports the goal of the European Commission of “good governance” for the development of harmonised European standards. The national delegation principle has proven to be a well-functioning and inclusive process to provide “good governance”. As mentioned above, it is also of utmost importance that the European standardisation system is embedded in the international standardisation system. In the international ICT standardisation system, ETSI plays an important role, especially as organisational partner within 3GPP, which is very important for the German electro and digital industry and needs to be maintained. We therefore urge the Commission to evaluate the ETSI governance together with ETSI and find ways to adapt the processes to ensure a good governance for harmonised European standards while avoiding a de-coupling of ETSI in the international ICT standardisation system.
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Meeting with Damian Boeselager (Member of the European Parliament)

6 Apr 2022 · Data Act

Response to Ecodesign requirements for vacuum cleaners (review)

5 Apr 2022

As representative of Germany’s manufacturers of household appliances, ZVEI e.V. appreciates the possibility to comment on the European Commission’s call for evidence on the future regulation of vacuum cleaners. We sincerely thank you for considering our comments and are available for any of your questions. Please find a detailed statement attached. Thank you.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

The German electrical and digital industry association (ZVEI) welcomes the recast of the Energy Performance of Buildings Directive (EPBD). It presents a crucial opportunity to create a futureproof framework in all member states for new buildings and the renovation of the building stock. A climate neutral building sector is only feasible through a significant increase of the renovation rate and depth. Technologies to achieve this goal already exist and are continuously being improved. The growth of the renovation rate and depth needs to encompass a wider distribution of such advancements. In case of heating systems, the renovation rate needs to be at least six percent, five percent in case of lighting. Hence, plans of the EPBD regarding deep renovations – meaning extensive, deep, and futureproof renovation measures - are justified and important. In the short-term, Member states need to expand on their financial support schemes accordingly while guaranteeing them in the long term. A fast realisation of energy savings through renovations should be encouraged financially just as a particularly high reduction of emissions. Here are some points that we see as key to maximize energy performance improvements with the recast of the EPBD: • Minimum energy performance requirements should be economically feasible, linked to an event (e.g. a new tenant or a sale) and take existing requirements into account. • Efforts to improve data on the European building stock are highly welcomed. However, the administrative burden should be as low as possible to avoid hindering the realisation of renovations. This is also applicable for all documentation regarding buildings. • Data and documentation should serve to increase transparency about the energy performance of buildings as well as their digitisation-level • New standards and indicators (e.g. minimum energy performance standards, SRI) should be comparable within the union and applicable in every member state. • In line with taking emissions and energy usage over the life cycle of a building into account, the operation of technical systems should be monitored and optimised. • The topics of energy management systems and the state of electrical installations in existing buildings should be covered in a separate article. Let us work together to achieve climate neutrality by 2050 – the attached document provides an overview of key ZVEI recommendations for a revision of the EPBD.
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Meeting with Ismail Ertug (Member of the European Parliament, Rapporteur) and ChargeUp Europe

24 Mar 2022 · AFIR

Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

ZVEI thanks for the opportunity to comment in the context of this Call for Evidence. The electrical and digital industry sees the RoHS Directive as an effective tool for the restriction of hazardous substances in electrical and electronic equipment. A simple structure and easy-to-understand provisions have been the key success factors for the directive to become the international flagship for many RoHS-like regulations. Because of the directive´s continuous adaptation to technical and regulatory progress, RoHS has become increasingly complex over the past years. The identified inconsistencies and shortcomings can most probably only be solved by amending the legal text. We therefore support a targeted revision of the RoHS Directive. Major changes to the basic RoHS principles will imply significant adjustments for companies. Any changes to the legal text should therefore be justified by measurable simplifications and improvement of processes. The global flagship function of the RoHS Directive must not be lost. The splitting of exemptions into numerous sub-exemptions makes communication in the supply chain for the purpose of conformity assessment unmanageable. The exemption process needs to be improved in terms of timeliness and predictability, and with respect for granting appropriate (longer) transition periods in the event an exemption (renewal) request is rejected. Regarding the substance restriction provisions findings obtained during any of the assessments within other legislation should be considered when considering additional restrictions under RoHS. Parallel assessments with potentially different outcomes should be avoided. A lack of certain information should not automatically lead to a higher prioritization for restriction of a substance under RoHS. Only substances with a very specific significance for electrical and electronic equipment should be regulated under RoHS, provided that a specific risk is associated with the presence of these substances in electrical equipment. Regarding the coherence with other legislation unintended overlaps of different legislations should be eliminated from the European chemical’s legislation framework. A segmentation of substance restrictions into many different legal texts (REACH, RoHS, POP, Eco-design) should be avoided. Regarding the provisions for spare parts the principle of "repair as produced" should fundamentally be anchored in the RoHS Directive, so that spare parts for products with a long service life can also be maintained after subsequent changes to the exemptions and substance restrictions under RoHS. The conversion of the RoHS Directive into a regulation could improve Europe-wide harmonization of legal requirements and their implementation. The spirit of RoHS should not change as a result of the transformation into a regulation. RoHS must further be recognized internationally as a lex specialis for electrical equipment. The European Commission should further engage in the global harmonization of RoHS-like regulations. A repeal of the RoHS Directive would be counteractive to global harmonization. We strongly advocate the further coexistence of RoHS and REACH. In addition, the CE conformity assessment procedure can only be integrated into the REACH Regulation with difficulties. The Commission paper on the common understanding between the REACH and RoHS should be pushed even more in the focus of substance regulation. RoHS shall remain the central tool for regulating substances in EEE. The Eco-design Directive with its focus on requirements for resource and energy efficiency and the WEEE Directive regarding the separate collection and treatment of electronic waste focus on very different aspects than RoHS does. We sincerely thank you for considering our comments and are available for any of your questions. Please find a more detailed statement attached.
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Response to Review of the general product safety directive

4 Oct 2021

The ZVEI supports the objectives of the European Commission to better protect consumers and create better framework conditions for economic operators through the revision of the existing General Product Safety Directive (2001/95/EC). We see it as positive development, that the draft regulation is linked more closely to the harmonised legislation under the NLF, for example by standardising definitions and approaches for market surveillance. At the same time, the draft regulation significantly increases bureaucratic requirements for economic operators without creating any concrete added value for consumers and product safety, so that in many cases those requirements no longer seem proportionate. This applies in particular to consumer products which do not pose any identifiable risk (paper clips, ballpoint pens, etc.) and includes information requirements which, due to their lack of relevance, simply come to nothing. In addition to that, the current draft regulation not only significantly expands the scope of application through the revision, but also the risks covered by it, which now include cybersecurity. Based on these comprehensive changes, the envisaged transitional period for the application of the new regulation of only 6 months for economic operators does not seem feasible. Finally, the draft regulation contains a consumer's remedy claim in the event of a product recall, which, on the one hand, is out of system in the preventively oriented product safety law and for which there is no need at all due to comprehensive coverage by already applicable law. In our view, the following points are of high importance for the implementation of the GDSR: • Establish coherence with the New Legislative Framework and the Market Surveillance Regulation, but also with other sector-specific product regulations. This concerns in particular definitions and terminology but also the requirements for economic operators. • Market surveillance issues should be regulated exclusively in the new Market Surveillance Regulation 2019/1020 and not divergently in the present draft. • Observe proportionality between risk potential of products and bureaucratic requirements for economic operators. • Allow for adequate transition periods to enable manufacturers to prepare for the sometimes extensive changes to the directives, both in terms of safety requirements and bureaucratic requirements. • The distinction between consumer products and commercial products should not be made more complicated by softening the definition of a product under the new Regulation. • Any claims for remedy that are fundamentally alien to preventive product safety law are already comprehensively covered by European and national laws and must therefore be excluded from the scope of the Regulation. • Avoid double regulation with existing harmonised legislation. The detailed comments are included in the attached position paper.
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Response to Requirements for Artificial Intelligence

6 Aug 2021

ZVEI welcomes the ambitious goal of the EU-Commission to promote and facilitate the uptake of Trustworthy AI in Europe. The EU-Commission puts forward a proposal for a harmonised European approach addressing potential risks and uses of AI applications. We plead ​to also focus on the immense opportunities related to the uptake of AI. Every market access regulation such as the proposed AI Act, carries the risk of hindering innovation as it sets down requirements for the placing on the market of products including certain technologies. Therefore, each provision in the proposal needs to be carefully examined and justified in particular for its potential impact on innovation and technological development. AI research and development should be strengthened on a European level, experimental space (i.e. regulatory sandboxes) should be provided for, as well as fostering both the continuous evolution of the technology and the understanding of the associated risks. Next to promoting a trustworthy, human-centric approach that aims at tackling risks linked to the usage of AI-technology, a future-proof AI regulation should also facilitate innovation and promote the general goal of boosting AI development and deployment across businesses in Europe. Industrial artificial intelligence is already a key driver for securing the future of European and German industry in a competitive global environment. AI is used in many applications and domains, as well as in public and private sectors. The deployment of industrial AI can optimise production processes and enable new levels of efficiency. In this way, AI can also make a significant contribution to resource efficiency and sustainability. As an enabling industry at the interface between IT and production world, the electrical industry has a key role to play in facilitating and implementing artificial intelligence in different application contexts. ZVEI welcomes the risk-based approach whereby the applicability of stricter requirements for placing on the market and putting into service of AI-based products is limited only to high-risk AI systems. However, the legislator should carefully assess regulatory gaps, inconsistencies and redundancies when addressing AI as a technology in its entirety. Particularly, in the case of AI embedded in products, potential risks regarding product safety and security are already covered by existing harmonisation legislation,or by functional constraints, where products can only act within their intended purpose. ZVEI in principle supports the NLF (New Legislative Framework) approach taken by the EU-Commission referring to established methods of conformity assessment in existing Union harmonisation legislation (Annex II). However, the Commission proposal contains a large number of additional requirements and obligations as compared to the NLF and the EU legislation based on it. Specific justification therefore is necessary for those additional elements, since established Union harmonisation legislation has proved to be effective in addressing public interest protection issues. This horizontal AI regulation should be discussed together with the relevant harmonised and sector-specific legislation and hence, needs to be in line with, and should ideally refer to, the conformity assessment procedures such as defined by the NLF (cf. Decision 768/2008/EC). In this respect the NLF provides the important basis to reach the necessary consistency over the relevant pieces of legislation. The legislator should carefully review and narrow down the scope of the proposed AI regulation, as the currently proposed AI definition is much too broad. It would not only cover AI products, but also applications that use pure statistical and knowledge-based approaches used for conventional data analysis and software that has been well-established for a long time. Our detailed comments can be found in the attached paper.
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Response to Standardisation Strategy

5 Aug 2021

ZVEI - German Electrical and Electronic Manufacturers' Association - represents the interests of a high-tech branch with a very widely varied and extremely dynamic product portfolio. Question 1: Whether the current European standardisation system is fit for purpose to support European strategic interests: - Only an efficient and supportive European system can support strategic policy objectives, both in Europe and world-wide. - A European standardisation strategy cannot be regarded in isolation from the rest of the world, it must be integrated in the overall system. The objective is to get unified international standards as far as possible, therefore international cooperation is important to avoid market fragmentation. - Technological advantage and competitiveness can only be achieved by innovation. We need an innovation friendly environment which is supported on all levels by the European policy makers. Therefore, we welcome the EC’s approach to consider a standardisation strategy as part of an industrial strategy. - Technical standards of the ESOs should remain the only standardisation documents used in European legislation. Other deliverables like implementing acts, codes of conduct, or other technical specifications, e.g. by the JRC should not be used to replace standards. Question 2: How the EU can leverage and promote global leadership in standards-setting: - Leveraging and promotion only works via presence and active participation in all standardization processes, especially in international processes. - Therefore, key is to increase the attractiveness to contribute to standardization processes for European business, SMEs as well and all other stakeholders. - Facilitate a speedy process for the development of standards in new developing high-technology areas. Focus on high-quality and the inclusion of international recognized state of the art requirements. Speed is important, but not the one and only criterion. - Industry is the main user and therefore also the main driver of standardization. Industry must have a serious say in all discussions: Organize a European „Standards for Competitiveness Roundtable“ (SCRT) with industry organizations such as Orgalim, Businesseurope and other industry stakeholders. This roundtable should bring together the bottom-up approach on market-driven standards with the top-down approach of strategic policy interests. - Standardisation is the creation of strategic alliances. We need these also in the PPP with the regulator, the administration, and the economic operators, especially industry. Promoting European strategic interests and values requires joint forces. - On international level, EC can give two-fold political support: * promote the European model of NLF in the world, * promote the use of international standards in other countries and regions instead of creating technical barriers to trade by national or regional standards. This goes together with a European commitment to use international standards also for supporting European policies and legislation as much as possible. Question 3: Whether changes in governance and working methods are required to improve the performance of the European standardisation system: We recommend following changes: - Respecting the reflection of the world-wide state of the art written down in IEC Standards, a better synchronization of the processes with IEC, EN, and HAS-Consultant is needed. - COM standardization requests should allow for a certain freedom for the ESOs to draft the standards. Too prescriptive SReqs with a hard deadline may prevent innovative approaches and may result in minor quality work due to time constraints. - An agreed evaluation “standard” for the HAS Consultants would be helpful to get more consistent evaluations from/among the various consultants. - The standardization managers in the ESOs need better qualification on the formal and content-related requirements for hEN (including legal aspects).
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Jul 2021

ZVEI welcomes the opportunity to provide input to the European Commission's Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence (AI). From a ZVEI point of view there is currently no reason for a fundamental revision of the Product Liability Directive (PLD) or the introduction of a new horizontal legislation on liability for AI. As product safety and liability legislation and the PLD are technology-neutral, they also cover in principle the potential risks that may be associated with the use of AI applications in technical products and systems. These rules apply comprehensively and are appropriate. There are currently no relevant liability gaps when using products with AI components. We therefore generally recommend: - to maintain the technology neutrality of liability law and in particular of the PLD; - to continue to use the preventive role of product safety law; - not to tighten up liability law, as there are no relevant liability gaps associated with the use of AI. With respect to the parallel AI Act consultation we see the challenge to adequately align both regulatory approaches in order to not create legal uncertainties that hinder innovative approaches in this fast-developing technology. Please find our detailed position on the policy options of the Inception Impact Assessment in the document attached.
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Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

25 Jun 2021

ZVEI feedback to the consultation on the Data Act Roadmap The EU-Commission addresses a variety of aspects of data economy potentially affecting a multitude of legal questions in competition, contract, intellectual property and data protection law. In general, the enormous potential of data sharing can only really be leveraged through sector specific approaches, as the specificity of the data contexts massively vary between different vertical application contexts (e.g. manufacturing or health), incentives for the individual data supplier and data user as well as through supportive framework conditions for business models. Data sharing obligations or enforced data access, e.g. for public authorities, will have rather opposite effects. Principles of freedom of contract Data access and data sharing within the framework of a potential Data Act must be regulated according to the principles of companies’ freedom of contract and the right to self-determination. ZVEI rejects a general "data sharing obligation" for industrial data, as industrial data usually contains sensitive information relevant to competition. Therefore, industrial data should be protected and treated as subject to trade secret and/or intellectual property rights. Data generators should be free to decide how to handle the data they generate. Access and use should be regulated between partners in fair contracts. Therefore, ZVEI welcomes that the Commission has recognized the untapped potential of smart contracts and distributed ledgers technologies. However, both the notion of “smart contract” and the scope of application need to be adequately defined. Facilitate voluntary data sharing: Business-to-business ZVEI welcomes the aim of supporting business-to-business data sharing, in particular addressing issues related to usage rights for co-generated data (such as IoT data in industrial settings), and clarifying rules for the responsible use of data (such as legal liability). The general principle is that of facilitating voluntary data sharing. Demonstrable market failures in the Common European Data Spaces and the question whether such failures arise from anti-competitive behaviour or as a result of a merger/acquisition should normally be addressed by competition law. An injunction to make certain data available is a remedy already available to the competition authorities. Any further obligation to share industrial data would require special justification, as this would interfere with protected corporate interests. Data access and data use in B2B-context is not per se limited, conversely there are already many existing industrial solutions enabling multilateral data sharing and access to common data. Intermediation structures or bodies should be case and sector- specific and therefore open to different forms and means of implementation (e.g. technical solution, trustee, IIoT platform). Business-to-Government ZVEI welcomes the initiative’s objective to increase access to and further use of data, so that the public sector can harness data to facilitate better policymaking. However, only in well justified cases the Data Act may clearly define the rights of public sector to access privately held data and develop appropriate measures and safeguards to protect business data from misuse and potential data breaches and protect companies’ trade secrets and intellectual property rights. These cases must also include an appropriate cost compensation for the companies. Further clarity is needed that existing trade secrets and intellectual property rights are – like in the B2B-context – upheld in principle when sharing data between companies and the public sector. Safeguard for international data transfers Regulatory measures addressing authority access to sensitive data must be based on existing international agreements and discussions. Any uncertainties surrounding the US Cloud Act cannot be solved only by regulatory means but require political solutions.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Supply Chain Communication: We welcome the opportunity to use extended SDS for the communication on hazard, risk & exposure for substances and mixtures. Standardized formats and details of the communication in the supply chain, especially digitally, should be agreed on after involvement of all stakeholders, e.g. in established standardisation bodies. The information requirements for substances in articles should continue to be based on Article 33 for SVHC of the REACH Regulation. Evaluation, authorisation, restriction: We welcome clarifications and simplifications of the current provisions but see a need to further specify the Commission´s plans of merging the REACH authorisation and restriction systems. We question the Commission’s assumption, that accelerated restriction processes are needed to tackle hazardous substances in consumer goods used by vulnerable groups. We reject the “essential use concept” as well as the “generic approach to risk management”. By widening the scope of precautionary principle-based restrictions, the Commission would abandon the application of case-by-case risk-based assessments and shift the focus from specific products to complete sectors. We believe that such broadened application of the precautionary principle is not justified. We urge to maintain the risk-based approach to assess and manage chemicals in the EU. A discussion about “essential uses” is inadequate at this stage. If the Commission insists in opening the approach, we request a societal debate on a possible turn away from the risk-based approach per se. Regarding restriction processes, the Commission should focus on better implementation and shift resources at ECHA to cope with the risk-assessments and to accelerate the decision making. RMOA is not mandatory currently. The regulation of a substance must always be preceded by an RMOA and associated early socioeconomic analysis in which the inherent risks of the substance are weighed against its substitutability and its positive effects. This contributes to a sustainable reduction of the risks to the environment and to users. RMOA should therefore be anchored as mandatory in the REACH legislative text. To be able to provide a qualified contribution to the socio-economic aspects, our industry needs sufficiently long consultation periods. We welcome the objective to strengthen the competitiveness of Europe’s industry by the reform of the restriction and authorisation processes. We see a chance to eliminate existing disadvantages; for example, creating a level playing field with imported products. Double regulation should be avoided. There are multiple regulatory overlaps for the same substances and products within the EU. As a result, the validation of compliance is increasingly complex and prone to mistakes. We call for the regulation of substances in articles to be as simple and transparent as possible. Please, address specific risks with the most relevant sectoral legislation, such as electrical and electronic equipment, vehicles, batteries, or toys. We stress the need to generally introduce the “repair as produced” principle, so that spare parts can be supplied even after changes to restrictions and/or authorisation under REACH. This supports the idea of Circular Economy and focuses on the repairability of equipment and increases the lifetime of the devices. The competitiveness of our industry is dependent on stability and predictability of restricted substances. For goods with long lifetime it is essential that spare parts can be produced and delivered until the end-of life of the product. Control and Enforcement: We welcome a strengthening of control and enforcement of restrictions and enabling a level playing field for all competitors. Regulatory measures should be verifiable and measurable. There is a need for both, harmonised test methods to check the limits for substances and authorities with expertise and resources to monitor compliance with the legal requirements.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

With its large portfolio of industries, the ZVEI hosts many technologies that contribute to making our buildings smarter, safer, increasingly energy efficient and more pleasant for their occupants. Thus, to bundle knowledge and competence we have created the ZVEI-Platform for buildings. The commissions aim to boost building renovation is a policy that the ZVEI and its platform for buildings support. For a comprehensive renovation policy two components are vital, high speed and deep renovation efforts. Those allow significant emissions reductions as well as a preparation for the implementation of future technologies. So, measures that increase the speed of renovations must be combined with those that secure a high quality of those technologies that are being introduced into existing buildings. In the context of the significant relevance that buildings have for achieving the ambitious climate goals, we argue that the revision of the EPBD should be started immediately. Renovating the existing building infrastructure is vital to reduce emissions and enable the use of smart energy management technologies. New legislation should not impede the speed of renovations. For expanding the amount of renovation efforts, it is important to set up a policy that demands a regular evaluation of technical equipment in buildings. In Germany regular energy audits are already being done. To make sure that the insights generated here are used to improve the buildings in question, such audits should create a binding obligation to address identified inefficiencies. Using this tool in an effective way requires regular checks of the technical equipment in buildings. Time intervals for this will differ depending on the type of technology and shall be defined in later stages of the process. In general, all technological systems should be inspected on a regular basis. Considering the goal to have zero emissions buildings, it is important to ensure a high quality of the technical equipment within buildings. Hence, a comparable measurement of a buildings technical standard is necessary. For this, the Smart Readiness Indicator (SRI) can serve to establish a useful value that makes building equipment in all member states comparable and helps to identify renovation needs. However, a lot of its effectiveness and depends on the implementation and methodology. Currently the methodology that is being developed is too complex to unlock its potential. We recommend revising and simplifying the SRI methodology, while still ensuring its value and relevance. We call for a nuanced approach on the SRI to gain better understanding about its actual effects in different building types. An in-depth assessment is necessary including more insights on the actual effects and benefits on ‘real’ buildings, in order to determine whether and how to move forward with making such an indicator mandatory or not. In order to make renovations happen on a large scale their economic feasibility is an important factor. Multiplying the current speed of renovations requires suitable financial support schemes. Here, it is important to consider the total cost of ownership of a given technological system and its components over their whole lifecycle. These costs differ depending on the use of buildings. Thus, we welcome the differentiated minimum standards depending on the building type. Often higher quality systems and components can compensate for their initial costs and produce economic gains in the future. Financial support programmes set up to increase speed and depth of renovations should recognize this. Thereby they can contribute to a technologically advanced building that is ‘fit for 55’.
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Response to Revision of the NIS Directive

18 Mar 2021

The ‘ZVEI, the German Electrical and Electronic Manufacturers’ Association’ appreciates the opportunity to comment on the EU Commission’s proposal for a Directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148. We understand and support the proposed “NIS-2-Directive” as approach to strengthen the overall cybersecurity of European companies and the cyber-resilience of society as whole. But in our view, there are some aspects, which would need alteration or in some areas a more proportionate approach: • Companies need clear rules, definitions and guidelines to be able to fulfil requirements with legal certainty, therefore some articles need some further clarification and differentiation, e.g. Art. 29 and Art. 30. The NIS-2-Directive could be able to make a valuable contribution by ensuring harmonization and regulatory consistency and in this way building a common European framework, which also has to carefully consider and respect other proven legislative frameworks, e. g. the NLF for placing products in the market or the CSA for harmonizing certification. • Art. 21 in its current form would do a disservice to recent initiatives, which try to “raise the bar” and strengthen overall cybersecurity and resilience. The ZVEI calls to limit the requirement in Art. 21 to essential entities and to critical components, which are used in critical core areas of operation of essential entities. There is no need for mandatory after the fact certification of (end) products, those should be regulated through a future European horizontal product regulation within the NLF. Inconsistencies between member states should be avoided, therefore, requirements should be established on the European level. • Raising the level of cyber-resilience is a desirable goal, but it has to be done in a way, that companies are able to adapt to it. Therefore, the double extension of broadening the scope and expanding the requirements and obligations, especially for SMEs, has to be reviewed and carefully adjusted to be proportionate. Raising cyber-resilience is a process, which should be accelerated but hardly can be rushed, because for example it is limited by the availability of security experts. Therefore, it is important to connect with and support ways of cooperation and initiatives, which are already making a contribution to this goal, like the globally well organised CERT and CSIRT community.
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Response to Modernising the EU’s batteries legislation

28 Feb 2021

The German electrical and electronic industry organized in the association ZVEI believes that the proposed regulation for the battery sector published by the EU Commission on December 10, 2020 is a good approach to strengthen the European battery industry, to harmonize national regulations, and to take into account the increased sustainability requirements. However, after an in-depth review of the proposal, we conclude that there is still a need for adjustment at various points in the draft. Main messages: 1) Definitions of terms and scopes need to be reviewed in a precise manner. The specifics of each battery application and battery technology should be considered. 2) Restrictions on hazardous substances should base on the well-established REACH and OSH regulations and not on new parallel processes in the Battery Regulation. 3) The scope of carbon footprint should focus in a first step on “electric vehicle batteries” and in a second step on battery technologies with the biggest CO2 saving potentials. 4) Any numerical targets, e.g. for collection rates, shall be adopted only after the adoption of a proper methodology. For collection of portable batteries, we propose the calculation method "batteries available for collection". 5) Recycling content targets should be based on yet to be developed reliable data on the development of markets for batteries, raw materials and recycling materials. 6) Repaired or remanufactured Batteries have to comply with the same strict standards and certification process as new products. 7) Removability and replaceability specifications should consider specific product requirements and safeguarding consumer safety. 8) For information sharing, the concept of the "Digital Product Passport" should be considered. 9) For standardization, the established European standardization system should be used in the development of harmonized standards relating to Batteries. 10) Due Diligence in the supply chain should be streamlined and facilitated. We propose the creation of a negative list of "non-sustainable" raw material companies. 11) Producers should not be made responsible for organizing the preparation for reuse and recycling of batteries and for bearing the costs of this activity. The decision to recycle or reuse a battery must be left to the market. 12) The clarification of how market access criteria for batteries will be tested and enforced, especially for batteries imported into the EU, is essential. 13) User safety is a top priority for producers. Product development therefore requires sufficient lead time in case of new product requirements by delegated and implementing acts.
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Response to Legislative framework for the governance of common European data spaces

29 Jan 2021

ZVEI welcomes the EU Commission’s objective to increase data availability and better access to public data, as well as facilitating private data sharing by increasing trust and reducing the transaction costs. The creation of a trusted European data infrastructure will support data-driven innovations in the economy. Digital ecosystems based on European values should ensure data exchange across borders and sectors and thereby contribute to the competitiveness of European industry. Increased access to use and re-use of public data can help to promote innovation and facilitate research activities. When creating an open data ecosystem, the public sector should act as a role model in providing data access and ensure secondary usage, e.g. for industrial research. • The establishment of data intermediaries may be a promising aspect of a functioning data economy in certain fields of application in Europe. However, there are already existing well-functioning data-sharing models in the B2B-context in various sectors, where data exchange is not restricted by a lack of trust or technical limitations. In industrial contexts, huge volumes of IoT-generated big data must often be processed and lead to challenges regarding the data layer architectures and the costs entailed by additional layer structures for a data intermediary. It is often more efficient to define data access and the purpose of data usage directly in contracts between the partners involved, and to offer independent audits of these agreements • The scope of Chapter III of the DGA needs to be clarified to prevent legal uncertainty and additional bureaucracy. It is unclear which data flows between companies will be affected and might in the future be subject to notification and requirements, whose compliance will be monitored by national authorities. Further, it is not clear which existing data sharing services will now be mandatory required to seek a notification. • Recital 22 of the proposal lists that the regulation does not cover certain services, including cloud service providers, data advertising brokers, data consultancies, or providers of data products. Also, platforms developed in the context of objects and devices connected to the Internet-of-Things that have as their main objective to ensure functionalities of the connected object or device are excluded. This exemption should be mentioned also in Chapter III, together with a clarification of the scope. • The administrative costs of establishing certified data intermediaries as well as the listed requirements for the exchange of (personal) data within these intermediaries should be limited. The obligations on data intermediary, data exporter and data importer should not exceed what is already listed in the GDPR. • Rather than trying to enhance data altruism through new organisations and consent forms, the DGA should address current uncertainties regarding the GDPR and increase voluntary data sharing by clarifying the standards regarding the anonymisation and pseudonymisation of personal data. In close cooperation with the European Data Protection Board, the Commission should enable exemptions in the GDPR to facilitate the processing of personal data for altruistic purposes or for the purposes envisaged by the data owner. • A full anonymisation before further processing can be counterproductive, e.g. in the re-use of patient data for training AI-based applications in the healthcare sector (see Recital 11 on re-use of protected data). The various options of enabling altruistic data sharing should also be reflected in the envisaged European data altruism consent form. • ZVEI welcomes the creation of the European Data Innovation Board, although scope and competencies still need to be clarified. In any case technology industries should be on the list of the specific sectors listed in the Article 40 of Chapter VI as Manufacturing is the backbone of the economy and creates around 14% of the EU’s GDP (2019).
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Response to A European Health Data Space

26 Jan 2021

You will find ZVEIs statement attached in a separate document
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

29 Oct 2020 · Industrial Ecosystems and EU Standardization.

Response to Requirements for Artificial Intelligence

9 Sept 2020

The Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (ZVEI) welcomes the opportunity to provide feedback to the Inception Impact Assessment of the European Commission for a proposal for a legal act of the European Parliament and the Council laying down requirements to stimulate the development and uptake of Artificial Intelligence (AI) and new technologies. AI will be a core enabling technology for many sectors of European industry. Therefore, ZVEI supports a European approach. A patchwork of national rules and initiatives in 27 EU Member States must be avoided. ZVEI welcomes a debate about the risks and opportunities but calls for a very cautious approach when regulating an essential transversal technology. The immense opportunities must not be ignored, innovation and regulation must facilitate the development and uptake of AI. ZVEI would like to bring forward four points: 1) There is currently no need for a new, horizontal regulation for AI technologies, because there is no evidence yet of any fundamental regulatory gaps. Particularly, in the case of AI embedded in products and machines, AI-characteristics (opacity, complexity and scalability) are limited by existing regulation and functional constraints. 2) The EU-legislator should not regulate specific technologies but should instead target the effects of AI applications in a technology-neutral way. Otherwise, there is a risk of hampering innovation and having to constantly adapt laws to technological progress. After careful assessment of regulatory gaps, AI applications where personal privacy or where life and limbs are at stake should be critically evaluated in a case-by-case approach. Hereby the risk level should be objectively determined in a short range for the beginning by the criticality of the application itself. Transparent and comprehensible criteria are needed to classify AI-based products and services. Legal uncertainty would be a huge barrier to the use of AI, in particular for SMEs and MidCaps, and would hence hamper the use of AI in Europe. 3) We do not see a need for legislative action on product safety. In the General Product Safety Directive, the safety requirements are technology-neutral and expand without preventing technical innovation and thus cover AI applications. 4) ZVEI does not believe that a readjustment of the Product Liability Directive and national liability regimes is needed at this stage. The Product Liability Directive is formulated in a technology-neutral way and the courts have applied it over the years to a wide range of products, many of which did not exist when the Directive was adopted, like AI now. ZVEI favours a combination of policy option 1 and 3b in the presented Inception Impact Assessment. Policy option 3c (covering all AI) would raise a prohibitive barrier in a important sector of industrial AI and will finally will bring Europe’s industry to fall behind international developments, especially in competition with US and Chinese companies. -The basis should be a “Soft Law”-approach, which builds upon existing initiatives and guidelines on trustworthy AI across a wide range of experts within the industry. This will not only leave room for cutting-edge AI-solutions, but also allow a precise assessment of the real risks of AI and potential regulatory gaps. The use of “regulatory sandboxes” could help to find this balance. -In a second step, if necessary, specific requirements could be established for clearly defined “high-risk”-applications - if they are not covered by existing regulation. It is crucial to focus on "high risk applications" and avoid hampering harmless AI-applications. In the industrial context (B2B), AI offer enormous economic potential and is in general uncritical -non-personal machine data is often used to optimise production processes or increase efficiency along the value chain-. This is already covered by a technology open legislation where AI applications do not require further legislation.
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Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

3 Sept 2020 · New MFF, implementation of Green Deal and Digital Transition in the context of the Recovery

Response to Review of the Construction Products Regulation

18 Aug 2020

The feedback can be found in the attached file.
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Response to Revision of the NIS Directive

31 Jul 2020

Strengthening cyber-resilience is an important goal, so that all stakeholders involved can live and work peacefully with each other in an increasingly networked and digitalised world. Cyber incidents cause considerable damage to both companies and private individuals and are therefore a threat for the economy and society. Consistent and coherent regulation is essential and dearly needed, overlaps and conflicting regulation should be prevented. Fragmentation and inconsistent national regulation must be avoided and should be harmonized, to ensure a European level playing field. Non-coordinated national propositions, like the German IT-Security Law 2.0, pose an unfair competitive disadvantage for companies concerned. Only consistent European regulation, which ties into the international markets, allow for the unhindered function of the European internal market. Technical specifications should be avoided in regulation, this more detailed elaboration should be in the responsibility of the European standardisation organizations. The establishment of some basic rules of cyber security hygiene may be required. Every regulation has also take into account that cyber security is a moving target, which needs the collaboration of all actors and their acting in the respective responsibility. Therefore, a possible extension of the scope of the regulation must be done with a sense of proportion for the role of the affected actor, especially small and medium-sized enterprises (SME’s) must be enabled to implement adequate cyber resilience. Hence, there also shouldn’t be different sets of operators of essential services among the EU member states. In consideration, rules shouldn’t be so specific, that smart and innovative ways to tackle the fast and everchanging cyber security threats, are hindered. Legislation should refer to the current state of the art without specific preferences for a technology. Furthermore, a risk-based approach is favourable to account for different environments and applications.
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Response to Modernising the EU’s batteries legislation

9 Jul 2020

The ZVEI - German Electrical and Electronic Manufacturers´ Association appreciates the opportunity to comment on the European Commission’s inception impact assessment on modernizing the EU’s batteries legislation. We see this assessment as a further step on the way to a coherent legislative framework on batteries in Europe. Please find the feedback of the ZVEI in the document uploaded enclosed.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

5 Jun 2020

Energy efficiency and digitalisation technologies for buil-dings – consultation on ‘renovation wave’ initiative - ZVEI contribution A. Context, Problem definition and Subsidiarity Check Context The yearly renovation rate of the building stock is 1% in average in the EU. That means, that we need 99 years to renovate the current building stock. But if Europe is to fulfil its 2050 climate and energy goals, this rate will need at least to reach 3% per year. Reno-vation is the key element of the European Green Deal and has been identified as a key driver for the European society and economy post COVID-19. With 75% of EU buildings in need of renovation,because they are not energy efficienct. The ZVEI believes that the upcoming Renovation Wave Initiative represents a unique opportunity to ensure the energy efficiency of buildings and also to address the well-being of occupants through a better indoor environmental quality through digitalisation technologies. With this paper, we as ZVEI urge policymakers to address energy efficiency and digitalisation technolo-gies for buildings as part of the Renovation Wave Initiative and share our recommenda-tions. Problem the initiative aims to tackle A wide use of energy efficiency technologies in buildings can make a comprehensive contribution to climate protection in Europe. At the same time, the digitalization of buil-dings is a profitable investment - it can be very fast contribute to significant energy savings in both residential and non-residential buildings. The broad application of various building technologies - including control and monitoring systems in connection with digitization and methods of artificial intelligence - must there-fore be adequately taken into account in the strategy for the wave of renovations and appropriate incentives created for such investments. With respect to the action plan as-pects proposed by the European Commission, we as ZVEI would like to bring some ad-ditional points into consideration when considering the potential of renovations in the building sector. Basis for EU intervention and subsidiarity check B. What does the initiative aim to achieve and how? • Increase acceptance and willingness to invest in rental properties through tar-geted funding. The modernization of the electrical system, including preparation for digitalization, energy transition and automation, this must be included among the eligible individual measures. • Consider building energy efficiency across sectors. Energy efficiency must not be viewed in isolation in individual sectors, since energy consumption can also be re-duced systemically by coupling the sectors of electricity, heat and transport in the building • Intelligent networks need intelligent buildings: appropriate incentives for investors and building owners to expand building intelligence. • Consider internet connection as part of the renovation wave. Wave of renovations can be thought of holistically with the measures of the European Commission to promote broadband expansion. • Create a "Smart Readiness Indicator" applicable throughout Europe: Such an in-dicator would remove information barriers and create transparency about the effi-ciency of automated buildings and thus also contribute to real estate prices effec-tively reflecting energy efficiency measures. The strategy of the EU should accele-rate the rapid introduction of the SRI. • Expand expertise in building automation: The electronic industry is calling for an improvement in the framework conditions for training and further training of speci-alists, which must be underpinned by a European program. • Promotion of the installation of charging infrastructure: strategy taking into ac-count the incorporation of charging infrastructure during renovation work. • Testing and promoting new business models: As-a-service models are also available in non-residential buildings to increase energy efficiency, which must be funded by the EU.
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Response to Evaluation of the Electromagnetic Compatibility Directive

20 Feb 2020

ZVEI - German Electrical and Electronic Manufacturers' Association is one of the most important industrial associations in Germany. It represents the interests of a high-tech sector with a very wide and extremely dynamic product portfolio. The basis of the association's work is the exchange of experience and views between the members about current technical, economic, legal and socio-political topics in the field of the electrical industry. From this exchange, common positions are drawn up. The EMCD has a very broad scope and affects all kind of electric and electronic equipment. This broad scope ensures the coexistence of all kind of equipment without malfunction introduced by electromagnetic phenomena. Therefore, we are strongly convinced that the directive itself is very up to date and effective. This is also proven in millions of applications in the field. Harmonised standards are continuously updated by ESOs according to the latest technological development. Due to the involvement of EMC experts from industry and market surveillance authorities in the work of standardisation committees, information about new technical trends is always available and taken into account. Therefore, we oppose to any change to the scope of the Directive, nor to a change of the essential requirements. Instead, the principle of the New Legislative Framework has to be kept and applied unchanged. The directive must continue to only specify the high-level essential requirements. The EMCD is not a “safety directive”, meaning that the Directive is not supposed to deal with the safety of equipment. This proven principle has to be maintained. The EMCD has to be kept technology neutral. A clear separation from the RED is necessary, because the scope of the RED is “radio communication and determination” and not general coexistence of electronic equipment. Radio communication equipment has strict market access regulations all over the world with type approval requirements in most countries except Europe. When merging RED and EMCD in Europe, there is a high risk that other countries would feel invited to extend their type approval requirements also to non-radio equipment. This would pose a high economic burden on Europe's export oriented industry. Cables itself are passive elements in the sense of EMC. It is technically not possible to specify whether a cable meets any EMC requirement independent from the connected equipment. It is therefore not sensible to include requirements on cables in the EMCD. Moreover, it would entail additional red tape and administrative burden on thousands of manufacturers and millions of products in an attempt to solve an alleged problem which in reality only may exist in rare cases. If an apparatus only meets the requirements of the EMCD with e.g. certain (high-quality) cables, it is already today the manufacturer's duty to refer to this requirement in the operating manual of the apparatus or fixed installation. Our industry values the EMCD for its legal stability and predictability and we are convinced that any unclarities can be addressed in guidance documents without revising the EMC Directive.
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Response to Commission Regulation amending Annex XIV to REACH

21 May 2019

ZVEI-comments on the Draft Commission Regulation amending Annex XIV to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) - Ares(2019)2582382 1. Tetralead trioxide sulphate; pentalead tetraoxide sulphate; orange lead (lead tetroxide) and lead monoxide (lead oxide) We welcome the decision of the European Commission to postpone further decisions regarding the four lead compounds under REACH until the current Union binding occupational limit value and binding biological limit value for lead compounds under Directive 98/24/EC will be reviewed. Europe’s policy must find the right balance to support the growing demand of batteries while ensuring there is no risk to human health or the environment from battery materials. Tetralead trioxide sulphate; pentalead tetraoxide sulphate; orange lead (lead tetroxide) and lead monoxide (lead oxide) are used almost exclusively in the manufacturing of lead based batteries. They are not present in the batteries placed on the market and hence there is no danger of an exposure to these substances for the user of a battery. An authorisation of the four lead compounds would be detrimental to industrial growth and investment in battery manufacturing in the EU and could hinder the further development of a globally competitive EU batteries value chain, while not providing a higher level of environmental and human health protection. We are convinced that scientifically robust Occupational Exposure Limit Values under OSH for lead compounds used in batteries will be a more effective alternative to REACH authorisation. The battery industry is extremely active in exchanging on best practice to minimise employees’ exposure to lead. This exchange, which involves regular workshops, is supported by a voluntary program managed by EUROBAT (Association of European Automotive and Industrial Battery Manufacturers) that includes an employee blood lead target that applies to all member companies and that requires an annual data submission to track progress. The current target is that no employee should have a blood lead level exceeding 25 µg/dl by the end of 2019 (while current REACH DNEL is at 40 µg/dl and current EU limit value defined at 70 µg/dl). In terms of results of the blood lead programme, battery manufacturers are well under way to reach this target, and blood lead levels of employees are now significantly lower since the start of the programme in 2001 with only 0.63 % of employees in the EU with levels higher than 30 µg/dl at the end of 2018. Moreover, only 4.1 % of employees in the EU recorded blood lead levels higher than 25 µg/dl. Details of the program can be found under https://www.eurobat.org/environment-health-safety/occupational-health-safety. 2. NMP Most batteries manufacturing processes are using 1-methyl-2-pyrrolidone (NMP) as a solvent of the positive electrode binder or in casting processes. Batteries do not contain NMP greater than 0,1 %. Where visible NMP is collected after the drying process, reused for cleaning of equipment and finally sent for proper recycling. All potential risks connected to the use of NMP are already addressed by the restriction (Annex XVII - entry 71), which is the most appropriate risk reduction measure for NMP. Therefore, we remark our opposition to the inclusion of NMP in Annex XIV to Regulation (EC) No 1907/2006, and invite the Commission to close the process of inclusion in Annex XIV to ensure business certainty regarding the use of the solvent or flux melting agent.
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Meeting with Günther Oettinger (Commissioner)

27 Mar 2019 · Future of Europe

Response to Smartwatches and connected toys

3 Mar 2019

ZVEI sees as the primary objective and challenge in Europe to address cybersecurity for products in a consistent way without creating overlapping and potentially contradicting regulation in order to maintain for CE marked products the benefits of an EU single market. However, addressing cybersecurity requirements in a Delegated Act under RED, which essentially has to stay within the limits of privacy (Art 3.3 (e)) and fraud (Art 3.3 (f)) can only cover a subset of requirements. We are therefore concerned, that it is not possible to ensure the necessary consistency with other existing or upcoming legislative requirements. In order to prevent overlapping and fragmented legislative requirements we deem option 0 as the most appropriate policy option under the current RED. Furthermore, we are ready to discuss with the Commission a horizontal approach of addressing cybersecurity requirements for products. This horizontal approach should follow the principles of the New Legislative Framework.
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Response to Application of Article 3 (3) (i) and 4 of Directive 2014/53/EU relating to Reconfigurable Radio Systems

3 Mar 2019

ZVEI is pleased to provide its views on the particular issue of embedded and business software which may be installed in this equipment and products. Our industry is committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when further software updates and reconfigurations are applied to the products, under the framework of the Radio Equipment Directive (RED). It is key to acknowledge that a one-size-fits-all approach as well as a simple and undifferentiated classification of products will endanger the objectives of the roadmap in the Inception Impact Assessment, namely: innovation and competitiveness, functioning of the Internal Market and the risks of lockdown of (a majority of) radio equipment. A very careful selection of the categories and classes of radio equipment has to be made. More specific explanation is given in the attached statement.
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Response to Revision of the ETS State aid Guidelines

16 Jan 2019

Im ZVEI-Fachverband Kabel und isolierte Drähte sind die Hersteller von Kabeln, Leitungen und Verbindungstechnik für die Bereiche Energie, Kommunikationstechnik und Automotive sowie die Hersteller von Lackdrähten in Deutschland organisiert. Im Bereich In Fachbereich Energie des Fachverbands sind die Hersteller von Energiekabeln in Deutschland für den Spannungsbereich von 1 kV bis 500 kV vertreten. Die Mitgliedsunternehmen teilen die Meinung der EU-Kommission, dass durch den Ausgleich für energieintensive Unternehmen das Risiko einer Verlagerung von CO2-Emissionen minimiert, wird. Die Gefahr der Verlagerung von Produktionsprozessen bei hohen Emissionskosten ist in der Kabelindustrie gegeben. Unsere ausführliche Stellungnahme inklusive Erläuterungen entnehmen Sie bitte dem beigefügten Dokument.
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Response to Review of ecodesign requirements for lighting products

9 Nov 2018

Der Fachverband Licht im ZVEI Zentralverband Elektrotechnik und Elektronikindustrie e.V. begrüßt die Möglichkeit Kommentare zur neuen Ökodesign Regulierung für Lichtquellen und Vorschaltgeräten zu geben. Die jetzt vorliegenden Vorschläge beinhalten große Veränderungen im Vergleich zur aktuellen Gesetzgebung und bedeuten deutliche regulatorische Markteingriffe für unsere Mitglieder. Als ZVEI Fachverband Licht unterstützen wir ausdrücklich die Vorschläge in Artikel 4 die im Hinblick auf „Circular Economy“ Empfehlungen für Hersteller und Hinweise für Verbraucher geben. Eine verpflichtende Designvorschrift für alle Beleuchtungsprodukte in Bezug auf die Ausbaubarkeit von Lichtquellen und Vorschaltgeräten hätte unnötigerweise eine Vielzahl von Produkten vom Markt verbannt, die u.a. durch Parameter wie Haltbarkeit oder Materialeffizienz bereits Ziele einer nachhaltigen Kreislaufwirtschaft erreichen. Für die vorgeschlagenen Tests durch Marktüberwachungsbehörden sehen wir deutliche Schwachpunkte: a) Der vorgeschlagene Testzyklus von Produkten mit 21 Wochen erachten wir als deutlich zu lang, da er aus unserer Sicht die Marktüberwachung insgesamt erschwert und damit schwächt. Deshalb empfehlen wir deutlich die Testprozedur zu vereinfachen und auf maximal 500 Stunden zu begrenzen. b) Die vorgeschlagenen Toleranzen von +/- 5% für den Lichtstrom sind industriell nicht darstellbar. Wir schlagen deshalb eine einseitige Toleranz vor. Wir fordern, dass die Zeitpläne dieses Vorschlags mit denjenigen von RoHs synchronisiert werden müssen um Sicherheit für Industrie und Verbraucher hinsichtlich der Ausphasung von Beleuchtungsprodukten zu erreichen. Darüber hinaus haben andere Industrien und Nutzer Bedenken hinsichtlich des Ausphasens von Beleuchtungsprodukten für spezielle Anwendungen geäußert. Beispiele für solche, nicht durch LED technologisch ersetzbare Produkte finden sich im Statement von LightingEurope, das wir ausdrücklich unterstützen.
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Response to Review of energy labelling requirements for lighting products

6 Nov 2018

The Lighting Division in ZVEI -German Electrical and Electronic Manufacturers' Association thanks the European Commission for the opportunity to comment on the proposed review of energy labelling requirements for lighting products. We fully support the LightingEurope (LE) proposal: LE welcomes the discontinuation of the label for luminaires, as we believe that it does not provide any relevant information when evaluating a luminaire and has no other benefit for consumers. We fully support the proposal to limit the energy label to light sources. LE proposes additional revisions in order to clarify the text and ensure the proposal is feasible and easy to enforce. The scope has to be reduced to end-user replaceable light sources that are not marketed as part of a containing product (except when they are offered for sale, hire, or hire purchase or displayed separately to the end-user, for example as spare parts). LE urges the legislator to exempt in particular emergency lighting from energy labelling obligations, including EPREL, as emergency lighting is not intended for illumination but rather to ensure the safety of humans in case of emergencies. We also recommend more flexibility when it comes to the labelling format. As the energy label has to be printed on the packaging and lighting products come in multiple shapes and sizes. LightingEurope recommends maintaining the option of a complete horizontal label and a greyscale complete label. LE is very concerned with the proposals for EPREL. Uploading product information related to hundreds of thousands of light source models, including lamps and modules sold between 1 August 2017 and 1 January 2019, is unfeasible in light of the current timeline and state of preparedness of the database, and may result in involuntary incompliance. The necessary guidelines and infrastructure does not yet exist for suppliers to start registering and uploading information. The current planning foresees that this will only be possible from 14 December 2018. Eight working days is too short for industry to upload all information before the deadline of 1 January 2019. Additionally, in the second phase of EPREL starting from September 2021, the information requirements in their current format go far beyond the necessity of informing end-users and market surveillance authorities about the energy usage of lighting products and the level of details is far too complex. We need a much more pragmatic approach for dealing with data requirement. We therefore propose to limit the information requirements to what is necessary for end-users to be informed about the energy usage of lighting products.
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Meeting with Carl-Christian Buhr (Cabinet of Commissioner Mariya Gabriel)

13 Nov 2017 · Cybersecurity certification framework

Meeting with Cecile Billaux (Cabinet of Vice-President Cecilia Malmström)

15 Sept 2016 · TTIP SIA study

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V.

20 Jan 2016 · Medical Device Regulation

Meeting with Günther Oettinger (Commissioner)

11 Nov 2015 · Internet of Things

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

8 Oct 2015 · Aktueller Stand der FTA Verhandlungen insbes. TTIP und Japan aus Sicht der DG Trade

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 Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

27 Feb 2015 · Intro meeting