2022/0047(COD) · In Force
243 submissions from 209 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission received 254 submissions on this file. Shown here: the 243 from organizations. Not shown: 10 from private individuals. Their submissions are personal data; the Commission publishes them under its own legal basis, and republishing them by name here would need one we do not have. Organizations act in a public capacity, so their positions are public record. Also not shown: 1 further submissions we do not publish for other reasons: no quotable text (a comment under 250 characters and no readable paper), no organization named, or a private person who filed under their own name. About this data →
194 submissions from industry — companies and their trade associations — against 22 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 8.8 industry submissions for every one from civil society.
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
Self-declared to the EU Transparency Register (snapshot 14 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 13 May 2022 — it ran from 14 Mar 2022.
How it got here
Also on the Commission’s pipeline for this file, with no date recorded: Initiative planned.
Showing 25 of 243 submissions.
REQUEST FOR COMMENT RESPONSE Regulation of the European Parliament and of the Council on harmonised rules on fair access to and use of data (Data Act) May 13, 2022 I. INTRODUCTION In response to the European Commission’s proposal on the Data Act, CrowdStrike offers the following views.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
13 May 2022 Feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de la Loi 23, 1000 Brussels, Belgium to the European Commission on its Proposal for a regulation of the European Parliament and of the Council on harmonised rules on fair access to and use of data (Data Act) ACT | The App Association | Rue de la Loi 23, 1000 Brussels | www.actonline.org | [email removed] ACT | The App…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As an umbrella association of Czech online publishers, TVS, technological companies, advertising agencies and e-commerce players, we welcome the intention of the European Commission to propose a new regulation aiming to introduce a fair and effective tool for exchange of IoT data. Unfortunately, there seems to be a certain level of unclarity regarding the impact of the proposal on other types of data.
Filed in Czech · English published by the European Commission
Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE insurers, MOBILIANS, Mobivia, SESAM LLD, SNSA -UFE; connected mobility players New services involved from vehicle connectivity will improve driving, comfort and life of drivers and passengers, who contribute to road safety, infrastructure optimisation, ecological transition and vehicle…
Filed in French · English published by the European Commission
SIIA appreciates the opportunity to provide feedback on the proposed Data Act. SIIA represents over 450 companies reflecting the breadth of the data-driven economy, many of which are based in the EU and most of which do business in the EU. Summary. SIIA supports the objectives of the Act to unlock the innovative value of data while ensuring responsible practices for its use, collection, and sharing.
The European Committee for Interoperable Systems ("ECIS") is an international, non-profit association of information technology companies founded in 1989 which endeavours to promote a favourable environment for interoperable ICT solutions.
Reactie BOVAG op voorstel Dataverordening - COM(2022) 68 final Bunnik, 13 mei 2022 Over BOVAG: BOVAG behartigt de belangen van haar 8.500 leden (85.000 medewerkers), actief in de mobiliteitsbranche (waaronder geautoriseerde autodealers en universele autobedrijven), de omzet in deze mobiliteitsbranche is ongeveer € 45 miljard.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Belron® is the world’s leading vehicle glass repair, replacement, and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. Belron supports the Commission’s proposal for a Data Act and considers it an important step in facilitating B2B data sharing.
SECOND FILING: REPLACES ORIGINAL CORRUPTED AND UNREADABLE PDF COMMENTS ATTACHED The Association for Computing Machinery (ACM) is the world’s largest and longest established professional society of individuals involved in all aspects of computing. It annually bestows the ACM A.M.
The Japan Business Council in Europe (JBCE) would like to welcome the Data Act proposed by the European Commission to promote fairness in the use of and access to data. We believe that the use of data among various stakeholders is essential to strengthen the competitiveness of companies and to create a fair society where everyone has the opportunity to innovate.
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EXECUTIVE SUMMARY ZIA German Property Federation is in favour of exploiting the potential of data more than before. Particularly with regard to climate and environmental protection and achieving the goals of the Green Deal, the introduction of digital building infrastructure for measuring consumption can help reduce CO2 emissions.
Microsoft welcomes and appreciates the opportunity to respond to the European Commission’s request for feedback on its proposed "Data Act & amended rules on the legal protection of databases" Regulation. Please find attached initial input and suggestions on which we look forward to engaging with EU policymakers and stakeholders.
Developers Alliance appreciates the opportunity to provide feedback on the European Commission’s proposal for a regulation on harmonized rules on fair access to and use of data (Data Act). The proposed approach is raising many legal and technical challenges, adding another layer of complexity to the EU regulatory landscape.
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Thank you for preparing the good draft. From our point of view there are two key issues regulated in the draft: the transfer of data from business to government and the possibility of its reuse by third parties, as well as the reform of database regulations, which was unfortunately omitted in the presented text of the draft.
Workday welcomes the opportunity to respond to the European Commission’s request for feedback on its proposed Data Act (please see complete response in the document attached). Workday is a leading provider of enterprise cloud applications for finance and human resources, helping customers adapt and thrive in a changing world.
The Data Act is a key pillar of the European data strategy. It aims to create a wider, more open European data market, framed by conditions set by the European Union and shared between the various players. It will make a major contribution to achieving Europe’s digital transformation goal in this decade, by establishing fair use rules on access to and sharing of data generated or collected by the so-called “Internet…
Filed in French · English published by the European Commission
13 May 2022 ITI Comments to the Data Act Proposal 1. Introduction The Information Technology Industry Council (ITI) is the premier global advocate for technology, representing the world’s most innovative companies from technology, hardware, software, services, and related industries.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Siemens Healthineers welcomes the initiative of the European Commission to facilitate access to and use of data, including business-to business and business-to-government. We too share the ambition and support the measures which would ensure fairness in the digital environment, stimulate a competitive data market, open opportunities for data-driven innovation and make data more accessible for all.
EuroCommerce supports the aim of the European Commission to encourage further access and use of data in order to mutually benefit public and private actors. Voluntary contract terms, with the involvement of industry actors are welcomed especially for SMEs which often lack the resources.
Technological advances are leading to a transformation in users' practices, leading them to reconsider their expectations in terms of safety, respect for the environment, inter-modality of means of transport, but also, and above all, of services. Consequently, the downstream automotive sector, which is in direct contact with users, is at the heart of these transformations.
see attached document. The Federal Bar Association would like to thank you for the possibility of an opinion. The draft is comprehensive and ambitious. Its implementation would have a significant impact on: all users and providers of everyday products and related services in a Multitude of situations. It should be avoided that the use of these products: this makes it more difficult.
Filed in German · English published by the European Commission
Stockholm 13 May 2022 The Confederation of Swedish Enterprise position on the Data Act proposal The Confederation of Swedish Enterprise brings together 60,000 companies and 50 industry and employer organisations. We work on issues that are important to all companies, irrespective of sector and size.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
FEDENE is a french professional association representing 500 energy service companies. From district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members implement and develop sustainable services. FEDENE embraces the proposal which heads in the right direction to facilitate interoperability of data and improve transparency for final users.
Airlines for Europe (A4E) welcomes this initiative of the European Commission and also the possibility to provide feedback to this call for evidence. Aviation and Airlines/aircraft operators in particular rely heavily on data, its sharing, and analysis in two different areas: • Air Traffic Management (ATM) and Air Navigation Service Provision as well as • Airline internal analytics and processes We support the EU…
FIEV welcomes the initiative of the European Commission to propose a regulation helping automotive suppliers to have a fair, reasonable and non-discriminatory access to the data produced by mobility systems and their environment, fostering innovation and providing customers with added value services. Over the last decade, data has indeed been considered as the new “oil of the industry”.
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T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry would like to use this opportunity to raise our concerns on the EU Data Act, as it impacts our current and future service business based on IoT. Key points: • Legal uncertainties due to high regulatory density, which may inhibit rapid market uptake in industrial B2B (IoT).
The American Chamber of Commerce to the EU (AmCham EU) shares the objectives of the European Commission to increase access to and further the (re-)use of data through the proposed ‘Data Act’. In order to ensure the Data Act meets its stated objectives, it should focus on promoting greater voluntary data sharing in order to boost economic growth, research and innovation, competitiveness, job creation and to achieve…
EDF welcomes the publication of the Data Act and its objective to fulfil the ambition set out by the Data Strategy: to make the EU a leader in a data-driven economy. The focus on data sharing and availability, data interoperability, portability, and sovereignty are highly relevant.
Philips feedback to Data Act proposal Philips welcomes the opportunity to provide feedback on the proposed Data Act which aims at building a single market for data and making Europe a global leader in the data economy. Data is the cornerstone of digital transformation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
On 23 February 2022 the European Commission presented its draft Data Act. AFNUM supports this approach and calls for more data exchange. However, with a view to achieving a proportionate and effective text, AFNUM would like to make several remarks and recommendations on the draft Regulation. The general scope of the text goes in the right direction.
Filed in French · English published by the European Commission
• IAB France represents the broad digital advertising and marketing ecosystem in France whose 150+ members include advertisers, agencies, publishers, and technology companies. • IAB France and its members support the general objectives of the Data Act to promote a competitive European market of data and to clarify the rules of access and use of data to enable a transparent and fair allocation of value between all…
Dear ladies and gentlemen, we appreciate the European Commission's proposal on the Data Act and support the fundamental principles, already formulated in the European Strategy for Data in 2020, that secure data sharing is - and moreover will be - one important pillar for the European digital economy.
TIM comments to the Public Consultation on the Data Act 13 May 2022 TIM welcomes the opportunity to comment on the European Commission proposal on the Data Act, a pivotal piece of legislation to reestablish the role of Europe in the global data economy. TIM supports the overarching objective of promoting and facilitating data sharing, pursued by the proposed Regulation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Arthur's Legal, Strategies & Systems welcomes, supports and endorses the Data Act proposal. In this Digital Age, where digital is not a nice to have anymore but a need to have, it is a necessary component that was - so far - missing. It’s an important piece of the puzzle towards the Digital Decade 2030.
13 May 2022 FEEDBACK ON THE EU DATA ACT COMMENTS ACCIS is the voice of organisations responsibly managing data to help assess the financial credibility of consumers and businesses. Established as an association in 1990, ACCIS brings together more than 40 members from countries all over Europe as well as associates and affiliates across the globe.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Dear Sir or Madam, please find enclosed the opinion of the Automobile Industries Association (VDA) on the draft Data Act. Yours sincerely, Dr [name removed], LL.M. Head of Legal and Compliance Department Association of Automotive Industries (VDA) Behrenstr.
Filed in German · English published by the European Commission
Overall, the Data Act is a welcome proposal as it broadens access rights to machine-generated data while providing structural conditions for greater sharing and reuse of data. Likewise, it introduces new interoperability provisions to secure a fairer allocation of machine-generated data between users and data holders.
In the view of the DIHK, the objective of the European Commission to enable wider data use of industrial data and to exploit the potential for strengthening innovation and growth in the long term is to be supported in principle. For this to happen, businesses need a reliable framework.
Filed in German · English published by the European Commission
Stellungnahme des VCI zum Legislativvorschlag des EU Data Act Der Verband der Chemischen Industrie (VCI) vertritt die Interessen von rund 1.900 Unternehmen aus der chemisch-pharmazeutischen Industrie und chemienaher Wirtschaftszweige gegenüber Politik, Behörden, anderen Bereichen der Wirtschaft, der Wissenschaft und den Medien.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
It is widely recognised that data are today a source of values, opportunities and innovation offering broad prospects for growth and competitiveness. The sources of digital power are now considered to be in the exploitation of data. To this end, MEDEF supports the horizontal approach adopted by the European Commission in its proposal for a Regulation on access and use of data (‘Data Act’), presented on 23 February.
Filed in French · English published by the European Commission
About the GFII: The French organization of information industry (GFII) is unique in the FR data landscape by bringing together private and public data holders and re-users, in every area of practice (geography, legal, statistics, company info…) in order to determine the best ways to develop and to promote a sustainable economy of data.
Communications & Political Affairs Consultation Response EU Data Act Status: 11.05.2022 E.ON supports the plans of the European Commission for a twin green and digital transition of our economy. The transformation of the energy sector, with data and digital solutions as key enabler, is at the heart of Europe’s climate ambitions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DEKRA, an international testing, inspection and certification company, very much welcomes the European Commission’s proposal for the Data Act, which fosters access to and use of data. The data generated by connected products will be crucial, among other things, for assessing the connected products’ continuous compliance with safety and security requirements.
Position paper Mei 2022 Ontwerpverordening Data Act COM (2022) 68 final Met 5 miljoen leden is de ANWB de grootste vereniging van Nederland. De ANWB behartigt de belangen van zijn leden op gebied van verkeer, recreatie en toerisme. Binnen verkeer zet de vereniging zich met name in voor betere bereikbaarheid, verkeersveiligheid, duurzaamheid en consumentenbescherming.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As a leading alternative European cloud service provider, Scaleway is welcoming very positively the Data Act proposal published by the European Commission. We share the objective of the European Commission to remove commercial /financial, technical, contractual obstacles that still prevent customers from switching between cloud services, developers’ freedom of choice -annihilating therefore effective and smooth free…
As a member of the aeronautics, space and defence ecosystem, we welcome the Commission’s proposal on harmonised rules and fair access to and use of data (Data Act). We are particularly positive on the proposed provisions in chapter VI (switching between data processing services) and VII (international non-personal data safeguards).
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Société Générale hails the draft Data Act as a new step in the EU ambition to further develop digital economy and strengthen its sovereignty. We appreciate the text indeed aims at developing a European space of IoT data exchange through homogeneous, structuring protocols including a welcome principle of compensation for the data-holder.
This is a joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological…
Insurance Europe welcomes the proposal as it sets out common rules on the use of data generated by connected devices, including how to access and share it. We also welcome an enhanced data portability right, which, among others, looks to improve technical standards for access and portability of data generated by individuals.
IBM submission on the European Commission Proposal for a Data Act Introduction IBM welcomes the opportunity to provide its opinion on the European Commission’s proposal for a Data Act, and to offer our views on the measures we believe can help strengthen a thriving data economy while avoiding undermining trust in technology.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Commission Feedback Data Act & amended rules on the legal protection of databases EFPIA welcomes the opportunity to provide feedback to the proposed Data Act and amended rules on the legal protection of databases, published on 23 February 2022. There are many aspects of the Commission’s proposal which EFPIA fully supports, including the overall goal of facilitating the re-use of data.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The AFCAR Alliance (Alliance for the Freedom of Car Repair) represents a wide range of European stakeholders in the automotive aftermarket, as well as vehicle dealers, operators in the mobility value chain and the European consumers. We account for over 4.5 million jobs, most of which are in the over 500.000 SMEs operating in this sector.
Proposal for Regulation on harmonised rules on fair access to and use of data (Data Act) Comments by MFE-MEDIAFOREUROPE N.V. MFE-MEDIAFOREUROPE (hereinafter, "MFE") is the holding company, registered in Amsterdam (Netherlands) with fiscal offices in Italy and Spain, which controls Mediaset S.p.A. and Mediaset España Comunicación S.A. It is listed on the Milan and Madrid stock exchanges. In Italy, Mediaset S.p.A.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DocuSign Envelope ID: E8767769-7CEA-4CF9-95D5-943998B88DCC Ref. Ares(2022)3659883 - 13/05/2022 Helsinki, 13 May 2022 MyData Global response to Data Act We congratulate the European Commission teams who have been working on the Data Act proposal. We particularly appreciate the importance brought to protecting (citizens) data generated by the use of a product or related services.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Volvo Group wants to thank the European Commission for the opportunity to give feedback on the proposed Data Act. -- Volvo Group welcomes the Commission’s proposal to assign users wider rights to oversee third parties’ access to data generated by their products and related services.
As Europe’s leading independent location technology specialist, TomTom appreciates the opportunity to provide feedback on the Commission’s proposal for the Data Act. Overall, TomTom supports many of the components of the Data Act. However, we would like to seek clarification on some issues and propose some changes to improve the implementation of the proposed regulatory framework.
As the global maritime and energy sectors are moving towards a data-driven and connected future, the upcoming Data Act has been studied within the different business units at Wärtsilä. Generally speaking, we understand and support the Commission’s ambition to strengthen the European Union as a fair data economy by fostering the access to and use of data.
About eco: With more than 1,100 member companies, eco is the largest Internet industry association in Europe. Since 1995, eco has been instrumental in shaping the Internet, fostering new technologies, forming framework conditions, and representing the interests of members in politics and international committees.
The Verband Autoteil-Handel (GVA) e.V. welcomes the principles and objectives of the Data Act, in particular with regard to the regulation of B2B data exchange. As industry representatives in the free motor vehicle parts and services market, we share the view that at present a manufacturer can exercise exclusive control over the data generated by its product, thereby hindering market entry and competition with…
Filed in German · English published by the European Commission
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The Austrian Social Insurance welcomes the initiative for a fair and innovative data economy by proposing a European Data Act as part of the European Commission’s Data Strategy. The primary goal of the Data Act in view of the public sector is to improve public services and policy making and is therefore supported by the Austrian Social Insurance.
IFRRO, the International Federation of Reproduction Rights Organisations, is the international network of collective management organisations and creators’ and publishers’ associations in the text and image spheres, with over 150 members in 85 countries. Our members represent many millions of authors, visual artists, and publishers of books, journals, newspapers, magazines and printed music.
SGI Europe welcomes the Commission's proposal on a Data Act and the challenges raised by the proposed regulation, which will stimulate the development of a market for data from competitive connected objects and innovation based on this data.
Visa welcomes the opportunity to provide feedback on the Data Act proposal and to support the overall objective of the European Commission to facilitate data access and data use, and to promote data sharing while preserving incentives to invest in data innovation as a fundamental condition to establish the European Single Market for Data and to enhance the development of the data economy in Europe.
As the world leading provider of location data and services, HERE Technologies appreciates the opportunity to provide feedback on the proposed EU Data Act. Enhancing data availability, access and re-use are key prerequisites to develop a fully-fledged EU Data Economy and pave the way for a true EU Digital Sovereignty, that both Member States and the European Commission are aiming for.
Please find MedTech Europe’s full answer attached. MedTech Europe shares the Commission’s objective to address barriers for data sharing. In our view, the Data Act needs to provide clear definitions in alignment existing legislation. Where health data is generated as part of the authorised use of medical devices, healthcare professionals play a crucial role in interpreting the data.
10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological…
BDI supports the EU Commission’s intention and objectives of promoting the use and fair sharing of data. However, there are serious concerns that with the Data Act-proposal these goals can be achieved. In our position paper, who provides general remarks and thus specific comments on the various chapters.
Filed in German · English published by the European Commission
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The societal importance of data is growing as it has become a key raw material for new business, research and knowledge-based decision-making. Europe’s future success depends to a large extent on how we manage the emerging data society and ensure availability and re-usability of good-quality data for all legitimate purposes.
Section ELSA (ethical, legal and social aspects) of National Research Data Infrastructure (NFDI) e.V., welcomes the EU initiative to promote FAIR data sharing practices as well as harmonised rules on data access and use (EU Data Act Proposal) in the field of research. However, we see a significant need for clarification in several areas of the proposed regulation.
Filed in German · English published by the European Commission
FEM welcomes the European Commission’s proposal to foster the EU data economy. The transition of the EU to a data-driven economy will generate a considerably positive impact on the future growth and competitiveness of European industries. Materials handling equipment in operation has already become smart.
FNSEA considers that, as it stands, the draft Data Act makes it possible for farms to make real progress, particularly in terms of controlling the use of agricultural data, and of their portabilities and interoperability. Protection against unfair contract terms involving non-personal data will foster the exchange of data sought by this draft Regulation.
Filed in French · English published by the European Commission
Technology Industries of Finland welcomes the Commission initiative on putting use data of connected machines into use. Globally, the Commission's proposal marks a third way between Eastern and Western approaches and aims especially to help SME companies in their digitalisation pathway.
The German insurance industry welcomes the legislative proposal for an EU Data Act. The landmark dossier creates important foundations for data exchange and data portability. As an active participant in the data economy, the insurance industry would like to contribute to the process with the following comments: Motor insurers in particular support the Data Act, but would also prefer a dedicated, sector-specific…
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The German Banking Industry Committee (GBIC) welcomes the objective pursued by the proposal for a European Data Act, namely to establish a horizontal legal framework to facilitate the access to data for, and the exchange of data between, consumers and businesses. Data-driven innovation and services are becoming increasingly important, both for individual businesses and the European economy as a whole.
Beltug, Cigref, CIO Platform Nederland and Voice-e.v. jointly support the Commission’s ambition to ensure fairness in how the value of data is allocated among actors who are active on different levels of the data value chain. Data is not only a core component of the digital economy, but also a strategic asset of business users, in all sectors.
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The German Confederation of Skilled Crafts and Small Businesses (ZDH) explicitly welcomes the proposal for a European data law (Data Act). Fair access to competition-relevant data and open interfaces are essential for crafts operating in downstream markets. Remote maintenance and diagnostics are becoming common practices.
The International Road Transport Union (IRU) represents the voice of over 3.5 million companies providing mobility and logistics services. Transport and logistics innovations such as automated functions, connected vehicles, smart cities, and digital mobility platforms have increased data generation by transport operators.
Automotive technology is rapidly advancing, with vehicles generating and collecting ever greater quantities of data to operate and monitor systems. This can provide significant benefits to drivers, passengers, and other road users. This data is also valuable to an expanding market that can make use of it, offer new services to consumers, or improve upon existing repair and maintenance services.
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The Federation of European Publishers welcomes the opportunity to provide feedback on the European Commission’s proposal for a Data Act. FEP is the independent, non-commercial umbrella association of book publishers associations in the European Union. FEP represents 29 national associations of book publishers of the European Union and of the European Economic Area.
Allianz welcomes the proposal and its objective of advancing data sharing, strengthening data availability, and thus laying the foundations for the EU data economy. We particularly support the proposed empowerment of consumers that should be achieved by facilitating access to data and giving consumers more control over who can access and use their data.
STELLUNGNAHME Data Act Stellungnahme zur Verbändeanhörung 1. Rechtliche Zuordnung von Daten als Dateneigentum Der Data Act weicht der grundsätzlichen Frage aus, wem die Daten originär zustehen. Er betrachtet lediglich bestimmte Fälle oder Fallgruppen und versucht, dazu faire Lösungen zu schaffen. Die Methode zielt also auf die Symptome und nicht auf die Ursache von Rechtekonflikten.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The European Automobile Manufacturers’ Association (ACEA) appreciates the opportunity to give feedback on this proposal for a Data Act. ACEA supports the Commission’s ambition to put consumers at the centre of the data-sharing process and to achieve fair, reasonable, and non-discriminatory access to data across all sectors of the data economy.
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First, we would like to thank the European Commission (EC) for the opportunity to participate and discuss this proposal. Data sharing is a critical element of the digital economy, which must contribute to a diverse and lively data ecosystem. It is necessary to navigate complex and ever-changing technologies. Efforts to incentivize data sharing are essential to fostering competitiveness and protecting end-user data.
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Japan Electronics and Information Technology Industries Association 10 May 2022 JEITA Comments on the Proposal for a Regulation of the European Parliament and of the Council on Harmonised Rules on Fair Access to and Use of Data (Data Act) The Japan Electronics and Information Technology Industries Association (JEITA) is Japan’s leading digital association, with around 400 members from Japan and abroad.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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JAMA welcomes the Commission’s proposal for a Data Act which would i) remove barriers in B2B (business-to-business), B2G (business-to-government) and B2C (business-to-consumer) data access; ii) define the legal basis of data sharing; iii) prevent illegal data transfer from the Union; and iv) clarify the access to data generated by the use of connected products and related services.
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Liberty Global welcomes the Commission’s efforts to ensure a fair allocation of data across the data economy and foster access to and use of data. For the proposed Regulation to truly support data sharing it must abide to the principles of appropriateness, proportionality and legal certainty.
In principle, ZVEI supports the goals of improved data allocation and the integration of data producers into the data economy as described in the Data Act proposal. In order to fully leverage the value creation potential of industrial and machine data, it must be possible for data to flow to the actors in the value chain which generates the greatest added value from the data.
Filed in German · English published by the European Commission
With the Data Act, the European Commission aims to facilitate the availability of data while respecting fundamental European values. In principle, the Bundesverband Verbraucherzentrale Bundesverband (vzbv) welcomes the fact that (non-personal) data should be made more available. This is also desirable from a competition point of view.
Filed in German · English published by the European Commission
BSA | The Software Alliance (“BSA”) is the leading advocate for the global software industry before governments and in the international marketplace. Our members are enterprise software companies that offer technology services that other organizations use—such as cloud storage services, customer relationship management software, and workplace collaboration software—to make their own operations more efficient…
Moje Państwo Foundation 25/31 Nowogrodzka Street 00-511 Warsaw, Poland Transparency Register no.: 020222326905-75 Opinion of Moje Państwo Foundation on the Proposal for a Regulation of the European Parliament and of the Council on harmonised rules on fair access to and use of data (Data Act) Warsaw, 9 May 2022 1.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
CropLife Europe welcomes the objectives of the Data Act and believes this is a fundamental aspect for the long term success of digital and precision agriculture in Europe. We therefore greatly appreciate the opportunity to participate in this public consultation and look forward to further discussing with the EU Institutions and relevant stakeholders. Please find attached our detailed feedback on the proposal.
STM (https://www.stm-assoc.org/) supports its members in their mission to advance research worldwide. As academic and professional publishers, learned societies, university presses, start-ups and established players, we work together with the science community to serve society by developing standards and technology to ensure research is of high quality, trustworthy and easy to access.
APPLiA welcomes the Data Act as a key enabler for a data-driven economy that guarantees a fair treatment of data and ensures innovation. The full realisation of the potential of data-driven innovation requires the creation of a governance framework for data access.
ÖAMTC welcomes the EU’s data law proposal as a first important step to return to the European Konsument:innen its data sovereignty in an increasingly digitalised daily life. However, it must be said that a scheme established for household and consumer electronics is not suitable for achieving the desired objectives also in the automotive sector.
Filed in German · English published by the European Commission
The Commission has invited for an open consultation on the Data-by-scheme proposal. KL hereby sends your contribution and thanks you for the opportunity to submit comments. KL is an organisation of interests for the 98 Danish municipal councils and works to ensure that municipalities have the best possible framework to prioritise well-being and economics and to develop the municipality locally.
Filed in Danish · English published by the European Commission
On behalf of the Center for Data Innovation (Transparency Register #: 367682319221-26), we are pleased to submit this feedback on the European Commission’s adopted proposal for the Data Act. The Data Act contains fundamental pitfalls and needs significant modification so as to not harm the European data economy.
OVHcloud, the leading European cloud provider, supports the European Commission’s ambition to promote more fairness and legal certainty for data sharing and processing in a B2G and B2B environment. Ensuring consistency with its long-term engagements and current activities, OVHcloud encourages the establishment of a fair European data economy, based on three pillars: fair competition, fair protection and fair…
Please see attached file. I submit this as president of the European copyright society on behalf of the society. The society is a platform for critical and independent scholarly thinking on European Copyright Law and policy.
Volkswagen Group welcomes the efforts of the European Commission to establish a flourishing data economy within the EU. The Data Act constitutes a main pillar of the European Data Strategy and is an essential milestone to achieve the single market for data.
Huawei is grateful for the opportunity to provide feedback on the European Commission’s Proposal for a Regulation Of The European Parliament And Of The Council on harmonised rules on fair access to and use of data (hereinafter referred to as the “Data Act”), a crucial piece of legislation which will support the EU in fulfilling its digital ambitions, foster the single market, and consolidate Europe’s position as a…
The Big Data Value Association (BDVA) is a European industry-driven research and innovation community on Big Data, Data Value, and Industrial AI. BDVA is also a unique platform for pre-competitive collaboration between industry and research, combining a research-oriented and experimental approach to data-driven innovation and a focus on competitiveness and adoption.
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French Fédération Nationale de l'Automobile (FNA) has been the professional organization representing craft businesses in the automotive sector and in mobility services since 1921. Their representatives are supporting entrepreneurs and craftsmen whether they are self-employed or affiliated with a network.
Orgalim represents Europe’s technology industries, world leaders in connected products and production systems, which are becoming increasingly “intelligent” via data-based services. The transition to a data-driven economy is of paramount importance for the future growth and competitiveness of our industries.
Wirtschaftsverband der deutschen Ref. Ares(2022)3632766 - 12/05/2022 Kautschukindustrie e.V. wdk views on Data Act and Access to invehicle data initiatives The tyre industry welcomes the publication of the Data Act proposal as it represents a horizontal, high-level, principle-based regulation aiming at deploying a cross-sectoral governance framework for data access and use in line with the spirit of European Data…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
With its draft Data Act (Data Act-E), the EU Commission has presented far-reaching regulations for the access and use of non-personal data in the EU. In our view, the Data Act as a horizontal regulation - if done right - offers the opportunity to shape an open and democratic data economy guided by European values, in which there is a fair distribution between those involved in the creation of value.
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The French Publishers Association (SNE) welcomes the opportunity to provide a feedback on the European Commission’s proposal for a Data Act. SNE is France's trade association of book publishers. It represents approximately 788 member companies whose combined business endeavors account for the bulk of French publishing and whose total turnover amounted to 2.7 billion € in 2020 (3.7 billion € expressed at the retail…
The German Council for Scientific Information Infrastructures (RfII) was established by the Joint Science Conference (GWK) of the Federal Republic of Germany to provide advice on the enhancement of scientific information infrastructures and related topics of the digital turn in science and humanities.
VDMA represents more than 3,400 German and European companies of the mechanical engineering industry. The industry stands for innovation, export orientation and medium-sized businesses. Our companies are solution providers for digital manufacturing and are core enablers for Industry 4.0.
As a third party or an end user, Enedis welcomes the proposal bringing more transparency on data processing services and granting consumers and businesses with more data. Should the definition of “product and associated services” apply to electricity smart meters, Enedis would like to insist on its commitment to make energy consumption and generation data available to users.
ETRMA views on Data Act and Access to in-vehicle data initiatives The tyre industry welcomes the publication of the Data Act proposal as it represents a horizontal, highlevel, principle-based regulation aiming at deploying a cross-sectoral governance framework for data access and use in line with the spirit of European Data Strategy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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The Federation of European National Statistical Societies (FENStatS) is an independent European scientific organisation with non-profit and non-political motives, aiming to promote mutual communication, cooperation and statistical research in Europe. FENStatS advocates for the key role of statistics and data in Society and supports the diffusion of statistical education.
Although SNCF welcomes the objective of improving the availability and exchange of data, it is somewhat concerned about the lack of clarity and inaccuracy of the proposed Regulation. The means of implementing that regulation appear disproportionate to the objective pursued. In particular, the increase in the burden and costs on data holders seems disproportionate.
Filed in French · English published by the European Commission
Confederation of Finnish Industries (EK) is the leading business organization in Finland. EK represents the entire private sector and companies of all sizes. We have 20 member associations and 15,300 member companies across all business sectors (96% SMEs), and our member companies employ 900,000 employees.
In the context of the implementation of a fair and equitable data economy defined by the Commission, the Fédération Bancaire Française welcomes the publication of the draft Data Act, in that it lays the foundations for a new pillar for harmonising data sharing at European level, thus helping to strengthen the EU’s digital sovereignty and innovation potential.
Filed in French · English published by the European Commission
The Weizenbaum Institute for the Networked Society in Berlin congratulates the European Commission for approaching an important milestone in the implementation of the data strategy announced two years ago. The Data Act legislative proposal includes a package of measures that are expected make more IoT data available to data-driven enterprises.
RELX welcomes the opportunity to provide feedback on the European Commission’s proposed regulation on fair access to and use of data (Data Act). RELX is a global provider of information-based analytics and decision tools for professional and business customers.
With currently more than 21 million members, ADAC e.V. is the largest automobile club in Europe and the second largest in the world. The four letters in its name stand for an association which offers its members assistance, protection and advice around the clock and is a powerful stakeholder on all mobility issues.
Filed in German · English published by the European Commission
Feedback from the consultation on the proposal for a Regulation on harmonised rules for fair access and use of data (Data Act) As the current version of the proposal for a Data Act published by the European Commission on 23 February 2022 has an extraordinary impact on the medical devices industry, the Bundesverband Medizintechnik e.V.
Filed in German · English published by the European Commission
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COCIR welcomes the opportunity to provide feedback to the European Commission’s proposal for a European Data Act. Without a doubt, Data Act will play an important role in shaping Europe’s digital future. The proposal aims mainly at creating a regulatory framework to ensure fairer value allocation from data and foster access to and use of data.
10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological…
UNIFE - the association of the European rail supply industry - supports the European Commission’s objective to increase access to and further use of data, in both the B2B and the B2G contexts. We firmly believe in the added value of data sharing and the development of an inclusive data ecosystem to maximize the benefits of data for the mobility ecosystem.
Please find SMEunited complete feedbacks attached. Overall, we very much welcome the initiative to take a horizontal approach to lay down common basic rules for all sectors regarding data access. The Data Act is a significant step towards a more competitive and innovative data economy, and it is crucial for SMEs to have better and fairer access to data.
New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological transition and vehicle electrification. As with any digital technology, data represents the key component in these developments.
10 May 2022 Joint Statement on Data Act and the need for a sector-specific legislation on access to in-vehicle data By ACA, FFEA, FRANCE ASSUREURS, MOBILIANS, MOBIVIA, SESAM LLD, SNSA & UFE; connected mobility players New services arising from vehicle connectivity will improve peaceful driving, comfort and life of drivers and passengers, while contributing to road safety, infrastructure optimization, ecological…
The European Association of Co-operative Banks (EACB) welcomes the possibility to contribute to the discussion on the Data Act legislative proposal. We support the Commission’s general principle of facilitating the sharing of data. Sharing should be based on free choice, voluntary and on a contractual basis.
The European Savings and Retail Banking Group (ESBG) welcomes the European Commission's data strategy and its commitment to create a single market for data that will constitute a potential source of growth and innovation. A European approach to data is essential to ensure competitiveness, avoid fragmentation of national regulations, and benefit from an effect of scale.
We, the Japan Intellectual Property Association “JIPA”, are a private IP user organization with about 970 major Japanese companies as members. JIPA presents its compliments to the European Commission, and with respect to the feedback on "Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on harmonised rules on fair access to and use of data(Data Act, COM(2022) 68 final)", has honor to attach…
The Data Act constitutes a horizontal regulation for all IoT application fields even though there appears to be no apparent evidence of market failure or information asymmetries, or only in very specific market segments. Therefore, such a broad regulatory intervention seems premature and could even create new obstacles for the desired market uptake of the European data economy in industry.
Open-Xchange would like to thank for the opportunity to provide comments on the Commission’s proposed text for the new Data Act. We generally support the Commission’s objectives and the current proposal, but we would like to address the issue of data sharing obligations for software and hardware products operating in the homes of European consumers, such as browsers, smartphone apps, smart TVs, IoT products etc…
Please find attached FEBIS ' comments on the Data Act proposal. FEBIS stands for Federation of Business Information Services, the specialized and recognized industry body of providers of global B2B business intelligence services for managing trade risks. Today´s 140 plus members of our federation are present in nearly 60 countries throughout Europe, Asia, Africa, and the Americas.
Please find the full comments of the German Economic Institute on the Data Act enclosed (in German). Our key feedback is the following: The aim of the Data Act is to ensure that more data is available in Europe and that the potential of the data economy can be exploited.
Filed in German · English published by the European Commission
11th May 2022 EU Data Act Comments March 2022 ______________________________________________________________ The Spanish Banking Association welcomes the opportunity to contribute to the European Commission's feedback period on the Data Act & amended rules on the legal protection of databases. Our main comments on the proposal are set out below. I.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The undersigned members of the Law and Technology Group of Sciences Po Law School, identified as it appears in our signatures, respectfully submit the following comments to the Proposal for a Regulation of the European Parliament and the Council on harmonised rules on fair access to and use of data (“Data Act”), open for open consultation and feedback from stakeholders from 14 March to 13 May 2022.
Please find the full feedback of the Federation of Finnish Enterprises attached. Our key messages are: - The proposal is a significant step towards a more competitive and innovative data economy in Europe and, if implemented effectively, improves SMEs’ opportunities to access, share and use data, and to switch data processing services.
The PFA (Plateforme de la Filière Automobile) welcomes the European Commission’s Data Act proposal and its intention to increase the breadth and depth of data usage within the European Single Market. In our attached position paper (short version), we provide general feedback on the text to feed the legislative debate.
To the European Parliament and Council After two years of pandemic crisis and with the implications of this Russian invasion for the European economy, Europe is taking important decisions. Both the pandemic and the war in Ukraine are huge external shocks with potentially different outcomes across the EU.
Data Sovereignty Now’s contribution to the EU Data Act - As the member organisations of the Data Sovereignty Now (DSN) campaign, we herewith outline our input for the Data Act. We welcome the Data Act and applaud the fact that it marks the first time that data sovereignty is being included in EU regulation, giving people and organisations control over the data they generate.
City authorities welcome the proposed Data Act to regulate the access, sharing and use of privately held data, however, there is a series of crucial aspects that need further attention and clarification. Limited scope: Limiting the scope of B2G data sharing to exceptional need reduces the potential of city governments to exploit the data for the benefits of citizens and society.
Berlin, 10. Mai 2022 STELLUNGNAHME Deutscher Juristinnenbund e.V. Vereinigung der Juristinnen, Volkswirtinnen und Betriebswirtinnen Geschäftsstelle / Office: Anklamer Straße 38 ● D-10115 Berlin fon: [phone removed] ● fax: [phone removed] [email removed] ● https://www.djb.de zum “Vorschlag für eine VERORDNUNG DES EUROPÄISCHEN PARLAMENTS UND DES RATES über harmonisierte Vorschriften für einen fairen Datenzugang und…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
10 May 2022 Feedback of OFS Portal on: Proposed EU Data Act on harmonized rules on fair access to and use of data [2022/0047(COD)] Introduction and Background OFS Portal, LLC is a member based organization owned by its six members, who are all suppliers of oil and gas exploration products and services. Some of those members include Baker Hughes, Halliburton, Schlumberger and Weatherford.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The EU is one of the very few regions in the world that recognises an additional layer of intellectual property protection on non-original databases. In 2015, the European Commission carried out an initial evaluation of the "Database Directive" and the new sui generis right. The Commission states: "Is sui generis protection therefore necessary for a thriving database industry?
On February, 23rd, the European Commision proposed a regulation on who can use and access data generated in the EU across all economic sectors: the proposal of a regulation on harmonized rules on fair access to and use of data (Data Act). The following document presents the input from Adigital to the Data Act open feedback period.
Dear members of the EU Commission DG CNECT, The Enel Group is a multinational company and a leading operator in the power and renewables markets of Europe and worldwide. The Enel Group welcome the Act as a positive step towards a Europe fit for the digital age, and see some possibilities to improve the holistic, practical, executional side of the Data Act, below summarized and fully explained at the position paper…
General Comments We support the aim of the Data Act, as part of the EU’s Commission’s data strategy, to promote greater sharing and reuse of data and to ensure fairness among players. After the coronavirus outbreak, more than ever data has become an essential asset for crisis management and prevention and in general for the economic recovery of the EU, given its potential for innovation and job creation, as well as…
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The tyre industry welcomes the proposed Data Act as it represents a horizontal, high-level and principle-based regulation that aims to implement a cross-sectoral governance framework for data access and use in the spirit of the European Data Strategy. A successful data law will be essential for transforming the use of data in Europe in all sectors, including the further development of smart and sustainable mobility.
Filed in Spanish · English published by the European Commission
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The FNTP welcomes the proposal for a European Data Act as it was essential to address the issue of data at European level in order to avoid fragmentation of national regulations. Too broad or absent definitions: The FNTP considers that the scope of the Data Act is unclear due to too broad definitions, in particular on data, which leads to risks of legal uncertainty.
Filed in French · English published by the European Commission
The AFCAR coalition welcomes the underlying principles and objectives of the Data Act, in particular as regards the regulation of B2C and B2B data exchange. We fully support the principle of data sovereignty of users of connected products, including their right to allocate access to data generated by the use of their products to third-party service providers of their choice.
Filed in Spanish · English published by the European Commission
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LKQ Europe, a subsidiary of LKQ Corporation, with its head office in Zug, Switzerland, is the leading distributor of automotive aftermarket parts for cars, commercial vans and industrial vehicles in Europe. It currently employs approximately 26,000 people with a network of more than 1,000 branches and approximately $6.1 billion in revenue in 2021.
E.DSO welcomes the opportunity to provide feedback to the European Commission’s Data Act proposal. E.DSO fully endorses the Commission’s view that the availability of and access to data holds immense potential for innovation and value creation, and that this will greatly contribute to the recovery and resilience of the society post COVID-19 pandemic.
The Finnish Innovation Fund Sitra promotes the fair data economy model that is human-centric and creates benefits to all participants from all sectors. Our vision is in line with the European strategy for data (2020) and the attempt to create a single market for data built on European values. Sitra supports the Data Act as a core part of the fair data economy.
With the draft Data Act creating harmonised rules for fair access and use of data, the European Commission presents another building block of the comprehensive data strategy. However correct the aim is to build a strong data economy in the EU, some of the funds are critical.
Filed in German · English published by the European Commission
The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication. 99,6% of our members are SME.
On 23 February 2022, the European Commission presented its proposal for a regulation establishing harmonised rules for fair access and use of data, known as the Data Act, which MAIF warmly welcomes. Since 2020, MAIF has been working on the development of a European Personal Information Management Systems (PIMS) that will allow users to keep control of their data through their consensual and secure use within an…
Bitkom welcomes the European Commission’s Data Act proposal and its intention to increase the breadth and depth of data usage and innovation within the European Single Market as this will help to fuel the digital transition by offering countless new opportunities to European citizens and businesses.
Micro, small and medium-sized enterprises are duly involved in the digital economy and receive tangible benefits from it. According to the France Num Barometer, conducted in October 2021, 78 % of the managers of micro, small and medium-sized enterprises consider that digital technology represents a real benefit for their business.
Filed in French · English published by the European Commission
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We welcome the limitation of the scope of the Regulation to holders and recipients of data collected through IoT devices, manufacturers of IoT devices, the public sector and data processing service providers. However, the scope is still not clearly defined.
OpenAIRE welcomes EU's initiative to develop a comprehensive framework for Data Sharing both in the B2B and the B2G context and would like to thank the European Commission for the opportunity to provide feedback at the stage of inception of such policies.
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For aeronautics Business 2 Government (B2G), GE Aviation would like to state that this aspect is fully covered by the applicable aviation Regulations, as they cover which data must be shared with authorities for certification, organisational oversight, safety monitoring etc.
A European data economy should grant access to and use of data in a transparent, inclusive, fair and competitive manner while ensuring data security and privacy for data owners, data providers and data consumers. In traditional centralized data markets, the data assets are often controlled by third parties, and the data security depends on the security measures taken by the market provider.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The National Library of Luxembourg and the French consortium Couperin.org would like to thank the European Commission for the opportunity to comment on the Inception impact assessment of the coming Data Act, which we support.
COCIR welcomes the opportunity to provide feedback to the European Commission’s inception impact assessment for a Data Act. COCIR fully endorses the Commission’s view that the availability of and access to data holds immense potential for innovation and value creation, and that this will greatly contribute to the recovery and resilience of our society following the COVID-19 pandemic.
Data Act Inception Impact Assessment Broadcom would like to thank the European Commission for the opportunity to provide feedback on the intended initiative and to participate in the consultation activities. Broadcom provides data processing services such as cloud computing services among other products and services. Broadcom is a provider of Software as a Service (SaaS) through its CA and Symantec businesses.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Belron® is the worlds leading vehicle glass repair, replacement and recalibration service provider, operating in over 25 countries in Europe with brands such as Carglass®, Autoglass® and Safelite®. As a key provider of aftermarket services in the automotive industry, Belron is cognisant of the increased role that data is playing in the ability to create, offer, and ultimately provide services to consumers.
The Fédération Française du Bâtiment (Fédération Française du Bâtiment) welcomes the European Commission’s initiative to introduce fairness and harmonised rules in the data-driven economy. It thus supports the draft Data Act, which aims to enhance the interoperability of systems and develop data portability in value chains.
Filed in French · English published by the European Commission
The European Banking Federation (EBF) welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) on the Data Act and continues to support its ambition to build a Single Market for Data in Europe. Making more data available and improving the way in which data is accessed and used is essential for tackling a wide array of challenges.
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The German transport association (Verband Deutscher Verkehrsunternehmen, VDV) welcomes the Commission’s initiative to increase good governance and fairness in the data economy by fostering in particular business to government (B2G) data sharing.
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The European Chemical Society (EuChemS), an international organisation comprising 50 member societies from Europe and beyond and having had a representative on the EC’s High Level Expert Group Open Science Policy Platform (OSPP) 2016-2020 welcomes the Commission’s initiative to clarify and harmonise data sharing provisions across the EU and especially B2G data sharing rules, which do remain unclear for part of the…
Leaseurope feedback to the Data Act Leaseurope, the European Federation representing the leasing and automotive rental industries, fully supports the European Commission’s intention to create a Single Market for data and to create fairness in the data economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EU’s Data Strategy sought two complementing measures (1) an enabling legislation for governance of EU’s common data spaces, the now draft Data Governance Act (DGA), and (2) a more substantive legislation governing relations among various data actors, including laying out rights of data access and use.
(see PJ for full opinion) The agricultural and agri-food sector in Europe is characterised by a very large number of small and medium-sized enterprises. There are more than 10 million farms at European level. The interconnection between these structures is important and necessary for the functioning of the entire economic sector.
Filed in French · English published by the European Commission
25 June 2021 Microsoft feedback on the European Commission’s Data Act Inception Impact Assessment (IIA) Microsoft welcomes the opportunity to respond to the Inception Impact Assessment (IIA) for the Data Act and its ambition to foster data sharing and data-driven innovation.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Please find attached the feedback of ACT | The App Association (Transparency Reg. # 72029513877-54) to the European Commission’s roadmap for a Data Act. Anna Bosch Policy Associate ACT | The App Association (Transparency Reg. # 72029513877-54) Rue de Trèves 45 B-1040 Brussels
IBM welcomes the opportunity to comment on the policy options that the European Commission is examining and contemplating for the ‘Data Act’. Creating and promoting more fairness in the data economy, with the aim to increase legal certainty for data sharing in Europe, is a laudable objective and one we support.
EuroCommerce welcomes the opportunity to provide feedback to the European Commission’s Inception Impact Assessment on the Data Act. We welcome the effort of the European Commission to establish legal certainty and to promote more data sharing. It is important to ensure that any future (legislative) framework encourages competition and the development of new business models.
Dear Members of DG CNECT G.1, Enel SpA, a multinational company in the energy sector, highly appreciates the EC proposal for a regulation aimed to create fairness in the data economy by addressing the difficulties of access to and use of data. Enel especially welcomes the willingness to establish more competitive markets for cloud computing services.
EFPIA Comments on Inception Impact Assessment for Data Act (including the review of the Directive 96/9/EC on the legal protection of databases) EFPIA welcomes the chance to comment on the Inception Assessment for the Data Act. We note the objectives of the Act to: - Promote fair reliable and transparent B2G data sharing.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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ETNO, the European Telecommunications Network Operators' Association, welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment for a future Data Act. Please find attached our comments: "ETNO_response to Data Act IIA.pdf". Best regards,
The VKU is grateful for the opportunity to comment on the Commission’s impact assessment on the so-called Data Act. Position of the VKU in the near future: The VKU welcomes the Commission’s intention to use private sector data for the common good.
Filed in German · English published by the European Commission
The Data Act is an important addition to the Data Governance Act (DGA), that further completes the European Data Strategy. While the DGA provides the framework for data sharing to take place in the first place, the Data Act seems to be designed to provide the economic conditions to foster the emergence of sectoral data spaces.
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FIGIEFA’s feedback on the Data Act-Roadmap focuses on the scope and objectives of the Commission’s initiative, as mentioned in the Inception Impact Assessment report. FIGIEFA is the European Federation which represents the businesses of independent wholesalers and retailers of automotive replacement parts and their associated repair chains, together with its 20 National (European) members.
ETNO, the European Telecommunications Network Operators' Association, welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment for a future Data Act. Please find attached our comments: "ETNO_response to Data Act IIA.pdf". Best regards,
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Booking.com welcomes the opportunity to provide input to the Commission’s work on the future Data Act initiative. We share the view that data is at the centre of the digital transformation of today’s economy and society.
CLEPA appreciates the intention of the Commission to provide with the Data Act a robust regulatory framework as general guidance for data sharing and to raise the awareness of businesses on the benefits of data sharing is a pre-requisite to allow all parties to benefit from data-driven innovation.
BSA | The Software Alliance Response to the European Commission’s Data Act Inception Impact Assessment Brussels, June 2021 BSA | The Software Alliance (“BSA”) 1 welcomes this opportunity to offer these comments in response to the European Commission’s Inception Impact Assessment on a proposed Data Act (the “IIA”).
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
STM welcomes the opportunity to provide feedback on the European Commission’s (the “Commission’s”) Inception Impact Assessment on the future Data Act. STM welcomes the overall goal of the Commission to work towards the creation of a Single Market for data, where data flows between countries and sectors, where data is available for use in full respect of European values and rules, and where there are fair, practical…
Mastercard welcomes the opportunity to provide feedback on the Inception Impact Assessment (IIA) of the European Commission’s future Data Act (including the review of the Directive 96/9/EC on the legal protection of databases). Mastercard is supportive of the development of a human-centric data ecosystem which will encourage public entities and business to share and use data in a fair and transparent way.
About the GFII: created in 1979, the GFII, the French organization of information professionals, is a unique association in the data landscape that brings together private and public data producers and re-users, such as the French Ministry of Interior, Total, Crédit Agricole, BNP Paribas or The French Ministry of Environment.
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Access, interoperability, and the use of high-quality data are cornerstones of research and innovation. Science Europe, therefore, welcomes the initiative of the European Commission, as outlined in the European Strategy for Data from 19 February 2020, to create a single market for data that would enable the digital transformation of society through more and better access to data.
About the GFII: created in 1979, the GFII, the French organization of information professionals, is a unique association in the data landscape that brings together private and public data producers and re-users, such as the French Ministry of Interior, Total, Crédit Agricole, BNP Paribas or The French Ministry of Environment.
DIGITALEUROPE welcomes the possibility to provide feedback on the European Commission’s inception impact assessment for a Data Act and a revision of the Database Directive. Find attached all our comments. We also plan to reply to the public consultation. - Scope: The different notions applicable to the Data Act will need to be carefully defined.
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IP Federation’s response to the European Commission’s Inception Impact Assessment on the Data Act and amended rules on the legal protection of databases. Founded in 1920 in the UK, the IP Federation represents IP intensive companies who are extensively involved in business activity in Europe and internationally across a range of industries.
cecra.eu Brussels, 25 June 2021 Subject: Feedback from CECRA on Data Act & amended rules on the legal protection of databases. About CECRA: The European Council for Motor Trades and Repairs (CECRA) is the European federation of professional associations representing the interests of automotive dealers and repairers.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
25 June 2021 FEEDBACK ON THE EUROPEAN COMMISSION'S DATA ACT 1. BACKGROUND ON ECIS 1. The European Committee for Interoperable Systems ("ECIS") is an international, non-profit association of information technology companies founded in 1989 which endeavours to promote a favourable environment for interoperable ICT solutions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Workday is pleased to have the opportunity to comment on the European Commission’s Inception Impact Assessment (IIA) for the proposed Data Act. Workday is a leading provider of enterprise cloud applications for finance and human resources, helping customers adapt and thrive in a changing world.
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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.
The Data Act will introduce important new rules concerning inter alia access to data held by the private sector, data portability rights, and the interplay between proprietary interests pertaining to data on the one hand, and the newly established rights of access to the data on the other hand. Such new rules are expected to have more than just a marginal impact on the EU data economy.
Gisad welcomes the European Commission’s initiative to regulate the exchange of data by law in order to ensure respect for copyright, citizens’ sovereignty and optimal exploitation by industry. However, already in the EU’s opinion on the impact assessment of this initiative, it is clear that it is likely that it will not be possible to meet the partially contradictory objectives.
Filed in German · English published by the European Commission
ISFE response to the Data Act Inception Impact Assessment - Public Consultation Transparency Register Identification Number: 20586492362-11 1. ISFE welcomes the opportunity to respond to the Inception Impact Assessment Consultation on the Data Act and supports its overall objective to ensure fairness in the allocation of economic value among actors of the data economy.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Insurance Europe welcomes the overall objective of the European Commission to create a single market for data, where data from public bodies, businesses and citizens can be used safely and fairly for the common good. For insurers, a greater availability of data could lead to improved risk monitoring and assessment, better customer experiences and increased fraud detection.
Facebook appreciates the opportunity to comment on the European Commission’s Inception Impact Assessment on the Data Act. As a company at the forefront of technological innovation and investment globally, including in the European Union, Facebook believes in the benefit of data sharing where it can be done in a way that respects privacy, is consistent with data protection principles, and incentivises innovation.
RATP welcomes the Commission's effort to foster a more competitive and fairer data economy. Indeed, more than ever, a few actors of the digital economy are in position to capture available data and use them in services where the data producer will not get his fair value share.
Dear DG CNECT Unit G.1 Attached is our written submission signed by 16 energy system analysts. title : Submission on a proposed Data Act for the European Union from the perspective of energy system analysis — Release 07 filename : morrison-european-data-act-inception-submit_07.pdf format : PDF document, version 1.5 md5sum : 8fa3831abccabd98aff81965a961df32 From our perspective, we would like the European Union to…
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FEP takes note of the plan of the Commission to review the Database Directive as part of the incoming Data Act. Publishers rely on a daily basis on the rights granted by the Database Directive, including its sui generis right, to protect their databases, ensure legal access to them and ensure that their significant investments in databases are protected.
ZDH welcomes the possibility to provide feedback on the inception impact assessment (IIA) regarding the planned Data Act. General observations: The IIA pinpoints the core challenges for SMEs in acquiring data access and using data in business-to- business situations (B2B) and rightly focuses on the GDPR which plays a key role in data portability. We believe that Art. 20(2) GDPR is not fit for purpose.
Orgalim supports the facilitation of data access and use in business-to-business (B2B) and business-to-government (B2G) situations. Orgalim believes that the role of the legislator in this field should be limited only to measures that would encourage and foster B2B and B2G data sharing. Freedom of contract as the guiding principle should be at the heart of any new initiative.
Instrat is a progressive think-tank focused on public policy advisory. We provide research and consult on the digital economy, energy and environment, sustainable finance, labor market, and inequalities. We act in the public interest, in our work we create and adopt open access & open source tools.
ITI Response to Data Act Inception Impact Assessment Introduction The availability of large and diverse datasets from the private and the public sectors enables technology developers to innovate in the digital economy across industries and meet the needs of individuals and society.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
DANSK ERHVERV Børsen 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2021)4161505 - 25/06/2021 European Commission June 25th 2021 Comments from the Danish Chamber of Commerce on the Commission’s roadmap/IIA on the Data Act The Danish Chamber of Commerce is pleased to provide feedback on the European Commission’s IIA for the Data Act.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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BDI-Feedback BDI is convinced, that in order to make the EU data economy successful, it is necessary to increase the use and exchange of data based on legal certainty and trustworthy data infrastructures. However, in addition to making data accessible to many interested parties, the legal and economic interests of the data producers must be acknowledged equally.
The American Chamber of Commerce to the EU (AmCham EU) shares the objectives of the European Commission to increase access to and further the use of data through the proposed “Data Act”. AmCham EU provides below some suggestions and recommendations to ensure that the outcome of the Data Act will be to promote more data sharing and help Europe’s data economy to boost economic growth, research & innovation…
POLICY PAPER Ref. Ares(2021)4159816 - 25/06/2021 SMEunited input to the EC Roadmap on the Data Act SMEunited welcomes the opportunity to comment on the European Commission’s Roadmap on Data Act (including the review of the Directive 96/9/EC on the legal protection of databases), published on 28 May 2021. SMEunited agrees with the objectives of the initiative.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Members of the French Publishers Association, in particular legal, scientific, technical and medical publishers obviously rely on the database right, as a complement to Copyright. For instance : - legal databases often comprise raw data, not protected by copyright.
About eco: With over 1,100 member companies, eco is the largest Internet industry association in Europe. Since 1995 eco has been instrumental in shaping the Internet, fostering new technologies, forming framework conditions, and representing the interests of members in politics and international committees.
CIGREF welcome the Commission’s objective to ensure fairness in how the value from using data is shared among businesses, consumers, and accessible public bodies. We welcome a harmonised European approach with effectiveness, fairness, proportionality as guiding principles. This data strategy is also an opportunity to promote the international competitiveness of the EU market.
Filed in French · English published by the European Commission
EARE’s answer to the European Commission’s Inception Impact Assessment on the Data Act and amended rules on the legal protection of databases. 25 June 2021 The European Alliance for Research Excellence, a coalition of companies and research organisations formed in 2017 committed to the future of innovation and R&D in Europe, welcomes the European Commission’s ambitions to increase access to and further use of data…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
These are the contributions of the ESPAÑOL CENTRO DE DERECHOS REPROGRÁFICOS EGDPI (CEDRO) to the roadmap on the future “Data Act” and amending the rules on the legal protection of databases. Cedro is an intellectual property rights management organisation established in Spain, authorised to carry out its activities, in accordance with Spanish law, by the Ministry of Culture and Sport.
Filed in Spanish · English published by the European Commission
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As a global movement that, among others, develops and runs the world's largest free knowledge base Wikidata (made in the EU!) we acknowledge and welcome the hard work of the Data Policy and Innovation unit in freeing up data and making it re-usable over the past years. Thank you! In this feedback round we have decided to remain laser-focused on the issue that is the sui generis database right.
Ref. Ares(2021)4153008 The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents - 25/06/2021 all Austrian companies – some 540,000 businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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Initial Comments to the Data Act Technology Industries of Finland has more than 1,600 members in various fields of technology, of which roughly 1,500 are SME companies. We have been actively advancing data usage within our member companies and developing balanced and practical models for data usage and sharing. Commission proposes new practices for public sector access to business data.
Contribution of GANVAM to the roadmap for the Data Act: Data Access & Connectivity As the longest established and most representative Spanish association of the automotive distribution sector, GANVAM -the Spanish Association of Motor Trade, Repair and Parts- welcomes this opportunity to participate in the roadmap for a regulation that will have great impacts on our members.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Vodafone welcomes the publication of the Inception Impact Assessment on the EU Data Act and strongly support the key objectives of this file to harness the power of data to achieve the objectives of the European Green Deal, EU Recovery Plan and Digital Decade. If we get this right, enhanced sharing and reuse of data could unlock significant economic and societal benefits for Europe.
The National Federation of Public Works (FNTP) welcomes the Commission’s initiative to draw up a Data Act. Strong EU action on data is absolutely necessary. Indeed, the data produced by construction companies as part of their operations constitute a real asset that must be preserved in order to ensure the sustainability of the know-how in the field of construction.
Filed in French · English published by the European Commission
Contribution to the Data Act Roadmap To the attention of the European Commission DG CNECT G.1 (Data Policy and Innovation), Brussels, 24 June 2021 News Media Europe is the voice of the progressive news media industry in Europe, representing over 2,500 news brands in print, online, radio and TV.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
MAIF welcomes the will of the Commission to publish, by the end of the year, a Data Act to increase access to and further use of data. In this contribution, MAIF shares several key points raised in the inception impact assessment published on 28th May 2021.
EuroGeographics is an independent international not-for-profit organisation representing Europe’s National Mapping, Cadastral and Land Registration Authorities, responsible for a large set of public sector datasets including high value geospatial datasets that are defined in the Open data and PSI directive.
ID Register: 52431421-12 TELEFÓNICA COMMENTS ON EUROPEAN COMMISSION’s INCEPTION IMPACT ASSESSMENT FOR A DATA ACT June 2021 EXECUTIVE SUMMARY Telefónica supports the overall objective of the creation of a European model fostering data sharing and re-use across sectors and Member States.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The Computer & Communications Industry Association (‘CCIA Europe’) appreciates the opportunity to provide comments on the policy options which the European Commission (‘Commission’) is considering ahead of its proposal for a new Data Act.
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The European Data Centre Association (EUDCA) represents the European data centre (DC) operator community. The EUDCA is happy to submit feedback on the new rules for the common European data spaces and wants to draw attention to the following key points: • EUDCA members host several customers who regularly share and commercialise data on both B2B and B2G.
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The German Mechanical Engineering Industry Association (VDMA) represents over 3.300 mechanical engineering companies in Germany and Europe. Our companies are solution providers for digital manufacturing and are core enablers for Industry 4.0. Consequently, the exchange and usage of industrial data is of high importance for the innovation capacity and global competitiveness of our member companies.
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The German Data Forum (RatSWD) welcomes the plan to establish a data act. An enormous amount of data is already being produced in a variety places, but especially in the private sector. In light of this, it will be crucial to create a legal foundation for using this data, as well as involve equitable data collectors and data subjects in accordance with data protection requirements (especially Art. 89 GDPR).
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We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe and consider the creation of a European data space to be an important step towards strengthening the competitiveness and innovative capacity of European companies in international competition.
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BlackBerry, the global cybersecurity software and services company, welcomes the opportunity to provide input to the EC roadmap on the EU Data Act. We support efforts put by public authorities to promote data sharing and access, and welcome the Commission’s interest in the field.
It is absoletely mandatory to consider these two objectives: 1. 5G networks, Artificial Intelligence technologies and the Internet of Things raise security and privacy issues that could not be addressed only by GDPR.
For DEKRA, an independent TIC company, safety, security, and sustainability are our vision and mission. In the field of vehicle inspection, DEKRA represents a leader, whose objective is to ensure that vehicles are safe during their whole life cycle. To guarantee that future automated vehicles (AVs) also perform safely, access to in-vehicle data will be necessary.
The FIA European Bureau welcomes the Commission’s plans to address the systemic challenges of data access and use, as well as enhance citizens control over their data by means of a Data Act. Data-driven mobility The IIA recognizes the essential role of data in the digital economy. With the advent of the ‘connected car’, mobility is increasingly becoming software driven.
In general, Pex welcomes the Data Act Initiative which focuses on fair distribution of data in the economy. Many copyright stakeholders encounter imbalances on a daily basis when dealing with platforms which, in addition to copyright-protected content, store great quantities of metadata related to the said content.
Challenges with Data in Construction Sector The German Construction Industry would like to draw the European Commission’s attention to the specific challenges the industry faces in Europe with regards to Data. Introduction Digitalisation is a key driver for the construction industry.
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The Data Act and its roadmap a) Access to Data: Concerning B2B data exchanges, there should be sector specific regulations, but no general obligation to grant access to data. Contractual arrangements should be the preferred option. However, in certain industries such as the automotive sector, sector specific regulation is required in order to ensure fair competition between market participants.
We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe. To achieve this, it is crucial that especially SMEs have better and more equitable opportunities to access, share and use data.
FESE supports the plan of the European Commission in proposing an overarching data strategy that has the potential to achieve the benefits of the single market. To this end, we believe a harmonised European approach is preferable to speed up the use/investment in technologies while effectiveness, fairness, proportionality, the international competitiveness of the EU market, and the safety of its people should be a…
AI adoption in Europe has barely started as European companies are stuck in the GDPR trap. While the European commission is writing the standard contract clauses to give legal security to non-EU companies no European company can get legal security with respect to GDPR. The certification especially for European SME's as mentioned in 42(1) GDPR is not available until today.
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I noted the purpose is ''to help start-ups and SMEs to develop new products/services in the digital economy.'' ... OR, I run à Quick search for words on the PDF document: IPR, Intellectual, Proprety, IP, WIPO, EPO and did not find any. I do not think this legislative proposal is to destroy intellectual creativities of students, designers, authors, engineers & etc... It is not to lead new offerings available today.
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