Amnesty International

To ensure a just transition, the following changes must be made to the Critical Raw Materials Act (CRMA)*: Certification schemes: The CRMA must remove the reliance on certification schemes to demonstrate Strategic Project compliance with project requirements. These schemes vary significantly in their transparency, requirements and frequency and quality of assessments.

The attached position paper sets out Amnesty International’s concerns around the key gaps and shortcomings in the EU’s proposal for an Artificial Intelligence Act. As it stands the proposed regulation falls far short of the measures that will be required to meaningfully protect people from harmful AI systems in the EU and globally.

Civil liability and access to justice: The proposal includes a fault-based liability regime allowing people affected by corporate abuse to obtain judicial remedy. But major barriers to justice still remain as tort law in Member States puts the burden of proof on the claimants. Victims will need to provide evidence of the company’s breach of its duties which normally requires access to internal company information.

Amnesty International welcomes the Commission’s intention to launch a legislative initiative establishing mandatory rules for corporates not to harm human rights and the environment and to carry out due diligence and to request corporate directors to integrate wider societal and sustainability interests into business decisions.

Amnesty Internationals research shows that many Big Tech companies rely on and profit from a fundamentally abusive business model. Far from their claims of being a digital town square or a place for discovery and connection, online platforms have evolved over time to become ever more manipulative and extractive rather than empowering, informative and educational.

Amnesty International welcomes that the Digital Services Act (DSA) increases accountability of providers of online services, improves transparency of platforms’ practices and establishes clearer rules for content moderation. The fact that the DSA upholds the conditional liability exemptions and the prohibition of a general monitoring obligation to find illegal activity is equally welcome.

As the European Commission (EC) looks to modernize the EU’s batteries legislation, Amnesty International calls on the EC to ensure that human rights and environmental protection go hand-in-hand with the EU’s efforts to transition to green alternatives and address climate change.

Amnesty International welcomes the DMA’s focus on levelling the playing field and addressing the dominant role of gatekeepers over the online environment. However, Amnesty believes the DMA should put more focus on end-users and be more ambitious to allow competitors to the gatekeepers to emerge that offer more choice and better conditions to end-users. 1.

Amnesty International is strongly critical of the European Commission for the decision to appease the violations committed by the Latvia, Lithuania and Poland, instead of following up with a prompt and robust infringement process to uphold EU law, as mandated under the Treaties.