ANEC

ANEC fears that the Digital Omnibus proposal results in a reopening of the AI Act and risks undermining the carefully crafted political agreements reached by the co-legislators as well as the horizontal nature of the AI Act, thus lowering consumer protection. The proposal is creating a high level of legal uncertainty that not only puts at risk consumer rights but is also not in the interest of legitimate businesses.

ANEC contributes to this call for evidence focusing on the possible postponement of the applicability of the AI Act in case the Harmonised Standards for high-risk AI systems would not be ready on time. Postponing the applicability of the AI Act because the development of harmonized standards is delayed or for any other reason, would undermine both the purpose and credibility of the regulation.

The European Unions ambition to advance a circular economy presents a critical opportunity to reshape production and consumption patterns in ways that protect both the environment and consumers. In response to the European Commissions Call for Evidence for the forthcoming Circular Economy Act, ANEC- the European consumer voice in standardisation - calls for a systemic shift toward a resource-saving and…

ANEC welcomes the proposed regulation on packaging and packaging waste, as it will provide consumers with more convenient options for reducing their packaging waste. ANEC agrees with the choice of a regulation as the legal instrument as it will ensure equal implementation across Member States, unlike a directive.

In ANEC’s view, the "essential requirements" of the Packaging Directive are vague, do not give clear instructions to business and cannot be enforced. The associated CEN standards were intended to provide more detailed provisions and clarity, but the influence exerted by the European packaging industry in their drafting meant they do not contain the substantive requirements needed.

ANEC recognises some improvements have been made in the EC proposal for revision of the Energy Performance Directive COM(2021)802 compared to the current text. However, there are still several points where we believe more ambition is required to effectively boost renovation of buildings in the EU, lower CO2 emissions and achieve more energy savings.

ANEC clearly favours ‘policy option 3’; the amended EPBD is to address in particular the following 7 key aspects among the measures considered: - The update of the framework for Energy Performance Certificates is fundamental.

Raising standards for consumers POSITION PAPER ANEC comments on the European Commission proposal for an Artificial Intelligence Act (Regulation laying down harmonised rules on artificial intelligence and amending certain Union legislative acts) s COM(2021) 206 final, 2021/0106 (COD) Contact: [name removed] [email removed] ANEC is supported financially by the European Union & EFTA Ref: ANEC-DIGITAL-2021-G-071 July…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

As the European Commission’s assessment of product safety and liability legislation shows, there are gaps in present legislation and new AI related aspects such as explicability require new legal provisions, especially for enforcement purposes. We therefore support Option 3.c: EU legislative instrument establishing mandatory requirements for all applications.

We are pleased to share ANECs assessments and recommendations in response to the Commissions Proposal for a Directive on New rules on substantiating green claims. We do so based on our participation in standardisation over many years and policy discussions on Life Cycle Assessment (LCA), Environmental Performance Declarations (EPDs), carbon footprint, corporate environmental indicators and performance evaluation.

The intention set in the Green Deal to tackle misleading green claims is laudable. So too is the recognition that consumers need reliable, comparable and verifiable information on the environmental performance of products and services. We disagree, however, that the substantiation of claims should be done using the PEF/OEF method.

ANEC supports the objectives of the Single Use Plastics Directive as an essential instrument to reduce the environmental and health impacts of single use plastics. The Directive has driven significant progress through bans, consumption reduction measures and improved producer responsibility: - Deposit Return Systems have proven to be among the most effective measures for reducing the negative environmental impacts…

It has been known for a long time that the current regulatory framework for Food Contact Materials (FCM) is deficient and puts consumers at risk. Harmonised rules (particularly for plastics) are incomplete and outdated; implementing measures for most other materials are missing. So far, the Commission has done little to improve the situation.

Batteries are a priority topic for consumers. ANEC agrees with the Commission that considering and investing in the safety and sustainability of these products is crucial. ANEC supports setting sustainability and safety requirements for all batteries placed on the EU market.

Batteries are becoming a priority topic for consumers. With the ever-reducing price of Lithium-ion batteries and technologies, we have the reality that batteries (integrated with solar/wind) could viably be powering the entire home as well as the car, the bicycle etc.

We agree with the EC assessment that "the current restriction process is too slow to sufficiently protect consumers and professional users against risks from the most hazardous substances" and "the normal restriction procedure, through specific risk assessment, puts a high burden on authorities".

Raising standards for consumers POSITION PAPER ANEC comments on draft Cyber Resilience Act (CRA) ANEC contribution to public consultation Contact: [name removed] [email removed] European Association for the Co-ordination of Consumers Representation in Standardisation aisbl ANEC is supported financially by the European Union & EFTA [Type here] Ref: ANEC-2022-DIGITAL-CYBER-015 21/12/2022 Rue d’Arlon 80 – 4th Floor -…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANEC supports the broad scope of the initiative and agrees that a robust and coherent EU legislative intervention on cybersecurity will provide a more effective, less-fragmented protection for consumers. ANEC agrees that the CRA will complement and close gaps in the existing EU legislative framework. We submit the attached position.

Raising standards for consumers POSITION PAPER ANEC REPLY TO THE EUROPEAN COMMISSION CALL FOR EVIDENCE ON THE REVISION OF THE STANDARDISATION REGULATION Contact: [name removed] [email removed] [name removed] – [email removed] The European Consumer Voice in Standardisation aisbl ANEC is supported financially by the European Union & EFTA Ref: ANEC-SC-2025-G-[phone removed] Rue d’Arlon 80 – 4th Floor - B-1040 Brussels…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANEC welcomes the European Commission's initiative to identify opportunities for reducing unnecessary administrative burdens affecting housing supply and affordability. However, simplification should not come at the expense of consumer protection, safety, accessibility, housing quality or environmental performance. The full ANEC position paper is attached and provides detailed recommendations.

ANEC supports the establishment of a secure and interoperable registry provided for in Article 13 of the ESPR. While the registry is not expected to be directly accessed by consumers, it will be fundamental to the quality and trustworthiness of the DPP information consumers will receive through the web portal provided for in Article 14 of the ESPR, product data carriers, and other authorised services.

ANEC strongly calls for minimum recycled content requirements for plastic packaging to be aligned with the Chemicals Strategy for Sustainability and combined with: - objectives to minimize and phase out hazardous substances, and - requirements for information on content of hazardous substances to be included in the Packaging and Packaging Waste Regulation (PPWR).

The transport and mobility sector has huge potential for transformation. It has a tremendous opportunity to reduce GHG emissions as well as improve Noise and Traffic Congestion throughout the EU. ANEC, therefore, welcomes the Commission’s proposal for a regulation on the deployment of alternative fuels infrastructure (AFIR) that aims to enable widespread uptake of low- and zero-emission vehicles.

ANEC, the European consumer voice in standardisation, welcomes the opportunity to express its views on the European Commission Evaluation Roadmap/Impact Assessment published April. The EU urgently requires a new framework to work towards reduced emissions (zero emissions) and support the development of infrastructure for electric vehicles on European roads.

ANEC welcomes the European Commission’s inception impact assessment on the revision of the Machinery Directive. The Machinery Directive has generally worked well in providing a sufficient level of safety for consumers in the EU, as well as aiding the free movement of machinery products. Consumers benefit from the greater choice of products, and from competition. However, some limitations can still be observed.

ANEC has long emphasised that a safe and genuine circular economy must be founded on strong rules for the elimination of hazardous substances throughout the entire product lifecycle. In particular, legacy hazardous substances present in existing waste streams shall not re-enter the economy through recycling (https://tinyurl.com/j3svhj8z).

Raising standards for consumers POSITION PAPER ANEC reply to the European Commission proposals on Omnibus Directive and Regulation Aligning product legislation with the digital age Contact: [name removed] [email removed] [name removed] – [email removed] The European Consumer Voice in Standardisation aisbl ANEC is supported financially by the European Union & EFTA Ref: ANEC-WP1-2025-G-051 02/09/2025 Rue d’Arlon 80 –…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANEC strongly supports the proposed General Product Safety Regulation: The underlined value of the safety net function and precautionary principle Coherent market surveillance rules between harmonised and non-harmonised products as well as the new tools given to Member States Stronger traceability in the supply chain and a greater responsibility for safety of online marketplaces New provisions on connected products…

We agree to the problem definition, emphasising the challenges posed by new technologies, e-commerce and a fragmented legislative framework for market surveillance. We recommend Option 4. A full revision of the legal instrument is necessary to address safety risks brought by the Internet of Things and Automated Decision Making, to clarify the obligations of all actors in the supply chain, including online…

ANEC highlights persistent and structural shortcomings in the EU market surveillance system that continue to expose consumers to unsafe and non-compliant products. While Regulation (EU) 2019/1020 introduced important improvements, notably the requirement for an EU-established economic operator, ANEC considers that the Regulation has not achieved its core objective of ensuring that only compliant products reach the…

In general, ANEC welcomes the Commissions intention to modernise and simplify the technical requirements applying to type-approved motor vehicles regarding emissions. Air pollution is a very serious environmental and human health risk in European cities and the urban population is still exposed to pollutant levels above the limit values, a large part of which is due to road vehicles.

Raising standards for consumers POSITION PAPER ANEC reply to the European Commission proposals on Omnibus Directive and Regulation Aligning product legislation with the digital age Contact: [name removed] [email removed] [name removed] – [email removed] The European Consumer Voice in Standardisation aisbl ANEC is supported financially by the European Union & EFTA Ref: ANEC-WP1-2025-G-051 02/09/2025 Rue d’Arlon 80 –…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ANEC agrees with the European Commission proposal to amend Regulation (EU) 1025/2012. We agree it is essential that action is taken to enable European standards, and other standardisation deliverables, to reflect only European values and principles in supporting the European public interest.

ANEC submits this feedback in response to the call for evidence on the topic of vehicle data, functions, and resources, published by the European Commission on March 29th. Today’s smart mobility (mobility devices and software) gathers a great amount of user and usage data which is currently limited or even not accessible to third parties, including users.

ANEC recognizes that there is a lot on the positive side regarding this topic (see economic, social and environmental impacts), but we must monitor consumer interest as it is suggested under 'likely impacts on fundamental rights'.

ANEC supports advancing data interoperability requirements to facilitate rail transport for consumers. Interoperability, including cross-border functionality, is necessary for all of Europe and fundamental to the success of future transport systems. Data standards relating to traffic infrastructure and coordination can lay down the baseline for an open, interoperable and integrated service provision.

Having in mind the crucial objectives identified in the Call for Evidence for modernisation of the EU postal regulatory framework, ANEC favours policy Option 2 provided our recommendations above are taken into consideration.

ANEC, the European consumer voice in standardisation, appreciates the opportunity to submit input in support of the draft REACH restriction on CMR 1A/1B substances in childcare products. In contrast to toys, current EU legislation does not adequately protect children from exposure to CMR substances in these products.

ANEC welcomes the opportunity to provide comment on the current Ecodesign and Energy Labelling Regulations for Electronic Displays in order to help improve revised Regulations for this important product group. Our position is summarised in the attached position paper, we invite al relevant stakeholders to read it.

ANEC, the European Consumer Voice in Standardisation, supports the amendment. Although we are still of the opinion that the lower limits for fragrances should have been part of the suggested changes, we endorse the document because of the lower limit of BPA migration as an important amendment to the Directive.