APPLiA

Policy paper 2026-02-20 Bld. Brand Whitlock 114 B-1200 Brussels [email removed] | www.applia-europe.eu APPLiA Home Appliance Europe AISBL Transparency number: 04201463642-88 VAT BE 0460 033 584 APPLiA’s recommendations and amendments proposal for the Digital Omnibus: Data Act and GDPR 1/7 1.

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

Policy paper 3 févr. 2026 Bld. Brand Whitlock 114 B-1200 Brussels [email removed] | www.applia-europe.eu APPLiA Home Appliance Europe AISBL Transparency number: 04201463642-88 VAT BE 0460 033 584 APPLiA’s recommendations and amendments proposal for the AI Omnibus 1/9 AI Omnibus Europe’s home appliance sector is built on decades of trust, following rigorous safety standards.

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

APPLiA represents household appliance industry in Europe. Attached please find out detailed input to the call for evidence "Simplification - digital package and omnibus". We strongly believe that the elements addressed by us should be seriously taken into consideration if the digital omnibus intends to provide a real simplification of the existing rules.

Effective enforcement is essential to ensure that the European Unions upcoming Circular Economy Act remains both achievable and capable of strengthening the competitiveness of European industry. APPLiA, representing the Home Appliance Industry, together with a coalition of other leading industry associations, is calling for concrete action to remove persistent barriers that continue to hinder circularity.

Please find attached the official response from APPLiA (Home Appliance Europe) to the ongoing consultation regarding the Industrial Accelerator Act. While APPLiA acknowledges the IAA as a meaningful step toward strengthening Europe's industrial base, the linked statement further clarifies our position and outlines areas where the current framework is incomplete.

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Renewable Energy Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.

APPLiA represents hosehold appliances manufacturers in Europe. More info about us can be found at www.applia-europe.eu. We would like to respond to the Medical devices and in vitro diagnostics targeted revision of EU rules call for evidence with follwoing comments/questions.

Packaging is necessary to protect home appliances in the factory warehouses and during shipping, ensuring that the product is in good working order when it arrives at consumers homes, and consumer safety is ensured while using the equipment. The EUs proposed Packaging and Packaging Waste Regulation (PPWR) marks a landmark step to combat the over-packaging of products and growing amounts of waste.

APPLiA is supporting the European Commission Delegated Act, amending the Taxonomy disclosures, and the climate and environment, now under scrutiny. It is a step towards more straightforward, clearer and simpler reporting requirements.

Bld. Brand Whitlock 114 / B-1200 Brussels T: [phone removed] Candice Richaud [email removed] Feedback to the Commission proposal to recast the EPBD As the Commission presented its proposal to recast the Energy Performance of Buildings Directive, APPLiA, representing home appliance manufacturers in Europe would like to share its first impressions on the proposed text and look forward to the next legislative steps.

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

APPLiA would like to use the opportunity given in this consultation and comment on two important elements of the draft AI Regulation: 1. Article 6 - Classification rules for high-risk AI systems - Only products which basic safety features are secured ONLY by the AI system should be considered high-risk in this classification. If basic safety functions required by e.g.

First of all, APPLiA would like to point out that the concept of Artificial Intelligence is still not well defined and as such we oppose regulating it, as there may be completely different understandings of AI by various actors on the market. A similar situation applies regarding the lack of definition of “high” / ”low” risk.

Feedback on the Green Claims Directive Proposal Home Appliance manufacturers have been responding for many years to the environmental challenges and their responsibility towards society to produce sustainable products. It is paramount for home appliance manufacturers that consumer trust in our products is maintained.

APPLiA Home Appliance Europe represents the home appliance industry in Europe. Home Appliance manufacturers offer better lifestyles to Europeans, investing over EUR 1.4 billion in R&D and creating nearly 1 million jobs in Europe. The growth of our industry is directly linked to our freedom to innovate for our consumers.

APPLiA is a Brussels-based trade association representing home appliance manufacturers in Europe. Our membership includes 24 Direct Members who are leading global companies in the sector, and 26 National Associations across Europe. The sector is an economic powerhouse, with an annual turnover of EUR 67 billion, over EUR 1.4 billion invested in R&D activities and nearly 1 million people involved.

APPLiA - Home Appliance Europe - welcomes the opportunity to comment on the EU Commission’s Sustainable Products Initiative. We support the work towards a more coherent EU policy framework for a circular economy, while preserving the single market, competition and innovation.

Bld. Brand Whitlock 114 / B-1200 Brussels T: [phone removed] [name removed] [email removed] The CBAM proposal risks negative environmental impacts and it is unfair to European manufacturing A negative environmental impact, as a result of ETS and CBAM proposals APPLiA represents the Home Appliance industry in Europe and, as a leader in sustainability, fully supports the EU’s 2050 decarbonisation target.

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

In rolling out the EU climate strategy, the European Union will have the challenge of designing policy that will reduce CO2 emissions and encourage greener industry in Europe,while avoiding making European industry less competitive both in the internal market and on the world market. In avoiding carbon leakage, the EU must also avoid the “leakage” of the strength of European industry.

The attached paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the “Fit for 55” Energy Efficiency Directive proposal. It provides a first set of remarks on the provisions of the legal text under consultation. APPLiA is also proposing amendments and/or comments to specific articles of the Commission.

The paper attached is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on two of the Fit for 55 package proposals: The review of the Emission Trading Scheme and the Social Climate Fund.

APPLiA Response to Have Your Say - Open Ended Question APPLiA supports the Commission's simplification agenda and believes that aligning definitions, streamlining reporting mechanisms, and avoiding overlapping legislation will significantly reduce unnecessary administrative burdens and improve compliance across the EU.

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

The CBAM transitional phase will end on 31 December 2025. From that point onwards, the definitive regime will come into force, gradually phasing out free ETS allowances and introducing the obligation to purchase CBAM certificates for goods listed in Annex I.

APPLiA Home Appliance Europe, the industry association representing the home appliance manufacturing sector in Europe, welcomes the opportunity to provide feedback on the European Commission's Call for Evidence for the upcoming Biotech Act II.

This paper is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on the Fit for 55 package proposals. It provides an analysis and the first set of remarks on the provisions of the many legal texts under consultation. In some instances, APPLiA is proposing amendments and/or comments to specific articles/provisions of the Commission.

a. Demand response One important area that the revision should take into consideration is how demand response instruments could contribute to reducing emissions of net greenhouse gases. Demand response solutions would be able to reduce the pressure on the network by better managing peak demands. To cope with temporary high energy requests, energy suppliers often make use of coal or fossil fuels.

Feedback to Call for Evidence on Digital Fairness Act 1/3 Feedback to Call for Evidence on the Digital Fairness Act APPLiA’s response to the Digital Fairness Act consultation focuses on the issue of enforcement on online marketplaces. 1. Main messages ➢ Major gaps remain in enforcing compliance on online marketplaces for non-compliant products and negatively affecting consumer safety and the level playing field.

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

APPLiA, representing EU manufacturers of home-appliances, including large domestic appliances, small domestic appliances and heating, ventilation, and air conditioning (HVAC) equipment, would like to provide the European Commission with the views of the sector and further recommendations regarding its Inception Impact Assessment (IIA) document Ref. Ares (2020)7731375 as published on the 18th December 2020.

APPLiA members highly appreciate the publication of the updated guidance, the Frequently Asked Questions and the draft Delegated Regulation that amends Annex I of the Regulation (EU) 2023/1115. Altogether, these documents provide a very much needed clarity for companies to understand which products fall within or outside the scope of the Regulation.

APPLiA, the European association representing home appliances manufacturers, welcomes this proposal for a Regulation on batteries for a more coherent battery legislative framework while preserving the single market competition and innovation. Please find attached the industry's reaction with complementary comments.

Bld. Brand Whitlock 114 / B-1200 Brussels T: [phone removed] Naomi Marc [email removed] Feedback Inception Impact Assessment – ‘Modernising the EU’s batteries legislation’ APPLiA Home Appliance Europe supports the European Commission’s work to examine options and actions for a more coherent battery legislative framework in view of the revision of the Battery Directive 2006/66/EC, amended by 2013/56/EU, while…

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

APPLiA - Home Appliance Europe, the industry association representing home appliance manufacturers in Europe, supports the European Commissions objective to simplify administrative burdens within environmental legislation with the Environmental Omnibus. Today, many manufacturers face overlapping obligations and administrative overload.

APPLiA, the EU trade Association representing manufacturers of home appliances, including, ventilating and air conditioning and heat pump equipment, would like to share with the European policy-makers its stance and views on the new proposal for a Regulation on F-Gases revising (EU) No 517/2014 published on 5 April 2022. Please find our position paper attached.

Bld. Brand Whitlock 114 / B-1200 Brussels T: [phone removed] Naomi Marc [email removed] Inception Impact Assessment – ‘Review of EU rules on fluorinated greenhouse gases’ APPLiA Home Appliance Europe welcomes the European Commission’s activities to examine the F-Gas Regulation in view of its evaluation and revision, while preserving the single market, competition and innovation.

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

APPLiA welcomes the opportunity to provide feedback on the methodology for the definitive period of the CBAM, starting 1 January 2026. While the methodology for products currently in scope is the primary focus of this consultation, it is equally important to prepare the framework for the future extension to downstream goods.

APPLiA, representing EU manufacturers of home-appliances, including large domestic appliances, small domestic appliances and heating, ventilation, and air conditioning (HVAC) equipment, would like to provide the European Commission with the views of the sector and further recommendations regarding the objectives and policy options as proposed in the IIA called “Revision of EU legislation on registration, evaluation…

APPLiA representing household appliance industry in Europe - acknowledges the draft proposal for the Cyber Resilience Act. It is based on the New Legislative Framework Principles and as such should serve as one stop shop, central reference point for all cybersecurity requirements. Some detailed comments and recommendations from household appliance industry can be found in the attached file.

APPLiA represents Home Appliance Industry in Europe. We provide more details in the attached file. The brief summary can be outlined here: Whilst the NIS and NIS2 Directives properly address organisations with a set of consistent requirements, there is a risk that our products are regulated by different, disconnected pieces of legislation.

APPLiA, the European association representing the home appliance industry, submits this response to highlight the substantial risks posed by the Commissions proposed steel safeguards to downstream manufacturing.

APPLiA represents household appliance industry in Europe. We would like to give our feedback to the Call for Evidence of the Standardisation Regulation Revision. See the details in the attached file. We remain available for further consultations in the future regarding this topic.

APPLiA welcomes the European initiative on microplastics pollution as this global issue shall be discussed at the European level with a holistic approach. This paper reflects the Home Appliance contribution to the Call for evidence for an impact assessment on the microplastics pollution initiative, launched by the European Commission on November 30th, 2021.

There is an oversight within the proposal for transitional arrangements in respect of Annex XVI products that have now been brought within scope of the Medical Regulation. Whilst new Common Specifications have recently been established for such products, they do not benefit from existing conformity certificates under the former Medical Devices Directive.

APPLiA members fully support the transition to a circular economy, the proposed framework for mandating minimum recycled content faces severe structural, technical, and regulatory barriers. Setting rigid, legally binding recycled-content thresholds in the absence of analytical verification methods will impose heavy administrative and financial burdens on compliant EU operators.

APPLiA represents household appliance industry in Europe. We found the CRA Guidelines already quite good. However, we would like to use this opportunity to share some comments collected from members aiming at some improvements and clarifications to be further provided in these useful guidelines. We are opened for further discussions or exchange on those elements to finalise the CRA Guidelines soon.

APPLiA welcomes the publication of both Commission initiatives to promote repair and to substantiate green claims. The two texts bring stakeholders the complete picture of proposed requirements in the area of environmental and consumer protection together with the initiatives on ESPR and empowering consumers.

APPLiA welcomes the Commission’s initiative on sustainable consumption of goods – promoting repair and reuse. It fits with the circular culture our industry is promoting and allows considering together aspects such as consumer rights, consumer and product safety, waste, sustainable behaviours and the creation of skilled jobs.

APPLiA appreciates the opportunity to provide this feedback. While a condensed version of our comments is below, please see the attached document for our full comments. APPLiA understands the need for comprehensive rules for a high level of cybersecurity within the European Union. APPLiA’s first concern lies in the fact that NIS2 is a Directive rather than a regulation.

APPLiA would like to use the opportunity given and comment in couple of points on the key elements in the draft Machinery Regulation. This set of comments does not exclude the possibility to deliver additional input in the future as well as improving/modifying certain statements provided here. APPLiA is available for further, especially verbal and bilateral explanation of its comments in more details.

Pre-contractual information is key to ensure consumers make informed purchasing decisions. The Commission proposal on empowering consumers in the green transition aims to provide those consumers with an additional set of information and protect them from “greenwashing”.

In order for the green transition to fully take place, consumers will have to play a much larger role in shifting to more sustainable consumption patterns, such as opting for repair over product replacement. With reference to the 2019 Sale of Goods Directive, APPLiA has long been a supporter of repair being first in the hierarchy of remedies to which consumers are entitled.

Policy paper on Omnibus IV (Paper vs. Digital documentation & Common Specifications) 1/10 Paper vs. Digital documentation We acknowledge the Commission’s intention to promote digital user manuals as a means to reduce paper consumption, lower costs, and minimise CO₂ emissions.

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

This document is focusing only on key aspects. APPLiA is happy to contribute to the legislative process with further details at a later stage. 1 - Improved coherence with New Legislative Framework The GPSR is thought as a “safety net” to Union harmonised legislation, therefore coherence with the New Legislative Framework (NLF) is of utmost importance.

APPLiA (Home Appliance Europe) believes that GPSD has been working reasonably well over those almost 20 years and does not require major revision. However, considering time and efforts already invested in possible review, Option 0 ’Status quo’ is probably not realistic anymore.

Policy paper on Omnibus IV (Paper vs. Digital documentation & Common Specifications) 1/10 Paper vs. Digital documentation We acknowledge the Commission’s intention to promote digital user manuals as a means to reduce paper consumption, lower costs, and minimise CO₂ emissions.

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

APPLiA is thankful for the opportunity to comment on the draft Implementing Regulation detailing companies disclosure obligations under ESPR. APPLiA has identified several areas requiring clarification and adjustment within the current draft. This paper outlines our recommendations to address these concerns.

APPLiA Home Appliance Europe welcomes the opportunity to provide feedback on the Draft Implementing Regulation regarding the labelling of batteries. Our members are fully committed to the successful implementation of the Batteries Regulation, supporting a digital-first approach that reduces waste and provides consumers with accurate, dynamic information.

We would like thank the Commission for sharing the call for evidence on airco, comfort fans and local heaters and for providing us with the opportunity to comment on it. While we support the Commission’s intention to update the labels, some of the energy efficiency calculations and the option of removing the least efficient products from the market, we would like to see it done without harming manufacturers…

APPLiA's comments on the draft Ecodesign and Labelling regulations for water heaters propose several critical modifications to ensure a fair level-playing field and prevent the unjustified market exclusion of certain efficient technologies, particularly Electric Storage Water Heaters (ESWH) and Electric Instantaneous Water Heaters (EIWH).

APPLiA's comments on the draft Ecodesign and Labelling regulations for water heaters propose several critical modifications to ensure a fair level-playing field and prevent the unjustified market exclusion of certain efficient technologies, particularly Electric Storage Water Heaters (ESWH) and Electric Instantaneous Water Heaters (EIWH).

APPLiA supports the decarbonisation objectives of the Green Deal and therefore appreciates the need for an ambitious package of policy measures. Nevertheless, the proposals presented so far by the Commission will not solve the issues with the existing framework and hamper the deployment and installation of more efficient technologies.

APPLiA - Home Appliance Europe supports the Commission's ambition to improve circularity and transparency in the iron and steel value chain. Delivering on this objective well depends on obligations being assigned appropriately across the value chain to the actors best placed to provide or verify the data.

We appreciate the efforts of the Commission to simplify the ecodesign and energy label framework. We trust that the energy product omnibus legislation will make it easier to market energy efficient appliances and reduce any red tape creating unnecessary burdens.

Article 26 of the Critical Raw Materials Act - Regulation (EU) 2024/1252 - empowers the Commission to specify in a list such items with a high potential for critical raw material recovery. This aims to help Member States create national circularity programmes containing measures to address various circularity dimensions, e.g. reuse, recycling and waste prevention & collection.

APPLiA represents household appliance industry in Europe. We appreciate that Commission regards standardisation as crucial for Europe. We appreciate that Commission proposes an amendment to Regulation 1025/2012 as we believe that this Regulation has the potential to improve the governance of effective standardisation in Europe.

APPLiA, the European Trade Association representing manufacturers of home appliances, including ventilation, air conditioning and heat pump equipment, would like to share the following comments as a response to the consultation on the draft implementing regulation laying down rules for the application of Regulation (EU) 2024/573 of the European Parliament and of the Council establishing minimum requirements for the…

APPLiA - Home Appliance Europe would like to provide its view on the energy labelling revision for local space eaters. In this paper, we would like to provide a simple and clear explanation of why electric local space heaters (ELSH) should not be compared to other products in one single labelling scheme.

Full details in the attached paper: • RRS are a specific class of equipment based on SDR (Software Defined Radio) and CR (Cognitive Radio) technologies that are able to change the radio parameters of a device via firmware/software update.

APPLiA (Home Appliance Europe) acknowledges the European Commissions proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on adapting non-contractual civil liability rules to artificial intelligence (AI Liability Directive).

APPLiA, representing the home appliance industry, takes this opportunity to give some initial comments from the perspective of our sector in relation to the EU product policy framework contributing to a circular economy. Please find this attached. Thank you.

The paper attached is APPLiA’s proposed contribution to the feedback mechanism launched by the European Commission on two of the Fit for 55 package proposals: The review of the Emission Trading Scheme and the Social Climate Fund.

APPLiA, the Association representing the home appliance in Europe, would like to welcome the Commission proposal for the review of the ecodesign and energy labelling requirements for Washing Machines and Washer-Dryers, and would like to thank the Commission for the possibility to provide comments through this platform.

APPLiA welcomes the initiative launched by the European Commission to amend legislation in the Ecodesign and Energy Labelling field to correct some technical issues. However, there are several important uncertainties and mistakes remaining that need to be resolved. The enclosed position paper provides the necessary recommendation to improve the legal text and ensure consistency among the ecodesign regulations.

Please find attached APPLiA's input on the call for evidence related to the revision of the ecodesign and labelling of cooking appliances. A number of comments stam from the ones sent to the Commission on the preparatory ecodesign study that DG ENER presented during the Consultation Forum meeting on the 29th of November 2022. They can be found in the Annex.

APPLiA, representing the home appliance industry in Europe, welcomes the revision of the ecodesign and the possibility to provide feedback on the establishment of a new energy label for vacuum cleaners. The Association would like to provide feedback to consider in the impact assessment. Please see attached our Position Paper.