APPLiA - Home Appliance Europe

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.

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.

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.

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 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.

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 - 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 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 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 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.

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)

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.

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.

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, 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'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, 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'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).