We wish to thank the Commission for producing guidance that includes examples of real-world scenarios. We have chosen to focus our feedback on questions from the Scope section. Due to the value provided by the examples, we do request that additional examples of non-compliant scenarios be included.
BDS
Black Duck Software
Company · United States
2
positions filed
in the 326 files tracked
2
legislative files
of 326 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
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Their record over time
Black Duck Software filed 2 positions between 18 Apr 2025 and 13 Apr 2026, across 2 of the 326 legislative files tracked here, attaching a full position paper 1 time.
2025 · 1 filed2026 · 1 filed
What they argued
From the perspective of a supplier of products with digital elements, one core assumption is that any product with digital elements is brought into scope under Regulation 2024/2847 due to its inclusion in at least one class under Annex III or Annex IV. Where a product with digital elements might require a conformity assessment based on multiple classes, only the first class need apply.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- DIGITALEUROPE · 2 files in common
- ITI - Information Technology Industry Council · 2 files in common
- French Banking Federation · 2 files in common
- SolarPower Europe · 2 files in common
- EUROMOT - The European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers · 2 files in common
Showing 5 of 18.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.