DECO

DECO, as a consumer protection organisation in Portugal, welcomes the European Commission’s intention to adopt a legislative act on the Circular Economy, as part of the Clean Industrial Deal and the Competitiveness Compass.

Filed in Portuguese · English published by the European Commission

PARC-000183-2020 Assunto: Review of the requirements for packaging and other measures to prevent packaging waste Requerente: Comissão Europeia I – GENERALIDADE É com agrado que a DECO analisou esta proposta para revisão da Diretiva 94/62/CE do Parlamento Europeu e do Conselho, de 20 de dezembro de 1994, que visa a prevenção e redução dos resíduos de embalagens.

Filed in Portuguese · English published by the European Commission

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

I. General comments: 1. On a general assessment, it can be said that the proposed Artificial Intelligence (AI) Regulation falls far short of the expectations of consumer protection organisations and also of the Commission’s own objective of making AI in something where citizens feel confident.

Filed in Portuguese · English published by the European Commission

PARC-000237-2020 Assunto: Proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence Requerente: Comissão Europeia - CNECT.A.2 I. Comentários na generalidade: 1.

Filed in Portuguese · English published by the European Commission

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

Green claims are an issue that must be addressed by the UE with priority, many traders are taking advantage of consumers’ growing interest in environmental matters because of the climate crisis and are using green claims to differentiate themselves from their competitors. Many claims are not or cannot be substantiated.

We welcome the European Commission's initiative to extend the scope of the Ecodesign Directive to a wider range of products within the framework of the “European Green Deal”. We appreciate the attention given to the overall life-cycle of the products placed on the EU market, in order to achieve longer product lifetimes, increase circular material use rate, reduce waste and achieve higher recycling rates.

The digital market has become central to the daily lives of European citizens and the current European digital ecosystem is more and more characterized by rapid technological innovation, the proliferation of new digital agents, and the growing integration of AI based tools into business models.

DECO recognises the relevance of the European initiative on climate resilience and risk management. Climate change is no longer an abstract threat; its effects are visible today through phenomena such as heatwaves, prolonged droughts, floods, fires and storms of increasing intensity. These events have direct impacts on the health, safety and quality of life of families, but also relevant economic consequences.

Filed in Portuguese · English published by the European Commission

CONVITE À APRESENTAÇÃO DE CONTRIBUTOS PARA O PLANO DE AÇÃO DA UE PARA A ELETRIFICAÇÃO A DECO entende que os obstáculos à eletrificação estão relacionados com: • falta de literacia energética dos consumidores; • elevado custo de aquisição dos equipamentos; • falta de competitividade económica das soluções elétricas; • falta de apoios/incentivos viáveis direcionados a consumidores vulneráveis • obstáculos/…

Filed in Portuguese · English published by the European Commission

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

PARC-000106-2023 Direito à reparação e durabilidade Rosário Tereso [email removed] 1 Direito à reparação e durabilidade Proposta de Diretiva relativa a regras comuns para a promoção da reparação de bens VOZ DO CONSUMIDOR 2 Voz dos Consumidores Síntese Os consumidores estão cada vez mais preocupados com a ameaça climática e querem fazer parte da solução.

Filed in Portuguese · English published by the European Commission

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

DECO welcome the proposal of a Directive under the Commissions Retail Investment Strategy (RIS). The overall objectives of increasing retail investors protection and access to information and knowledge are shared goals with consumer organisations.

DECO agrees that is urgently necessary to enable consumers to play a more important role in achieving the sustainable consumption. To make a valuable contribution to reaching the 2050 climate goals, we must all shift our consumption by 2030 at the very latest. Sustainable products and services must become the default choice, which is made easy, affordable, and most attractive for consumers.

Following your request about the revision of General Product Safety Directive (2001/95/EC), we have the following comments: • The General Product Safety Directive protects consumers by ensuring that only safe goods are sold on the EU market.

A. Context, Problem definition and Subsidiarity Check: We absolutely agree with the need to adapt the current legal liability regime to the digital age and the circular economy, since artificial intelligence (AI) will certainly contribute decisively in the transition to a circular economy.

Viagens Organizadas Proposta de alteração da Diretiva Rosário Tereso [email removed] Viagens Organizadas Proposta de alteração da Diretiva (UE) 2015/2302 relativa às viagens organizadas e serviços conexos COM/2023/905 final Apreciação na generalidade A Diretiva (UE) 2015/2302 relativa às viagens organizadas e aos serviços de viagem conexos (doravante, Diretiva 2015/2302), propunha-se, atendendo à evolução do…

Filed in Portuguese · English published by the European Commission

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

DECO considers that the current Directive needs to be reviewed in view of addressing several shortcomings, and that the evaluation including a thorough assessment of whether the original objectives of the Directive are still fit for purpose as when the Directive was first proposed is absolutely key and should really be the starting point.

DECO welcome this proposal. General comments: Acknowledging the objective of promotion of a data driven economy, it is important that there is a regulatory framework to establish the rules by which data sharing happens. This is particularly relevant for financial data as it entails sensitive information of natural persons and firms.

DECO, the Portuguese Consumer Protection Association, welcomes the proposal for a Regulation on Instant payments (IPs). To achieve a widespread take up of IPs, especially from consumers, it is crucial to have a regulatory framework making them available, accessible, and secure.

DECO welcomes this proposal reviewing Directive 2008/48/EC on credit agreements for consumers (CCD) to better adapt it to the evolution in the market and tackle arrears. We consider that some provisions will tend to increase the level of consumer protection, reflecting the views expressed by consumer representatives: the extension of the scope to include loans below 200 and up to 100.000 EUR; the introduction of…

DECO welcome this proposal. We consider the PSD2 needs to be profoundly revised especially regarding fraud, liability and redress. General comments: The proposals to address consumer/user confidence by enhancing their protection are very much welcome.

DECO welcomes the European Commission's proposal to ban CMR 1A/1B substances in childcare products. As extensively documented by ECHA, such products represent a substantial and largely unregulated pathway through which children may be exposed to CMR 1A/1B substances.

DECO welcome this proposal. It is essential to have a thorough review of the PSD2. We agree with the conclusion of the impact assessment regarding consumers' at risk of fraud. COMMENTS Scope (Articles 1 and 2 and Recitals 13 and 68) The proposal for a Directive on licensing and supervision of payment institutions is largely based on Title II of PSD2, regarding Payment Service Providers, which only applies to payment…

We consider that although the DMFSD needs significant updates and amendments the Directive is still relevant. Therefore, we would support the view that the COM should consider primarily option 3) Comprehensive revision of the Directive, and as a secondary choice option 2) Repeal of the Directive but moving the still relevant parts, once modernised, under another horizontal legislation.