Industrieverband Schneid- und Haushaltwaren e.V. - IVSH

IVSH welcomes the opportunity to contribute to this consultation. While harmonised registration formats are a positive step, companies continue to face significant administrative burdens arising from fragmented national registration and reporting systems. Our submission therefore focuses on the need for a more integrated, proportionate and SME-friendly approach to PPWR compliance across the Single Market.

Insights and feedback from our members and companies show that especially SME and mid-caps from the EU still face considerable hurdles and obstacles (due to the overall complexity of the process) when participating public procurement imitatives. Overall, the process of participation of SME & mid-caps should be analyzed and simplified.

We welcome the introduction of the value chain cap as an important and necessary step to limit disproportionate sustainability data requests within value chains and to reduce administrative burden on smaller companies. As already highlighted in our feedback to the "Value Cap" consultation, practical feasibility and proportionalityparticularly for SMEsare essential for successful implementation.

FEC and IVSH generally support the EUs CBAM mechanism but warn that the current CBAM design creates major competitive distortions. Excluding downstream products in our sector (e.g., cookware, cutlery, household goods with >70% metal content) risks carbon leakage, production shifts, and job losses.

The Industry Association of Schneid- und Hauswaren (IVSH) welcomes the consultation on the Digital Fairness Act (DFA). The Association stresses the need to better address the role and failures of large online platforms in the movement of goods and consumer products. The DFA should focus on the enforcement of consumer protection and rights while ensuring proportionate requirements for European SMEs.

Filed in German · English published by the European Commission

As IVSH we welcome the Commissions initiative to set rules for converting third-country carbon prices into CBAM certificates. However, we would like to emphasize once again a key point from our previous input on the downstream extension: For CBAM to achieve its climate and competitiveness objectives, it is essential to fully include downstream goods such as cookware, cutlery, and other metal-intensive household…

We appreciate the opportunity to provide feedback on the proposed revision of Annex I of Regulation (EU) 2023/1115, the EU Deforestation Regulation (EUDR). We would like to highlight a contradiction in the formulations regarding rattan, bamboo, etc., between the two documents published in the consultation.

We welcome the Environmental Omnibus Package as an important step toward reducing unnecessary administrative burden, strengthening the Single Market and restoring proportionality across EU environmental and product legislation. Please refer to our attached position paper for an in-depth assessment.

IVSH, representing the German speaking cutlery and household goods industry, welcomes the opportunity to provide feedback on the draft implementing regulation for the DPP registry. We support the overarching objectives of the Digital Product Passport. However: the DPP must clearly deliver added value in practice, unlock efficiencies and be SME friendly by design.

The Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) in general welcomes the Commission's initiative to implement the Digital Product Passport (DPP) as part of the new EcoDesign Regulation - if designed and executed well.

As IVSH we welcome the Commissions initiative regarding CBAM certificates and adjustements. However, we would like to emphasize once again a key point from our previous input on the downstream extension: For CBAM to achieve its climate and competitiveness objectives, it is essential to fully include downstream goods such as cookware, cutlery, and other metal-intensive household products.

On behalf of the Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) and in cooperation wit the Federation of the European Cookware and Cutlery Industries (FEC), we are pleased to submit our joint position paper on the Digital Product Passport (DPP) / digital product information in the context of the ongoing consultation on the Omnibus Regulation initiatives. Please find our position paper attached.

On behalf of the Industrieverband Schneid- und Haushaltwaren e.V. (IVSH) and in cooperation with the Federation of the European Cookware and Cutlery Industries (FEC), we are pleased to submit our joint position paper on the Digital Product Passport (DPP) / digital product information in the context of the ongoing consultation on the Omnibus Regulation initiatives. Please find our position paper attached.

IVSH (Industrieverband Schneid- und Haushaltwaren e.V.) welcomes the opportunity to contribute to this Call for Evidence. While the finished consumer products represented by IVSH are currently not within the scope of the proposed Delegated Act, our member companies are significant downstream users of iron and steel products and will be affected by sustainability information, Product Carbon Footprint and Digital…

The IVSH represents the interests of manufacturers of cutlery, household, kitchenware and bodycare products in Germany and the Austria and Switzerland, with a strong focus on consumer safety, regulatory compliance, and innovation.

IVSH (Industrieverband Schneid- und Haushaltwaren e.V.) welcomes the opportunity to contribute to the European Commissions evaluation of Regulation (EU) No 608/2013 on customs enforcement of intellectual property rights.