TÜV-Verband e. V.

The TÜV Association welcomes the European Commissions initiative to establish a Circular Economy Act (CEA) as a key pillar of the Clean Industrial Deal and the Competitiveness Compass. The proposed Act has the potential to significantly accelerate Europes transition toward a resource-efficient, climate-neutral, and competitive circular economy.

The TÜV Association welcomes the European Commission's initiative to accelerate the decarbonisation of energy-intensive industries (EIIs). The transformation towards a sustainable, resilient and climate-neutral industry is pivotal to Europe's future. An effective regulatory framework that creates transparency, investment security and market incentives forms the basis.

The TÜV Association welcomes the European Commission's initiative to revise Regulation (EU) 2017/745 on medical devices (MDR) and Regulation (EU) 2017/746 on in vitro diagnostic medical devices (IVDR). The implementation of both regulations led to a multitude of issues and open questions in the past.

The TÜV Association welcomes the EU Commissions proposal on substantiation and communication of explicit environmental claims (Green Claims Directive) to make environmental claims reliable, comparable, and verifiable across the EU. This will reduce greenwashing, increase consumers trust in green labels and help businesses and investors make more sustainable decisions.

The TÜV Association welcomes the proposal for a Cybersecurity Act 2 that further develops the European cybersecurity framework in response to the evolving threat landscape. The proposal reflects a comprehensive understanding of cybersecurity, notably by including both ICT supply chain security and the cyber posture of entities.

The TÜV Association welcomes the Commissions intention of revising the Cybersecurity Act (CSA). The CSA has been the first horizontal EU cybersecurity legislation by establishing cybersecurity requirements for products, services and processes. While being a relevant pillar still today, the CSA with its European Cybersecurity Certification Framework (ECCF) has unfortunately never reached its full potential.

The TÜV Association welcomes the European Commissions draft Implementing Regulation laying down implementation arrangements for the Digital Product Passport registry under the Ecodesign for Sustainable Products Regulation (ESPR).

The TÜV Association welcomes the opportunity to provide feedback on the ESPR delegated act as regards DPP service providers. Given their crucial role in storing and processing DPP data on behalf of responsible economic operators, robust requirements must be established to ensure a high level of resilience and a level-playing-field for DPP service operators.

We welcome the European Commission's initiative to undertake the Standardisation Regulation (EU) 1025/2012 a revision. European standardisation plays a key role for ensuring safety, quality and competitiveness of the Single Market. In addition, European Single Market legislation provides a central role for European standardisation (harmonised standards) as part of the New Legislative Framework.

TÜV-Verband represents the political and technical interests of the TÜV organizations, which together employ around 30,000 highly qualified professionals in the automotive sector and are active in approximately 70 countries worldwide. As independent, neutral, and sovereignly recognized technical services, the TÜV organizations and their experts have been instrumental in advancing vehicle and road safety since 1910.

The TÜV Association welcomes the initiative of the European Commission to assess and potentially review the Textile Labelling Regulation (EU) 1007/2011. Consumers must have better access to and confidence in all relevant information on textiles, in particular with regard to social and environmental sustainability aspects. Please find our feedback attached.

The TÜV Association and IG-NB welcome the European Commission's efforts to harmonise conformity assessment requirements of Notified Bodies operating under Regulations (EU) 2017/745 (MDR) and (EU) 2017/746 (IVDR). However, these efforts must not result in requirements being imposed on Notified Bodies that cannot be fulfilled or that create more bureaucracy.

The TÜV Association welcomes the evaluation of the Market Surveillance Regulation (EU) 2019/1020 initiated by the European Commission. An effective market surveillance system is central to a functioning EU Single Market and a competitive EU.

The TÜV Association welcomes the European Commission's intention to evaluate the Pressure Equipment Directive 2014/68/EU (PED) and the Simple Pressure Vessels Directive 2014/29/EU (SPVD). The SPVD has not been assessed since 1987, while the PED was last assessed in 2012 and then merely adapted to the new legal framework. Directives 2014/29/EU and 2014/68/EU have proven their worth in practice.

Thank you for the opportunity to comment on the proposed initiative. Please find our detailed feedback in the attached PDF document. In summary, TÜV-Verband welcomes the introduction of harmonised requirements for in-vehicle battery durability under Euro 7. However, we consider transparent and non-discriminatory access to the relevant reference data to be essential.