TÜV-Verband e. V.

The TÜV Association welcomes the European Commissions efforts to streamline and simplify the EUs digital regulatory framework. Clear, coherent, and predictable rules are crucial for strengthening the competitiveness of the European digital economy and ensuring the effective functioning of the Single Market.

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.

With the EU Critical Raw Materials Act, the European Commission aims to strengthen European sovereignty in the raw materials value chain. The TÜV Association welcomes this objective and considers the proposed policy measures suitable to achieve this goal, in particular the aim to improve the sustainability and circularity of critical raw materials.

TÜV welcomes the European Commission’s initiative to create a binding framework for regulating systems based on the use of artificial intelligence. A robust regulatory framework is essential to ensure people’s trust in AI-based products and systems and thus the acceptance of this new digital technology.

Filed in German · English published by the European Commission

The Association of German Technical Inspection Agencies welcomes the Commissions Inception Impact Assessment and would like to provide feedback on the core issues raised. Artificial Intelligence (AI) is a fast evolving technology that can create significant economic and social benefits, but equally entails significant risks to the safety, health and privacy of users.

Filed in German · English published by the European Commission

The TÜV Association welcomes the EU Commission's plans to establish binding requirements by considering the entire supply chain. Welcomed is also that the proposal includes comprehensive social and human rights, as well as environmental and climate-related due diligence obligations.

The Association of German Technical Inspection Agencies (Verband der TÜV e.V.) welcomes the Commissions initiative to promote a sustainable corporate governance framework at EU level and would like to provide feedback on some core issues.

The TÜV Association welcomes the EU Commissions proposal for a Regulation establishing a Union certification framework for carbon removals. Carbon removal is crucial for achieving the EUs climate targets. Both carbon removal options, nature-based (NBS) and technology-based solutions (TBS), need to be massively scaled up.

We strongly welcome the EU Commission's initiative to develop a legal framework for the certification of carbon removals. The instrument of certification is crucial to ensure that carbon removal activities are real, permanent, additional, and do not cause negative side effects. A clear distinction must be made between nature-based and technology-based solutions.

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 EU Commission’s proposal for a new Ecodesign Regulation within the framework of the Sustainable Product Initiative (SPI) in order to increase the environmental sustainability of products over their entire life cycle. Apart from setting out ambitious requirements, it is crucial to ensure their consistent and effective compliance.

The TÜV-Association welcomes the Commissions initiative to develop an initiative for more sustainable products and would like to provide feedback on the following issues. Establishing and enforcing EU’s sustainability rules Currently, there is no comprehensive set of requirements for a more sustainable product policy within the EU. Existing instruments are either limited to certain resources (e.g.

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 Commission’s initiative to consider a revision of the IED. While the use of Best Available Techniques (BAT) has proven successful in defining binding emissions values within the EU, it is equally important to ensure its effective implementation within the member states.

The TÜV-Association welcomes the EU Commissions initiative to modernise EU legislation on batteries. Batteries are becoming more and more essential for key sectors of our economy and society such as mobility, energy and communications. In order to fully tap the potential of batteries for environmental and climate protection, their own ecological and social footprint must be as low as possible.

VdTÜV: Comments on the Common European Mobility Data Space of the EU Data Strategy, July 2020 Future legislation in the context of a European mobility data space needs to take greater account of elements of data management, including ethical considerations related to the use of personal data.

Filed in German · English published by the European Commission

The TÜV Association welcomes the European Commissions Roadmap towards Nature Credits and supports its objective to establish high-integrity, transparent, and science-based instruments for financing biodiversity and ecosystem services.

The TÜV Association welcomes the European Commissions intention of establishing binding cybersecurity requirements for a broad range of connected products with digital elements. Given the ever-increasing number of cybersecurity incidents across the Union, it is of paramount importance to provide consumers and businesses with secure products both at the time of purchase and over their entire lifecycle.

The TÜV Association welcomes the Commission’s intention of establishing binding cybersecurity requirements for a broad range of products and services. To date, the EU is lacking an all-encompassing approach to cybersecurity. Cybersecurity provisions in current legislation are either limited to specific product groups or are only applicable on a voluntary basis.

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.

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).

In order to ensure a level playing field between economic operators and as a confidence-building measure, we support the mandatory involvement of independent conformity assessment bodies. This should be maintained. With regard to conformity assessment procedures, Decision 768/2008 should be used to the extent appropriate for the sector. We see the need to clarify and clarify the definition of plastic pellet.

Filed in German · English published by the European Commission

12 September 2022 Feedback to the EU Commission’s call for evidence Reform of the Union customs legislation In the light of globalization and growing pressure on supply chains, customs authorities are facing particular challenges in the course of their tasks. Not only does the number of traded goods continuously increase, but equally does the number of non-compliant and unsafe goods placed on the EU Single Market.

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

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.

The TÜV Association welcomes the EU Commissions proposal on common rules promoting the repair of goods. The Right to Repair will make it easier and more cost-effective for consumers to repair goods rather than have them replaced. In addition, increased demand will boost the repair sector while creating incentives for manufacturers and sellers to develop more sustainable business models.

As a TÜV association, we welcome a product policy that ambitiously promotes the transition from a linear economy to a circular economy. This includes the issue of the repair (ability) of products with the aim of significantly prolonging their useful life. The Sustainable Products (SPI) initiative should establish a right to reparability. The TÜV Association supports Option 3 taking into account all sub-options.

Filed in German · English published by the European Commission

The TÜV-Association welcomes the proposal for a new Machinery Regulation by the European Commission. Such an update of legislation comes at the right time in order to adapt to technical progress with regard to the connectivity of machines, cybersecurity, artificial intelligence, as well as robotics.

VdTÜV and its members welcome and support the EU Commission’s initiative to revise the Machinery Directive 2006/42/EC. Since the Machinery Directive is applied to a large number of consumer and industrial products, it is of the utmost importance that the revision will bring the requirements into line with the New Legislative Framework (NLF), clear up any ambiguities and take adequate account of technical progress in…

VdTÜV and its members welcome and support the EU Commission’s initiative to revise the Machinery Directive 2006/42/EC. Since the Machinery Directive is applied to a large number of consumer and industrial products, it is of the utmost importance that the revision will bring the requirements into line with the New Legislative Framework (NLF), clear up any ambiguities and take adequate account of technical progress in…

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 Commission’s intention to undertake the existing General Product Safety Directive (2001/95/EC) a substantial revision. Products must be safe and consumers have to rely on their safety. The Commission proposal is clearly a step in the right direction. However, further improvements are needed. Please find our feedback attached.

Unfortunately, the initial revision with commission proposal of 2013 was not successful and a missed opportunity. The GPSD needs now even more a fundamental revision to align its provisions with the goods package from 2008 and to update its safety requirements to new developments in markets, distribution channels and technology (security and privacy aspects). We therefore recommend Option 3.

Measuring greenhouse gas emissions is a key tool to drive sustainability, innovation and behavioural change and is already being used in various sectors of the economy. In the transport sector, there is not yet a generally accepted framework for measuring greenhouse gas emissions from different transport services.

Filed in German · English published by the European Commission

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.

VdTÜV (Association of Technical Inspection Agencies) advocates technical safety and trust in products, plants and services by independent testing in the European Union. Its international members are the TÜV organizations as well as industrial companies which are affiliated with the objectives and tasks of the association.

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.

TÜV Verband e.V. in line with CITA aisbl welcomes the initiative of the European Commission to tackle the issues of accessing vehicle data, functions and resources. Due to significant impacts of the Data Act on the mobility ecosystem, we support the intention of the EU Commission, in line with recital 3 of the Data Act, to adopt specific provisions within the EU type-approval regulations for the automotive sector.

Article 5 (12) Instructions for use should not in principle be changed after the conformity assessment procedure has been completed or only as a result of corrective actions. Therefore, “or” should be replaced by “caused by”.

Filed in German · English published by the European Commission

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.

The TÜV Association welcomes the opportunity to provide feedback on the proposed postponement of battery due diligence obligations for economic operators. While we share the Commission's view that a timely application of the due diligence obligations is not realistic under the current framework conditions, we would like to stress that the designation of notifying authorities by EU Member States is a structural…

The economic system and its environment are changing continuously. Against this background, the regulatory framework for the European Single Market – a key factor for European integration, must regularly be put to the test. In this sense the Federation of TÜV (VdTÜV) welcomes the European Commission's plan for an initiative „Towards an EU Product Policy Framework contributing to the Circular Economy“.

The TÜV Association would like to provide the following feedback to the planned Single Market Emergency Instrument: The well-established European quality infrastructure that has been built up over decades, consisting of legislation, standardization, accreditation and conformity assessment, reliably ensures the conformity of products and services.

Dear Madam, dear Sir, Please below some feedback from TÜV Verband and other Technical Services. The proposed EU-Commission's Regulation to streamline the use of non-road mobile machinery on public roads is welcomed by TÜV Verband, DEKRA, SGS and GTÜ.

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.