ZVEI e.V.

ZVEI supports the European Commission's objective of establishing harmonised and interoperable producer registration and reporting systems under Article 44 PPWR (EU Regulation 2025/40). To achieve this objective without creating new administrative burdens, the implementing act should follow three principles: reporting requirements must be limited to data that producers can reasonably obtain; information already…

The AI Act hinders the innovation and competitiveness of European industry in key areas. There is an urgent need for reform in three areas in particular in order to reduce double regulation and burdens on industry. Our key demands are: 1. The industrial use of AI is already covered by sectoral regulation.

ZVEI recommendations on the „EU Digital Omnibus on Data, Privacy and Cybersecurity“ Summary ZVEI welcomes the European Commission’s initiative to streamline and adjust the EU’s data, cyber security and data protection framework through the Omnibus VII. The Commission’s recognition of the need to enhance Europe’s competitiveness and to strengthen the conditions for data-driven innovation is both timely and necessary.

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

ZVEI welcomes this consultation and fully supports the European Commissions efforts to simplify and streamline EU digital regulation. The goal of a 25% reduction of administrative costs for all businesses and 35% for SMEs by 2030 is ambitious and necessary.

www.pwc.de Ref. Ares(2021)661871 - 27/01/2021 Opportunities and risks for Germany’s heating industry in a competitive global environment Efficiency and renewable energy for the heating transition Opportunities and risks for Germany’s heating industry in a competitive global environment Published by PricewaterhouseCoopers GmbH Wirtschaftsprüfungsgesellschaft By Dr.

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

ZVEI as the German Electro and Digital Industry Association welcomes the opportunity to contribute to the Commission´s proposal for a Digital Networks Act (DNA). We represent, among others, the manufacturers of gigabit network components such as fiber optic and coaxial amplifiers, filters, distributors and taps, fiber optic, coaxial and data cables.

Position regarding Digital Networks Act (DNA): Consultation We are pleased to comment on the recently published consultation of the EU Commission on the planned Digital Networks Act (DNA). We very much welcome the fact that the Commission´s 2024 white paper “How to master Europe's digital infrastructure needs” has already drawn attention to the expansion of digital infrastructures, as these are essential for almost…

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

ZVEI welcomes the European Commissions efforts to simplify the EU Taxonomy framework and improve its usability. While the overarching objective of fostering sustainable investment is fully supported, the current proposalsparticularly regarding Appendix C and the Technical Screening Criteria (TSC)remain overly complex, legally unclear, and insufficiently aligned with existing EU legislation.

The German electrical and digital industry association (ZVEI) welcomes the recast of the Energy Performance of Buildings Directive (EPBD). It presents a crucial opportunity to create a futureproof framework in all member states for new buildings and the renovation of the building stock. A climate neutral building sector is only feasible through a significant increase of the renovation rate and depth.

With its large portfolio of industries, the ZVEI hosts many technologies that contribute to making our buildings smarter, safer, increasingly energy efficient and more pleasant for their occupants. Thus, to bundle knowledge and competence we have created the ZVEI-Platform for buildings. The commissions aim to boost building renovation is a policy that the ZVEI and its platform for buildings support.

Position on Draft Simplified European Sustainability Reporting Standards (ESRS) Simplify reporting standards and reduce the administrative burden on businesses ZVEI welcomes the European Commission’s initiative to simplify the European Sustainability Reporting Standards (ESRS) under the Corporate Sustainability Reporting Directive (CSRD).

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

ZVEI welcomes the ambitious goal of the EU-Commission to promote and facilitate the uptake of Trustworthy AI in Europe. The EU-Commission puts forward a proposal for a harmonised European approach addressing potential risks and uses of AI applications. We plead to also focus on the immense opportunities related to the uptake of AI.

The Zentralverband Elektrotechnik- und Elektronikindustrie e.V. (ZVEI) welcomes the opportunity to provide feedback to the Inception Impact Assessment of the European Commission for a proposal for a legal act of the European Parliament and the Council laying down requirements to stimulate the development and uptake of Artificial Intelligence (AI) and new technologies.

We welcome the European Commission's objective of promoting the decarbonization of the transport sector by increasing the share of zero-emission vehicles through the planned initiative. The ZVEI supports the Commission's assumption that increased electrification of company fleets will give a positive boost to the used vehicle market and can make a significant contribution to promoting the market penetration of…

With the attached paper we take the opportunity to comment on the draft Ecodesign Regulation (COM(2022) 142 final) published by the European Commission on 30 March 2022 as part of its Sustainable Product Initiative (SPI). We welcome that the EU Commission continues to pursue the ecodesign approach.

The German Electrical and Electronic Manufacturers' Association (ZVEI) supports key aspects of the EU Commission's Sustainable products initiative. Striving for sustainable products is rightly at the top of the political agenda. Please find our detailed comment in the attached file.

21. September 2020 Bereich Energie Beitrag des ZVEI zur Konsultation der EU-Kommission zur Überarbeitung der EU-Energieeffizienz-Richtlinie 2012/27/EU Energieeffizienz als Kernanliegen der Elektroindustrie Die Energieeffizienz-Richtline (EED 2012/27/EU) ist im Dezember 2012 in Kraft getreten. Sie wird u.a.

Filed in German · English published by the European Commission

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

ZVEI welcomes the objective of the proposed Cybersecurity Act 2 to reduce regulatory complexity and strengthen Europes cybersecurity framework. At the same time, the proposal should better reflect industrial realities and avoid creating additional burdens for companies.

With the attached position paper, the ZVEI - Electro and Digital Industry Association wants to make a contribution to the consultation procedure for the proposal for a Regulation of the European parliament and of the council laying down harmonised conditions for the marketing of construction products, amending Regulation (EU) 2019/1020 and repealing Regulation (EU) 305/2011.

Safety & Security Division 17 August 2020 KRA ZVEI Safety & Security Division – Who we are The ZVEI represents the common interests of the electrical industry in Germany. It has over 1,600 member companies, together accounting for around 90% of all employees in the German electrical industry.

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

As manufacturers of construction products, the cable industry is severely affected by the CPR and any change of the legal framework. Summary of the positions - No legislative change, but improving implementation. - In the field of cables, the performances which have an impact on the basic requirements of construction works are sufficiently harmonized.

ZVEI welcomes the European Commissions efforts to simplify the EU Taxonomy framework and improve its usability. While the overarching objective of fostering sustainable investment is fully supported, the current proposalsparticularly regarding Appendix C and the Technical Screening Criteria (TSC)remain overly complex, legally unclear, and insufficiently aligned with existing EU legislation.

In principle, ZVEI supports the goals of improved data allocation and the integration of data producers into the data economy as described in the Data Act proposal. In order to fully leverage the value creation potential of industrial and machine data, it must be possible for data to flow to the actors in the value chain which generates the greatest added value from the data.

Filed in German · English published by the European Commission

ZVEI feedback to the consultation on the Data Act Roadmap The EU-Commission addresses a variety of aspects of data economy potentially affecting a multitude of legal questions in competition, contract, intellectual property and data protection law.

We, the Association of Electrical and Digital Industries, welcome the opportunity to comment on the European Commission’s White Paper How to master Europe’s Infrastructure Needs, published on 21 February 2024, which sets out the agenda for legislative reforms in the telecommunications sector.

Filed in German · English published by the European Commission

The German electrical and electronic industry organized in the association ZVEI believes that the proposed regulation for the battery sector published by the EU Commission on December 10, 2020 is a good approach to strengthen the European battery industry, to harmonize national regulations, and to take into account the increased sustainability requirements.

The ZVEI - German Electrical and Electronic Manufacturers´ Association appreciates the opportunity to comment on the European Commission’s inception impact assessment on modernizing the EU’s batteries legislation. We see this assessment as a further step on the way to a coherent legislative framework on batteries in Europe. Please find the feedback of the ZVEI in the document uploaded enclosed.

ZVEI welcomes the EU Commission’s objective to increase data availability and better access to public data, as well as facilitating private data sharing by increasing trust and reducing the transaction costs. The creation of a trusted European data infrastructure will support data-driven innovations in the economy.

In view of the tense economic situation in Germany and Europe, ZVEI strongly supports the EU Commission's goal of strengthening competitiveness in Europe through simplification and less bureaucracy. The Commission's proposals send an initial signal for reducing bureaucracy: especially the deletions of the SCIP database goes in the right direction. However, there is potential for more.

ZVEI Statement on the EU COM Draft F-Gas Regulation (EU) Nr. 2014/517 of 05 April 2022 Statement of the Power Engineering Association for the "Switchgear" sector, 28 June 2022 Fluorinated greenhouse gases ("F-gases") and most ozone depleting substances (ODS) have a global warming potential that is many times higher than that of carbon dioxide.

Supply Chain Communication: We welcome the opportunity to use extended SDS for the communication on hazard, risk & exposure for substances and mixtures. Standardized formats and details of the communication in the supply chain, especially digitally, should be agreed on after involvement of all stakeholders, e.g. in established standardisation bodies.

In the light of the proliferation of a fragmented regulatory landscape regarding cybersecurity, the ZVEI is a strong long-time proponent for a horizontal cybersecurity regulation for products within the proven new legislative framework (NLF).

The German Electro and Digital Industry Association (ZVEI) welcomes the opportunity to provide feedback to the Impact Assessment of the European Commission. Cybersecurity, as a cross-cutting task is a top priority at ZVEI in all its lead markets: Industry 4.0, energy, mobility, components, building, health and consumer electronics.

ZVEI German Electro and Digital Industry Association welcomes the opportunity to provide input to the European Commissions evaluation of Regulation (EU) No 1025/2012 on European standardisation. Please find attached the ZVEI position in response to the Call for Evidence regarding the revision of the Standardisation Regulation.

Housing affordability requires a life-cycle perspective Feedback to the Call for evidence regarding Housing supply and affordability ZVEI supports the European Commission's objective of increasing housing supply and affordability. How-ever, regulatory simplification must not be confused with deregulation. Europe needs less bureaucracy, not less ambition.

The DPP is the central instrument of the Ecodesign for Sustainable Products Regulation (ESPR) to pursue the goal of ensuring end-to end transparency about products throughout their entire life cycle from man-ufacturing to use, disposal, or reuse.

ZVEI, the German Electro and Digital Industry Association, emphasizes that maintaining a stable and predictable regulatory framework is essential to safeguard investments and drive Europes transition to zero-emission mobility.

ZVEI supports the European Commissions initiative to conduct a Digital Fitness Check of the EUs digital regulatory framework. We see this process as an important opportunity to assess how the growing body of EU digital legislation interacts in practice and how it affects Europes competitiveness and innovation capacity.

The ‘ZVEI, the German Electrical and Electronic Manufacturers’ Association’ appreciates the opportunity to comment on the EU Commission’s proposal for a Directive on measures for a high common level of cybersecurity across the Union, repealing Directive (EU) 2016/1148.

Strengthening cyber-resilience is an important goal, so that all stakeholders involved can live and work peacefully with each other in an increasingly networked and digitalised world. Cyber incidents cause considerable damage to both companies and private individuals and are therefore a threat for the economy and society.

The ZVEI welcomes the fact that, with this draft update to the Network Code on Requirements for Grid Connection of Generators (NC RfG (EU) 2016/631), the European Commission is defining harmonised and definitive requirements for grid-connected electric vehicles. This lays the foundation for a uniform, Europe-wide certification of vehicles.

The ZVEI welcomes the fact that, with this draft update to the Network Code on Requirements for Grid Connection of Generators (NC RfG – (EU) 2016/631), the European Commission is defining harmonised and definitive requirements for grid-connected electric vehicles. This lays the foundation for a uniform, Europe-wide certification of vehicles.

Filed in German · English published by the European Commission

ZVEI welcomes the upcoming revision of the Audiovisual Media Services Directive (AVMSD) as a crucial op-portunity to restore coherence, reduce fragmentation and enhance the effectiveness of the European internal market.

ZVEI German Electro and Digital Industry Association welcomes the opportunity to provide input to the European Commissions legislative process of an Omnibus Regulation aligning product legislation with the digital age. Please find attached our position paper with with comments and suggestions from the German Electro and Digital Industry.

ZVEI Statement Proposal for a directive of the European Parliament and of the Council amending Directive 2014/32/EU as regards electric vehicle supply equipment, compressed gas dispensers, and electricity, gas and thermal energy meters COM(2024)561 We have summarized below our comments on the proposed amendment made through the text COM(2024)561 and its annexes.

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

ZVEI statement Measuring instruments – technical update of EU rules Key comments from the perspective of the electrical and digital industry The MID should remain as stable as it is today and demand more clarification of the current MID across countries! ZVEI proposes that it should be an optional provision if the meter may or may not have a display.

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

The ZVEI supports the objectives of the European Commission to better protect consumers and create better framework conditions for economic operators through the revision of the existing General Product Safety Directive (2001/95/EC).

We thank for the opportunity to comment on the European Commission's Draft COM(2023) 781. ZVEI considers the RoHS Directive to be effective in its central function and to promote a circular economy. We are neutral with regard to the transfer of the RoHS evaluation procedures to ECHA.

ZVEI welcomes the opportunity to provide input to the European Commission's Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence (AI). From a ZVEI point of view there is currently no reason for a fundamental revision of the Product Liability Directive (PLD) or the introduction of a new horizontal legislation on liability for AI.

ZVEI German Electro and Digital Industry Association welcomes the opportunity to provide input to the European Commissions legislative process of an Omnibus Directive Aligning product legislation with the digital age. Please find attached our position paper with comments and suggestions from the German Electro and Digital Industry.

ZVEI e.V. represents the common interests of the electrical and digital industry in Germany with more than 1,100 members. We welcome the opportunity to contribute to the consultation on disclosure of information on unsold consumer goods under Regulation (EU) 2024/1781 (ESPR). A critical point from our perspective is the use of limited assurance as verification method.

The ZVEI represents the German electrical and digital industry. The membership of the ZVEI is very heterogeneous with regard to SEPs: In addition to companies that mainly act as SEP holders and companies that mainly implement SEPs in their products and solutions, many of our member companies are in a position to both hold and implement SEPs in their respective business lines.

Filed in German · English published by the European Commission

Please find attached the opinion of the German Electrical and Digital Industry Association (ZVEI) on the draft Implementing Act on Articles 17 and 13 of the Batteries Regulation. Both battery producers and battery manufacturers and the downstream customer industries use the batteries are organised in the ZVEI.

Filed in German · English published by the European Commission

ZVEI position on the Energy-efficient product legislation Omnibus simplification "Energy Products Omnibus". ZVEI welcomes the efforts of the European Commission to simplify current requirements and promote forwardlooking legislation with the Energy Products Omnibus.

ZVEI e. V., the German Electro and Digital Industry Association, welcomes the new Ecodesign and Energy labelling regulation via the revision of Commission Regulation (EU) 814/2013 and (EU) 812/2013. However, several elements of the regulation will disproportionately disadvantage specific product groups.

ZVEI e. V., the German Electro and Digital Industry Association, welcomes the new Ecodesign and Energy labelling regulation via the revision of Commission Regulation (EU) 814/2013 and (EU) 812/2013. However, several elements of the regulation will disproportionately disadvantage specific product groups.

General remarks on the European Standardisation System ZVEI welcomes the opportunity to provide feedback on the proposed Amendment to the Regulation (EU) No 1025/2012 European Standardisation. In general, we are of the opinion that the European standardisation system is set up the right way.

Environmental Policy Department ZVEI comments to Update of concentration limit values of persistent organic pollutants in waste Member of ZVEI - German Electrical and Electronic Manufacturers´ Association - offer electrical and electronic products on a global scale by processing raw materials procured from various locations around the world.

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

ZVEI is pleased to provide its views on the particular issue of embedded and business software which may be installed in this equipment and products. Our industry is committed to keeping such products interoperable in the public radio spectrum and safe for all end-users including when further software updates and reconfigurations are applied to the products, under the framework of the Radio Equipment Directive…

With reference to our statement from July 2021 on the Inception Impact Assessment and our position paper "Liability for AI" from May 2021 submitted in this context, we maintain the position that, in view of the existing technology-neutral and comprehensively applicable product safety and liability law, there are no relevant liability gaps for potential damage caused by AI applications and systems and thus no need…

ZVEI welcomes the European Chips Act (ECA). Now is the right time for Europe to become globally competitive for investments in semiconductor technologies. The ECA addresses necessary issues regarding strengthening Europe’s competences in the microelectronics ecosystems as well as state aid for capacity building, while also introducing far-reaching and unprecedented market interventions which ZVEI deems to be not…

Addition of an exemption for ATEX products Smartphones and tablets for Ex applications are a high technology niche, where European companies are currently leading worldwide manufacturers. Those Ex products are intended only for professional users in Ex environments. They are often used among others features for important communication and locating personnel in large facilities.

The ZVEI fully supports the objectives of the continuous further development and comprehensive implementation of the Stockholm Convention on POPs, including the introduction of a UTC value for polychlorinated biphenyls (PCBs) as part of the adaptation of Regulation (EU) 2019/1021 on persistent organic pollutants (POPs) in order to ensure legal certainty on the European market.

Filed in German · English published by the European Commission

As representative of Germany’s manufacturers of household appliances, ZVEI e.V. appreciates the possibility to comment on the European Commission’s call for evidence on the future regulation of vacuum cleaners. We sincerely thank you for considering our comments and are available for any of your questions. Please find a detailed statement attached. Thank you.