DIGITALEUROPE has been asked to provide data on television models placed on the market in order to contribute to an energy label database pilot project undertaken in Germany. We would like to take this opportunity to also make some general comments on the project.
Overall, DIGITALEUROPE does not support the introduction of a confidential database, since in our view it would be disproportionate in terms of costs and burden on manufacturers. There is a risk of losing confidential business data, know-how and IPR. In addition there are uncertainties concerning liability and potential negative consequences on businesses in case of technical or similar failures of the database.
It is not clear how this pilot project will feed into the EU policy making process. However, industry would like to reiterate the importance of a thorough and representative stakeholder consultation on the development of any potential database. Given the short timeframes for implementation of this pilot project, it is understood that the stakeholder consultation will be limited in scope and it is important that conclusions from this are not automatically transferred and assumed to apply in the broader context of products and equipment. There is a concern that details of the database are being discussed prematurely and without time for detailed input from manufacturers (for some the data is managed outside of Europe).