22 Aug 2016

Industry Comments on Germany Product Database

Industry Comments on Germany Product Database

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).

Back to Sustainability
View the complete Policy Paper
PDF
Our resources on Sustainability
Policy Paper 11 Jun 2020
JBCE – DIGITALEUROPE joint position paper on the NFRD review
Policy Paper 27 Apr 2020
DIGITALEUROPE’s Initial Views on the Revision of Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical & electronic equipment (RoHS)
Policy Paper 31 Mar 2020
DIGITALEUROPE Initial Recommendations for the Revision of the Battery Directive in 2020
Hit enter to search or ESC to close
This website uses cookies
We use cookies and similar techonologies to adjust your preferences, analyze traffic and measure the effectiveness of campaigns. You consent to the use of our cookies by continuing to browse this website.
Decline
Accept