Committee on the Internal Market and Consumer Protection Ordinary meeting
Legend
Transcript markers
- text Sentence being played
- text Search result
- text Intervention cited by the link you opened
Click a sentence to play the video from that moment. Select text to quote it with the speaker, timestamp and link.
More options
Offset
Transcript offset
Export
Replay
Versions of this video
Transcripts may differ slightly from one version to another.
IMCO European Parliament
Follow its sittingsBrando Benifei
The discussion was particularly timely following recent incidents involving autonomous hacking by AI agents and concern about loss of control over advanced AI models. They are among the systematic risks addressed by the AI Act's rules for the most powerful models. The AI Office presented its enforcement priorities, explaining that alongside ongoing dialogue with major providers over the past year, it has now issued requests for information to assess compliance and examine safety incidents. Members raised the question of incidents caused by models that an AI company develops and uses only internally without public release. The AI Office suggests that if an AI model is kept in a training environment and then it has an impact on the EU market, as was the case for Hugging Face, then the AI Act becomes enforceable.
Members inquired whether the Commission is considering AI liability rules to fill legislative gaps and make redress possible when such experimental AI models and autonomous agents cause harm. Members also raised concern about under-reported safety incidents with the AI Office and asked what action the office intends to take. The session also featured a presentation by the...
Members also raised concern about under-report safety incident with the AI office and asked what action the office intend to take. The season also featured a presentation by the AI accountability lab detailing training content transparency summary under articles 53 highlight the many required disclosures remain missing on really on vague boilerplate text. The working group will meet again on 11 November to discuss the code of practice on marketing and labeling AI generated content. Thank you very much.
Anna Cavazzini
Thank you Maria slash Brando for reporting back. Great. So for now this is our reporting back because one colleague is late we do it later and start now with our hearing on the European Product Act. I'm extremely happy that we have so many distinguished guests here. You know that the European Product Act and the question of how we can strengthen European enforcement in the e-commerce sector how can we make our products really safe on the internal market and also how we can foster second-hand refurbished products is one of the top priorities for this committee.
We have been working a lot in different resolutions on it and we are very happy that the Commission had finally announced the European Product Act. Now there are some slight delays but probably that also gives us the chance to again also listen to the experts and discuss with you what is really important to have in where are the gaps and what can we also push as European Parliament. So I'm very happy that we have these two distinguished panels. You know the program we start with panel one that is more meant to have an evaluation of the current framework. So we want to look at the new legislative framework the market surveillance regulation and the standardization regulation and see where they're still fit for purpose but where they need some updates.
And then in the second panel we want to address more the way forward and what the European Product Act is supposed to bring. So panel one we start with our speakers with Ms. Barbara Bonvissuto director for construction machinery and market surveillance at DG GROW from the European Commission and each of you has seven minutes. So welcome.
Barbara Bonvissuto
Thank you very much chair and good morning everyone. As always very timely this discussion because we just adopted the standardization regulation proposal last week and we are in hopefully the final stages of finalization of our proposal on the European Product Act. So the two proposals really go hand in hand. There are many synergies between the two not least because standards harmonized standards are highly used in order to provide compliance with the legal requirements on the product legislation. Now and both they highly contribute to the overall objectives stated in the one Europe one market roadmap of deeply integrating and strengthening the internal market.
So I will first start with giving you the highlights of our recently adopted proposal on the revision of standardization regulation and then I will give you some hints into what we are trying to do be trying to do with the European Product Act.
So first of all standardization. I in this committee we have often discussed about the strategic importance of standards. Standards they do support the competitiveness of our industry especially when we as the European community we are able to export our standard worldwide meaning that our companies can produce to one set of technical requirements and export everywhere in the world. They also as I was mentioning earlier highly facilitate compliance with legal requirements which is very much important in particular for SMEs who have a benchmark against which they can they can produce their products. And obviously they are an important instrument also for our sovereignty strategic autonomy for the defense of our values.
But in order for standard to actually support competitiveness to actually support our strategic autonomy and our resilience we need an efficient standardization system. And efficient standardization system means a system which delivers the standards when they are needed. And though our system has a lot of value and has a lot of strengths we have seen recently that it has some shortcomings. And many times it happened for example that legal requirements are in force but the underlying harmonized standards are not available which then leaves the companies in a doubt and how to show compliance and then they have they don't have the common benchmark. We also see that standardization has become highly relevant and strategic for many of our trade partners which means that they for example invest highly in strengthening their influence in international standardization bodies such as for example ISO IEC and and while it is welcome obviously that we have more third countries active and participating in such international standardization development we need to be careful that we continue as the EU to be standard setter rather than standard taker.
And then we have also the big challenge which stems from the jurisprudence of the European Court of Justice which has ruled that standard should be freely accessible. So faced with these challenges what has been our choice? It's a choice of evolution not revolution in the sense that we highly value the public private partnership system which we currently have where the legislators they work hand in hand with the standardization organization but we need to make sure that the system is faster is of produces standards of higher quality is more inclusive and that we deal with that in a more strategic way. And to do that we have worked in order to introduce some flexibilities to the system.
So if and so first thing that we try to do is to have a system which is more effective, which is faster. And here the the default route will always be the one of the European Commission addressing a standardization request to the European standardization organization. But if this doesn't work, and unfortunately we have seen in the past there have been cases where this didn't work, we need to have the alternatives going to other standardization organization or if that is not possible, adopting common specification, Commission common specification. And we have also included a series of timelines in order to make the overall process from the issuing of a standardization request to the publishing of harmonized standards shorter. We are have introduced provisions to make sure that the system is even more inclusive than the system the current system we have and allowing greater participation of SMEs, of civil society.
This is it's important in order for standard to be sure the standards actually reflect our values and interest of everybody in the EU. Then we have addressed the issue stemming from the jurisprudence of the Court of Justice, making sure that standards are freely available. And we have been working very closely with the ESOs, the European standardization organization on that because we want to combine this greater accessibility with keeping the viability of the business model of the European standardization organization and this is the balance we have tried to to keep there. And then on international, what we are the message that we are passing through the revision is we need to be a key actor in international standardization system, which means having the capacity to prioritize, to coordinate, but also choosing strategically when we have to go directly at the international level or when we first have to develop a standard at the domestic level and then exporting it at the international level. So this is these are the main highlights of this standardization system.
I will now spend a few words on the European Product Act. This is still in the making, so I cannot give at this stage too many details, but the idea or the objective is to make sure that we have rules which are adapted to the modern cycle of products. So products which evolve over time because of digital changes brought by software, products which evolve over time because they are refurbished. That we have rules which are simpler and coherent across all product legislation. We make the best use of the digital tools that we have.
And then that we have a single market which is protected from unfair competition. We cannot e-commerce has increased by 300% since 2022. And we see this translate into a flooding of non-compliant goods. This is not good for the protection of health, consumer protection, environmental protection, but is also not good because it undermines the competitiveness of our companies. So we want to introduce rules to make sure that only compliant products enter the market.
I see that I am already at seven minutes, so I will stop at that, but then in the question and answer session I can provide you with more details. Thank you very much.
Anna Cavazzini
Yeah, thank you so much for presenting the standardization proposal that we of course have all already looked at, but of course it's it's good to hear from the Commission again what your goals behind it is and I'm sure there's there will be also questions. So now I would like to welcome our next speaker, who is from the Hungarian Ministry for Economy and Energy. So welcome.
Fanni Oroszi
Thank you.
Honorable Chair, distinguished members of the IMCO Committee, representatives of the Commission and stakeholders, I am honored to address you today on behalf of Hungary's Ministry of Economy and Energy. As the ministry responsible for shaping our national market surveillance policy and overseeing the national trade and consumer protection authority, I would like to share our practical experiences and outline our core expectations for the upcoming European Product Act. The European market surveillance system stands at a critical crossroads. The explosion of e-commerce parcel volumes, fragmented supply chains, and the dominance of third-country digital platforms mean that our traditional law enforcement models and physical border checks have reached their logistical limits. While Hungary remains deeply committed to the single market, we must honestly admit that the existing frameworks can no longer independently guarantee consumer safety.
We highly value the Commission's efforts. The integration of the ICSMS and Safety Gate systems already allows Member States to adopt test results mutually, saving critical laboratory capacity. Similarly, the e-surveillance tools have significantly reduced administrative burdens during initial risk screening. However, profound structural bottlenecks remain. Millions of low-value e-commerce parcels arrive daily, making comprehensive physical inspections impossible.
Because third-country sellers ship directly to consumers, there is often no accountable economic operator within the Union to sanction, rendering product recalls highly ineffective. This dynamic creates a dangerous liability trap. When European citizens order directly from third-country platforms, they inadvertently become the legal importers of those products. If a defective product causes a fire or an injury, consumers find themselves defenseless, having unwittingly forfeited their warranty and damages rights under EU law. Furthermore, the Article 4 mechanism of the Market Surveillance Regulation has proven inefficient.
Many listed Union contact points exist only on paper, are unreachable, or lack access to technical documentation. For wholesale container freight, authorities face massive documentation fraud where CE markings and test reports are entirely fabricated. This is compounded by a persistent information gap between customs and market surveillance, causing logistical friction at our borders. At the national level, enforcement is complicated by a fragmented institutional landscape split across multiple sector-specific authorities. We take note of the Commission's 2025 Product Safety Report and the subsequent evaluation from July 2, 2026, which highlighted our low customs rejection rate of 0.5 per million declarations in 2025.
This performance fell below EU standards, primarily due to the exponential surge in e-commerce volumes. We have actively addressed this shortfall. Through 2025 and early 2026, Hungarian customs and market surveillance authorities increased targeted inspections sixfold. By the first quarter of 2026, our refusal rate rose to 1.5 per million.
Nationally, up to August 31st of this year, our authority executed 2,512 inspections, initiated over 1,000 formal proceedings, and our imposed fines are exceeding 200 million forints. It is also worth noting that 44% of our incoming customs alerts fell under other sectoral jurisdictions, which artificially lowers our main metric. Our 2024 priority control area joint action clearly illustrates the problem. Targeting private imports under 150 euros from major platforms like Temu, Shein, AliExpress, and Amazon, we physically inspected 300 selected packages. Out of 20 suspect product types sent to laboratory testing, including toys and electrical devices, we found a shocking 100% non-compliance.
This is a high danger rate, and identifying severe choking and electric shock hazards were also found. Crucially, the exercise proved that we must urgently refine our initial risk profiling using precise customs tariff codes and keywords to increase our screening hit rates. Looking forward, we anticipate that the European Product Act, scheduled for late 2026, will deliver the most significant reform to product safety law in two decades by merging the new legislative framework with the market surveillance regulation. This legislative fusion must transition our framework into a digital and circular reality through five core expectations. First, we expect horizontal coherence.
The EPA must provide a unified glossary to eliminate interpretative uncertainties across market surveillance, customs, and consumer protection laws. It must clearly interface with the GPSR, the DSA, and sustainability requirements to avoid overlapping obligations and minimize administrative burdens for both businesses and public authorities. Second, the regulatory framework must be digital by default. We support a central EPA registry requiring pre-market registration alongside a digital product passport accessible via a QR code. To prevent administrative overload, full real-time digital interoperability is vital.
ICSMS, Safety Gate, national customs, and the future EU customs data hub must be seamlessly connected, enforcing the once-only data entry principle. We specifically call for rapid ICSMS-CERTEX integration. Third, online marketplaces must be elevated to co-responsible economic operators. The EPA must mandate proactive screening obligations requiring platforms to automatically verify the existence of a digital product passport before a listing goes live. Fourth, we need intensified coordination.
While we support central coordination initiatives led by the Commission to save resources and also to improve data flows, we must maintain the right balance. Any shift of tasks to the Union level must be backed by solid data to avoid an unjustified curbing of Member State sovereignty and autonomy. Finally, the EPA must legally recognize circular economic models. We require clear legal guidance on when and by whom conformity reassessments must be conducted when products are substantially modified, officially recognizing refurbishers as a distinct category.
This must align with the modernized Product Liability Directive as well to ensure that if a digital defect causes damage, the liability chain remains instantly traceable. In conclusion, we expect the European Product Act to ensure the legal simplification goes hand in hand with strengthened regulatory efficiency. The EPA will be a real step forward if it delivers legal certainty, a clear chain of liability, better data sharing, and more effective border controls. Ultimately, product safety rules on the single market must not only be uniform on paper, but enforceable with identical efficiency across all Member States. Thank you for your attention.
Anna Cavazzini
Thank you so much for representing also a Member State's view. I think it's also very important to get knowledge or make use of your experience from the ground. So now we come to Ms. Patricia Gautier, Head of Consumer Rights from BEUC. Welcome again to our committee.
Patricia Gautier
Chair, honorable members, thank you very much for inviting BEUC to this discussion. When we talk about the future of product law and market surveillance, it's important to begin with the simple reality. Consumers increasingly buy products online, often from sellers from located outside of the Union through online marketplaces. And unfortunately, the enforcement of product safety rules has not kept pace with this transformation. And the numbers speak for themselves.
According to the European Commission's data, the numbers of low-volume parcels entering the EU continues to grow at an extraordinary pace, and it has reached now six billion consignments in 2025, which is enormous. And at the same time, our members, consumer organizations across Europe, continue to identify unsafe toys, electrical products, cosmetics that are being sold online. And the key conclusions from this from those tests and monitoring, market monitoring, is that this is not a series of isolated incidents. This problem is really systematic. And the European Product Act presents a unique opportunity not only to modernize market surveillance, but also to close the enforcement gaps that allow for those products to reach European consumers.
And during my intervention, I would like to focus on three priorities. First, online marketplaces must be accountable. Today's framework was largely designed for for a world in which products were sold through identifiable and reachable manufacturers, importers, distributors. But that's no longer the reality. A growing share of products reaches consumers through online marketplaces, often direct directly from third-country sellers.
And when what we've heard also from previous speakers, when authorities discover unsafe products, they frequently struggle to identify an economic operator in the EU that can be held responsible. And the recent findings of the product safety sweep highlight that the scale of that problem. According to to that sweep, only in 22% of cases the EU authorized representative has actually complied with its obligations and confirmed that they are indeed responsible for a certain product, and they complied with obligations under the General Product Safety Regulation. And that raises very serious questions of whether in practice an accountable economic operator that is capable of ensuring compliance, cooperating with authorities, and taking corrective action when unsafe products are identified really do exist in practice.
A European Product Act should close this enforcement gap and ensure that there is always a party who can be held responsible for products that are found unsafe. That concern is shared far beyond consumer movement. In July, we have signed together with almost 80 industry, consumer, and civil society organizations a joint call for the European Product Act to close those enforcement loopholes. And we see it not only as a consumer protection problem, we see it being also about competitiveness. Businesses that invest in compliance, product safety, and the quality of their products, they should not have to compete with operators that can evade EU rules and responsibilities.
If online marketplaces profit from the access to the single market, they must also contribute to protecting it. Second point, we need stronger enforcement also at the EU level. The lesson we have learned from the recent years is that unsafe products, they don't respect borders, but the enforcement remains largely national. A product that is listed on an online marketplace, it can be sold in 27 member states within hours. And yet market surveillance authorities, they still investigate largely within national boundaries.
And that can create some duplication, inefficiencies, enforcement gaps. We of course recognize that the current market surveillance regulation has significantly improved the cooperation of national between the national authorities. And this strengthening of this cooperation further, ensuring that the authorities have the necessary powers, interoperable IT tools, and sufficient resources, it still remains essential also for the upcoming reform. But at the same time, product safety risks increasingly arise and spread across the single market, particularly through online marketplaces operating across borders. And that's why we think that the European Product Act should also complement this national enforcement with an EU investigative EU-level investigative and enforcement powers, including with the ability to impose fines in cases that are affecting consumers across the Union.
The third point I would like to raise is about the penalties. They must be meaningful. Recent investigations, they show that even though we have quite strong product safety rules in the EU, the unsafe products, they still continue to appear on market on the market despite repeated enforcement actions, despite the testing done by consumer organizations. We also often find the products that have been previously removed reappear on online marketplaces, which is unacceptable. And one reason for that is that the current penalty framework, it remains very fragmented.
And there are strong differences also between the member states. The European Product Act should therefore establish a more harmonized and effective penalty regime across the Union. We have to remember that for large companies, low fines, they risk becoming merely a cost of doing business. And companies that systematically sell or facilitate the sale of unsafe products, they should face consequences, and those consequences should be serious enough to genuinely incentivize prevention and compliance. And to achieve this, we think that penalties should be linked to a percentage of the annual worldwide turnover.
Ultimately, I would say that the new rules should focus also on prevention, not only on managing the consequences of once the unsafe products have already reached consumers.
seriously and to stop the unsafe and dangerous products to enter the single market in the first place. So allow me to quickly conclude. The European Product Act should build on the momentum that was created by the customs reform and complement it by ensuring that products that enter the single market are not only properly controlled at the border, but they are also subject of effective oversight once offered to European consumers, either in physical or online shops. And what we need today is a safer single market, a level playing field for responsible businesses and strong consumer confidence that the products they buy, regardless of where, they are safe. Thank you very much.
Anna Cavazzini
Thank you so much and in general for BEUC's work of always bringing the consumer perspective to our debates. We have now the last speaker for the first panel. I welcome Mr. Simone Cimadomo, project and policy officer at RREUSE. Do I pronounce this correctly? Yes.
Simone Cimadomo
Thank you. Thank you, honorable chair and honorable members present and all other stakeholders present with us here today to discuss this important topic. Indeed, I'm from RREUSE. We are the European network of social enterprises that work in the circular economy. We represent broadly 1,300 social enterprises across Europe that work daily to prevent waste on one hand and at the same time provide inclusive employment for people that normally face barriers to the labor market.
It's easy to guess how the operations of our members, of course, are impacted by product policy and product legislation, seeing as they daily handle used products. They collect, sort and prepare for reuse lots of large volumes of used products that were previously placed on the EU market, seeing as they prioritize local reuse. They, as I said, prepare them for reuse and often resell second-hand, so competing on the internal market. This is also why over the years we've been able to see the many benefits of product legislation in the EU. On one hand, we had a new legislative framework that was successful at the time and over the years to improve the coherence and alignment of product laws.
It established, let's say, a toolbox of definitions, of procedures, of templates that we can, that can be used and can help stakeholders also be familiar with the rules. We also saw how it shaped product policy over the years and actually very recently, even in the field of circular economy, by facilitating the adoption, for example, of the Ecodesign for Sustainable Products Regulation, which is aligned with the NLF, which is actually now in its implementation phase and we are working very much on that as well. On the other hand, we had a market surveillance regulation that also successfully set out the necessary infrastructure, let's say, to make sure that the products or, yeah, ideally to ensure that the products placed on the market respect the EU regulatory requirements. Of course, despite these successes over the years, we've seen also many shortcomings that emerged in these legislative frameworks, as demonstrated as well by the evaluations carried out by the European Commission, for example, in previous years. So all of this demonstrates the need for a revision.
And we believe these shortcomings that emerged over the years can be summarized broadly in two points. First, of course, we have a new legislative framework which, to put it very shortly, is no new anymore. It's become fairly outdated and is still geared towards a largely linear economy, without really supporting existing and emerging circular business models in reuse, repair and refurbishment, which actually have been central in more recent sectoral legislation. And again, I want to mention here the ESPR that has been successful and even went further in supporting these models and which we think could actually inspire certain elements of the future European Product Act in a way.
I don't need to repeat what the other speakers have said here, but really we've seen an exposure of existing loopholes in compliance and we've seen also how e-commerce has fueled overproduction and overconsumption in the internal market, directly impacting of course on one hand reuse and waste operators, which I today represent from the side of social enterprises, but also market surveillance authorities, all of which need to deal with growing volumes of products that are put on the market and then eventually become waste or are disposed of and enter waste streams. So we've also seen how action from customs and market surveillance showed that these products are often in breach of EU rules, ranging from essential safety requirements, so impacting directly consumers, ecodesign rules, but also and importantly also for the waste sector, extended producer responsibility obligations, which are central of course where relevant to really financing the waste prevention system and waste management system. So all of this of course cause negative consequences on consumers first and foremost, on compliant businesses that operate in the internal market, on the environment and of course on downstream operators. And I want to focus here a little bit more on downstream operators, not just because I represent social enterprises today, but also because we've seen that the business models of these major online platforms that sell directly to EU consumers often rely on really rapid large-scale production of cheap products that we all know too well. I mean I could make examples here that are very familiar I'm sure with everybody, such as ultra-fast fashion models, but also increasingly fast tech and cheap electronics that enter the EU market, they're often found again to be non-compliant.
And the same non-compliant products then again cannot be reused or resold as second-hand, so they cause further losses then to reuse and waste operators. Now the shortcomings that I've highlighted so far of course are the exact reason why we look forward to the upcoming European Product Act and the intention also that we see from the Commission to really revise current rules in view of a transition to a circular economy and then in view of the challenges related to non-compliance from e-commerce. So we believe that the European Product Act should really act on these two levels: on one hand enable and support existing circular business models, really act on this, and at the same time prevent unfair competition from imports often from third countries through e-commerce platforms. This was also something that was mentioned, and I want to stress this, in the INI report that this committee actually worked on on the revision of the new legislative framework, which is a really good starting point actually for future discussions. The question of course now is how do we do it, you know, how do we actually make sure that these two things are tackled?
And from our side I think the focus on the first point that I brought, so supporting circular business models, should really be on first harmonized definitions of what these business models are, so what the activities that they carry out are, to ensure that there is first a clear distinction and different responsibilities for these actors, so to ensure clarity. Ideally these definitions should be aligned also with sector legislation, because we have definitions already in the ESPR for example for these types of actors, but they should also be inclusive really of all relevant actors in each category so as not to exclude also smaller actors such as of course I bring the example of social enterprises. So this is really the first point for me. On the topic of definitions I think we should also clarify really what constitutes a substantial modification of a product when it has a second life.
ing or software updates or data wiping, so normal operations that are also common in refurbishment do not constitute a substantial modification of a product. So we really, this should really be reflected in the in the upcoming European Product Act. The last point I want to mention, because I also see I'm close to I'm close to the limit, is also to provide refurbishment information. This is also something that the ESPR has stressed more and more, but of course depending on product categories, and we should really see it at a horizontal level in the upcoming European Product Act. So I want to just conclude with this, and I really look forward to working with this committee on this on this file.
Thank you.
Anna Cavazzini
Thank you so much for bringing in the perspective of the refurbishers. So now for the first panel we have the opportunity to discuss with you as experts, and the members can just signal me, and I think you made the list already, so Dirk is starting.
Dirk Gotink
Thank you, Chair, and thank you, panelists. I've getting some flashbacks on on this regarding the customs work we did, only that this will be ten times more complex because the issue with the so one member state, one customs. Here we have one member state and I don't know how many market surveillance authorities and I don't know how many protocols and standards and well, social enterprises. So I think everyone, not only the Commission, but also the stakeholders, could be could be challenged to really stick to well, what I would say centralize and simplify, yeah, centralize, simplify. We have to clearly integrate, this is what we did with the customs as well.
It doesn't work. We cannot say to European citizens that the single market is a single market if we treat it like a one big fragmented marketplace. So clearly there is a need to centralize and a huge need to simplify. And that's where my my concern will be also in sort of working with the rest of the process. Now when it comes to the market surveillance, we've spoken to many in the past years that have basically said, listen, we can't we simply can't do our jobs anymore.
No data, we have no idea where where we don't have lab capacity, we don't have the expertise, we don't have I mean everything from from the beginning to the end. What would your advice be in regarding the organization, so I'm really asking for practical insights, the organization of market surveillance to be this top-up of the customs integration that we have done now from the different perspectives of the panelists. I would be interested in that. Thank you.
Saskia Bricmont
Thank you very much. Good morning everyone and thank you for all the very interesting points that you've already raised. We see there's a lot of work ahead for the Commission and many challenges that also have been raised by my colleague. We've had several times discussions here already on the follow-up on Shein-style scandals. And I would really like us together to take the opportunity of this legislative changes to to tackle this at the roots.
So what do you foresee in the legislation to really avoid such scandals to happen again and to fight against this unfair competition as it has been said, but also endangering consumers. How can we make it possible that to allow the possibility for immediate suspension of the marketplaces in certain cases or as soon as we see, you see that products are not in conformity with the EU law. My second question is also related to prevention. It has been raised by BEUC intervention.
So what focus will be put on preventing that unlawful products that are not conform with EU rules are put on the market? And my third question is also related to the last intervention of the social economy sector. We've seen impacts of the EU legislations coming into force, like the waste directive before the EPR is really effective. And this has a huge adverse impact on social economy sectors. So is there, are there impact assessments that are conducted to avoid this, voilà, the fact that the legislations are complementary on the one hand but not applied at the same moment and can have impacts on the sectors?
We need impact assessments to be prepared for the implementation of those legislations and avoid that sectors suffer from these new rules. Thank you.
Elisabeth Grossmann
Thank you. I'm speaking German. So please use your headphones if necessary. Vielen Dank für Ihre umfassenden Ausführungen und auch Empfehlungen aus der Praxis. Es zeigt, wie wichtig auch die Zollunion ist und eine europaweite Produktüberwachung.
Und daran schließen auch meine Fragen: Welchen Personalressourceneinsatz erwarten Sie auf welcher Ebene? Wir haben nun die europaweite Zollüberwachungsbehörde ja in Lille mittlerweile angesiedelt. Welche zusätzlichen Ressourcen auf europäischer Ebene und eventuell auch, sofern es sich sagen lässt, auf nationaler Ebene? Und Sie haben auch mehrfach davon gesprochen, dass Online-Marktplätze verstärkt zur Verantwortung zu ziehen sind. Wie könnte nun diese Verantwortlichkeit aussehen?
Dass jedenfalls zu überprüfen ist, ob ein digitaler Produktpass vorliegt. Inwieweit kann auch der digitale Produktpass hier in der Umsetzung behilflich sein? Welche Informationen sollten diesbezüglich auch im digitalen Produktpass mindestens enthalten sein? Vielleicht können Sie uns hier auch Empfehlungen aus der Praxis geben, damit wir uns dann natürlich auch in der Legislative leichter tun. Danke.
Anna Cavazzini
I'm just checking if Piotr or Laura want to come in. No. No. Then I have probably last question and then I give the floor back to you. Probably my question is to reuse.
I think it's very important that as you said that we have like this common definitions, that it's a little bit clearer, that it's harmonized. I wonder nevertheless that of course reuse and second life stakeholders have to have different obligations than economic operators who put a new product on the market, right? So it needs to be I guess for you guys easier to bring a product back in the market and not to have exactly the same obligations than a...
Can you, can you specify a little bit what you need in order to make your life easier on that front? This I would be really interested to know. Thanks. So probably just go one by one again and probably you can try to concentrate around one or two minutes. Thank you.
So we start with the Commission.
Barbara Bonvissuto
Thank you very much. So first of all, integration, it's key. The resources are very scarce. We need to pool resources and already with the Customs Code, there are obligations for customs authorities to cooperate with market surveillance authorities. We will strengthen them also on the other side in the European Product Act so that market surveillance authorities cooperate more with customs authorities, but also, and it was already mentioned by one of the previous speaker, integrate the database, making sure that all the information we have, which is available through market surveillance, through customs, through the digital product passport, they are all integrated in an interoperable system and then we make the most use of the information that we have.
Digitalization will help a lot in this, and in particular the digital product passport, because it will help keep in track products and also the digital product passport, the idea would be that when there is an instance of non-compliance, it basically, it becomes invalid. And this is an information which will be sent to all the relevant economic operators and authorities. So maybe a step back. First of all, for all products which will be imported in the internal market, there will be a responsible economic operator. This is not the case currently, and for example in the case of authorized representative, there would have to be a clear mandate, they will have to be included in a registry so that if any instance of non-compliance occurs, the authorities will know to whom to address.
Then the online marketplaces will have to check automatically that the products they put on their on offer in their in their listing, they have a valid digital product passport, they have an authorized representative, and whenever there is an information from the authorities that there is an issue, then they will have to withdraw. And this will also prevent the reappearance, reappearance of products. And then maybe finally on the issue of staffing resources, well, we are, we are still discussing that. The proposal is still in the making. Our idea is that when there is a when there's a problem and the national market surveillance authorities are not acting and the problem is of EU scale and there's a high risk, then the Commission may be able to carry out investigation on its own, which then means that we will need staff for that, staff and resources.
Anna Cavazzini
That we hope to be able to finance through a fee that we will impose on imported goods.
And of course you know that the Parliament had asked for a proper European market surveillance authority. I guess you're also checking this, I hope. Before we go to the next speaker, I want to welcome a delegation from Sri Lanka here in our committee. Welcome, it's great that you're here. We're just discussing how to tackle e-commerce problems and probably you have the same.
Yeah, you can have an applause. Welcome here. So I give the floor now back to our panel. We get back to our Member State, the representative from Hungary, Ms. Ordasi, please.
Fanni Oroszi
Thank you.
But I think what would be important is to have a centralized coordinative authority in all member states, including in Hungary. I think coordination is extremely important in this case, and I agree that digitalization will help with this, but we also need the human resources necessary for that, because even if we have digitalization in this area, we still need the people who are doing the job. And I think in some member states, this is quite a big problem, as I already spoke about it in Hungary, we can see that there are so many products arriving from third countries. We really need the people for that, apart from the legislative proposals that are discussed here today. Regarding the online platforms, I agree with what was said before.
I think it is important to have responsible economic operators in all cases. We see this as a problem too, and I think cease and desist orders, high fines, and blocking pages instantly, coordinated between member states or coordinated by the Commission, depending on what will be the decision on that, I think that would be important. Thank you.
Patricia Gautier
Thank you very much for a lot of interesting questions. I will try to address at least some of them. First of all, maybe on the online marketplaces. Currently, they are not considered economic operators, and that means that they completely escape any kind of responsibility for products they sell to European consumers. What we think is that right now, the concept of authorized representative, that in practice does not work.
They are unreachable, often or even do not exist. And even if the Commission now is planning to strengthen this concept, if an authorized representative is still not available, which can happen very easily in reality, we think there should be this last resort falling on online marketplaces and the possibility for them to be held accountable so that the market surveillance authorities have someone to enforce the law against. On the resources, of course, this is super important. It is a big priority, I think, for the EU now and for European consumers as well, to make sure that products are safe. The authorities need to have sufficient resources, powers, but also the IT tools that would help them to conduct their work efficiently.
Those tools need to be interoperable, of course, the information flow needs to be very smooth between the authorities, but also with the Commission or the centralized authority. For what concerns the centralized powers, what we have noticed in consumer law enforcement is that the cooperation has its limits. At some point, if there is no strong deterrent effect that goes with a strong power on the EU level, the companies don't have this incentive to make sure that they comply. And that's why we think this new initiative could be a great opportunity to tackle this as well. Thank you.
Simone Cimadomo
Thank you. Yeah, thank you for the many questions. I will try to address some of them. The first one maybe where I can come in is on ultra-fast fashion scandals and you know how we can fight it in legislation. I think on this, I mean, I could touch upon many different pieces of legislation, many different ways in which we can address it.
I think for the purposes of today, of the European Product Act, I think there is work to be done on liability, on ensuring that simply they are, you know, these platforms are recognized as economic operators, ensuring that there is an EU operator responsible for products when they are sold. That's really number one. However, I also think that's in a way treating the symptom maybe rather than the actual problem.
I think through other pieces of legislation we can really then tackle these business model models at the source. Again, I don't want to go into too much detail today, but I can just make some examples. You know, there is of course the ESPR can act on this. We have also eco-modulation under EPR schemes that can contribute in a way to tackle this these issues. We also have the Digital Fairness Act, which should protect consumers against these these business models.
So, you know, there there are instruments at our disposal. The EPA is one of them, and I mentioned how how it could be how it could work in this in this respect. But indeed, yeah, thank you for for raising this. And also thank you for to Bricmont for raising the issue of the time gap between, well, taking the example of course of the textile sector where social enterprises have been responsible for separately collecting textile products since 2025. However, without implementation of EPR schemes until until in the future in the next few years.
So how do we obviously how do we tackle that? I think of course it should be done through a very ambitious Circular Economy Act. I know this this, I mean, again, it's not the topic of this hearing, but this committee will work on this and and we look forward to to working on that as well. So it's really it's really something to keep in mind to really support the the sector in that. And I'll keep it short again because because I don't want to go off topic.
But then the last the last question where I want to come in is is yours, yeah, on really what do we need when it comes to, yeah, definitions and other provisions of the European Product Act. I think from our side, the issue with definitions is is really to have clarity on responsibilities and to ensure that there are no misclassifications, you know, when when actors give a second life to products and don't substantially modify them, they shouldn't be required to have a conformity assessment that is comparable with the with a new product. I think this needs no explanation, but, you know, those kind of operations usually don't and should not require a conformity assessment. I also want to mention again something I was briefly touching upon before, the information for safe refurbishment and and for repair. This is also something that should be that should be mandated.
And I also want to stress there should be some caution, some safeguards also to ensure that these instructions that again should be provided are not restrictive then to refurbishment and repair. I again I don't know exactly how to ensure this, but perhaps it's something we can work towards also when it comes to amendments and when also we will see actually the European Commission proposal. But yeah, something to keep in mind and for the future. Thank you.
Anna Cavazzini
Thank you very much to all of you, to the excellent first panel where we examined like the gaps, but of course we looked already ahead. But now the second panel as I announced will be really concentrating thoroughly on the future European Product Act. And we start with Ms. Margherita Cossaro, Senior Policy Advisor from Ecommerce Europe. Welcome. Also seven minutes each.
Margherita Cossaro
Yeah, thank you very much, honorable chair and members of the EP IMCO committee. I would like to start by thanking you for the invitation and also the acknowledgment of the work that Ecommerce Europe has been doing in the last years on product compliance, especially in e-commerce. By the way, Ecommerce Europe is the unified voice of companies selling online to EU businesses to EU consumers. I can tell you that the NLF, the New Legislative Framework, and the Market Surveillance Regulation have been quite high on our agenda lately. The EU product acquis, the EU product legislation, has been instrumental for e-commerce to thrive in the EU.
Harmonized rules are an enabler of EU-wide cross-border sales of products. Common definitions, streamlined procedures, and minimally rationalized requirements help businesses navigate the landscape of product legislation.
Of course, thanks to harmonization efforts, the concept of compliance is the same in the whole of the EU, at least in theory. However, in the last years, different challenges have put pressure on the EU product rules framework overall. To begin with, the EU product rulebook has been moving a lot in the last few years. Just think of the General Product Safety Regulation, the new Product Liability Directive, the Ecodesign for Sustainable Product Regulation, but also Toy Safety Regulation, Detergents and Surfactants Regulation, etc. Changing rules, of course, temporarily increases overall compliance costs for businesses.
Nevertheless, this cost can be compensated if the rules are easy to understand, implement and are enforced in an equal and systematic way. But here lies the second challenge, of course. Compliance has become more complex and costly, while enforcement has been unevenly exerted. National authorities have different ways of dealing with non-compliance. Some of them might be more prone to take corrective actions, while others, of course, might escalate more easily to restrictive actions.
In addition, enforcement has proven hardly effective on certain actors selling to the EU but based outside of its borders. This, of course, resulted in an unlevel playing field where diligent businesses and innovative business models are penalized and struggle to be competitive. And on the other hand, ill-intentioned actors have no reason to be compliant as they can avoid the cost while continuing to make profit at the expenses, of course, of EU consumers, businesses and authorities. At this point, I would like to stress something quite important for us at Ecommerce Europe. E-commerce is by no means the root of the enforcement challenges.
If anything, e-commerce is exacerbating a more radical, existential shortcoming of the EU regulatory framework, that is its effective enactment beyond its borders. In fact, I can assure you that legitimate e-commerce players still exist. This can seem unnecessary to say, but given the widespread negative narrative around e-commerce these days, I think it's a good reminder. Good faith e-commerce companies, both European and not, invest in preventing and addressing the sales of non-compliant products. They continuously adapt their operations and policies to do so, not only to comply with rules and ensure consumer protection, but also more and more increasingly to distinguish themselves from rogue players.
And based on these introductory points, Ecommerce Europe has the following priorities for the upcoming EPA. The EPA must drive simplification in the area of product legislation. The EPA must tackle the level playing field issue and enhance enforcement. And finally, the EPA must empower non-traditional emerging business models. I will develop on these priorities in a minute, but first let me stress a cross-cutting objective: proceed with caution.
While the EPA should counter non-compliant operators and products, this should not come at a disproportionate cost for diligent companies operating in the EU. First, this means that the improvements considered under the EPA should not jump the gun. Rash measures can end up impacting the most accessible actors instead of the responsible ones. For example, placing product-related obligations on downstream operators who have no control on the products is unrealistic. Second, this means that increasingly more popular and new business models should not be hampered by the EPA.
Here I am referring to businesses allowing the trade of used and refurbished products, as well as live e-commerce. For these types of services, the regulatory framework is simply ill-adapted. Owing to this mismatch, such players can become unintentionally non-compliant. However, this kind of non-compliance should be clearly differentiated from deliberate and strategical non-compliance. But back to the priorities.
So to be a driver of simplification, the EPA should make it easier for e-commerce businesses to understand and implement their obligations under the EU rules. To enhance enforcement, the new rules should prioritize measures strengthening existing accountability chains. And here we recommend, for example, taking action around the role of the responsible economic operator or person. For example, businesses acting in this role should be accountable, reliable, and searchable. Moreover, any new measure set by the EPA must pass the so-called enforceability test, meaning that they should only be introduced if the competent authorities have the resources and operational capacities to enforce the new rules.
Finally, to enable circular and innovative business models, the EPA should avoid phasing in rigid one-size-fits-all legal requirements. So to conclude, Ecommerce Europe welcomes the EPA. We believe that this legal instrument has the potential to support legitimate e-commerce businesses in overcoming the challenges they've been facing in the last few years. If we proceed cautiously and think through the possible drawbacks and impacts of the rules on those that we want to protect, we are convinced that the EPA will be a successful tool. We look forward to a proposal which strikes the right balance between better enforcement and business empowerment.
Thank you very much for your attention.
Anna Cavazzini
Thank you so much for representing Ecommerce Europe's insights here, very important stakeholder of course. We come now to Ms. Andrea Gulacsi, Director of Policy and External Affairs at CEN-CENELEC, standardization of course. And as we said at the beginning, standardization of course are also the backbone of the internal market, so very important to have also your view.
Andrea Gulacsi
Thank you very much, Chair, and honorable members of the IMCO Committee. Thank you for having us and CEN-CENELEC here. I think you already stole one of my quotes, that standards are the backbone of Europe. I do have some slides which I think should show on the screen as well. So I realize I am the only one using slides, but maybe this focuses a bit the attention.
I think our central message here today is really that Europe needs a very robust and strong European public-private partnership for standardization. And we do very much look forward to working with you, with the members of Parliament, with the member states, with the European Commission to deliver on this ambition. I think this hearing is super timely of where Europe is in the geopolitical frame. And I hope that with this debate we will move forward on some things that we need to improve and of course on some things that we need to safeguard. My, I know the committee is familiar with who CEN and CENELEC are.
So we are a membership-driven organizations. We are two of the three recognized European standardization organizations in Europe. We work through our 34 members in Europe. And you see as well, it's a very complex and very wide system in Europe. So we do bring together over 90,000 experts that work across a range of different technical committees, from safety of toys to machinery to pressure equipment to the DPP that was mentioned, AI, etc.
So it is a very, very large system, the backbone of our European economy. And this is something that we of course want to safeguard. We understand there's improvement needed, but we are also calling for an evolution, not a revolution of the system. The international aspect was mentioned a lot.
Of course, Europe needs to be strong internationally. CEN and CENELEC have agreements at the international level with ISO and IEC. And in practice, you see that Europeans lead over half of the work at the international level. So that is a very strong asset of our system that we need to build on, that we need to align on and make use of. So I think that is definitely one of the critical aspects that we want to be recognized and kept in the future standardization regulation.
The one standard or the asset, the backbone of the standardization system is that once we adopt a European standard in Europe, all our members, all 34 members have the obligation to adopt it as a national standard. So that creates an incredibly strong and powerful network for our internal market and for the consumers. So we are talking about a full harmonization through standardization of the European market, which facilitates trade, facilitates, of course, industry's competitiveness. And I think that is something that the European standards organization bring to the table and something that we want to safeguard as well in the future standardization regulation. The critical aspects, of course, of the new standardization regulation that the European Commission outline are something that we stand fully behind.
You see here as well speed and flexibility, inclusiveness, working with SMEs, with consumers, with civil society. Access and legal certainty to standards is something that we are already putting in place. So we are providing that access, read-only access to standards, international alignment, so positioning Europe internationally. So in that sense, we're fully aligned and we're already taking action to improve the system, build on these objectives of the new standardization regulation. There are, however, some safeguards that we are asking European Parliament to pay attention to.
And there are the critical points that we want to raise here today and then also look forward to engaging with you as well when we're entering the assessment and the amendments for the new standardization regulation is a balanced oversight, so keep a co-legislative procedure where the Parliament and the Council has a role to play. We want to have access with safeguards, access to read-only standards while preserving the copyright and the intellectual property rights of standardization and the standards organization. A coherent system, so we want to make sure, and I think that was mentioned earlier as well by Gotink as well, we want a coherent system for standardization and we want an expert-led, voluntary, market-driven standardization. The market knows where the market needs standards, so let's not over-bureaucratize and increase costs around the standardization system. If you allow me, I'll go a bit in detail on each one of these four points, so we have food for thought.
I'll be very quick. I see I have three minutes left, four points, so let's try. The balanced oversight of the European standards organizations, any changes that the new standardization regulation proposes to the recognition of the European standards regulation, we require that it should be a delegating act and that the European Parliament and the Council have a role to play. And that is one of the changes we will be proposing to the Parliament as well. With regards to access, we are requesting that there access to standards is read-only, so not printable or downloadable access, which is no longer in the new standardization regulation.
them to continue to deliver the strategic autonomy that we're looking for for the European Union. With regards to the coherent European standardization system, it was mentioned earlier by Gotink, this proliferation of different standards, a lot of different standards, having delegated standardization organizations in the new standardization regulation alongside European standardization organizations will create a fragmentation of the market, will not help SMEs and civil society to know where to go, will increase costs. So the proposal we're making is that if we're working with other standardization organizations, this should be transferred through the European standardization hub of CEN and CENELEC that we're proposing, so that we have a coherent system and we don't fragment the market of standardization. And the last point is that standards are shaped by expertise and need. We want to make any restrictions and derogations to participation, to transparency, to international alignment to be exceptional and justified, so that we, as I mentioned at the very beginning, we evolve the system, we don't revolutionize the system.
We want to preserve copyright and intellectual property.
We can implement changes and we are very much here to work together and make sure we deliver a solid new standardization regulation, which brings me to the end of my point. As you examine this new proposal, I know we have a long year ahead of us, we invite you to shape a reform that builds on the strengths that we already have, so we don't add unnecessary costs, we safeguard a trusted public-private partnership, we preserve the independence of the European standardization organization, and we keep standardization firmly connected to the European market and civil society needs. Thank you very much.
Anna Cavazzini
Thank you so much for presenting your view on the upcoming or on the already published standardization revision. We come now to Mr. Alexandre Tanay, Senior Public Affairs Manager at Back Market. Welcome.
Alexandre TANAY
Thank you very much. Good morning everyone, can you hear me well? Yeah. So I'm Public Affairs Manager for Back Market, so it's a French and European marketplace fully dedicated to refurbished products in 13 EU countries. I'm not going to come back on many aspects in regard to e-commerce and marketplaces.
It's true that there is a loophole, especially when products are imported directly from outside the EU because in that case consumers become the economic operator responsible of conformity, which is not possible. Just to mention that it's not the case in the refurbished sector because in refurbishment sector, it's European players based in Europe, or if they are not, you have a fulfillment service provider because it's impossible to directly import an electronic device that has been refurbished directly to a consumer. So we are not in that case. And in any case, I would like to attract the attention to one point. Whatever are the rules on marketplaces in the current European Product Act, the current policy options envisioned in the debate would simply make second-hand product sales impossible on marketplaces, but not only.
And that's the situation I want to highlight today. So first, I would have to thank Anna Cavazzini and the IMCO Committee to give refurbishment a seat at the table. It's a rising sector, a green industry by design that should be supported across the political spectrum because it brings economic strategic autonomy targets with environmental goals. We don't have manufacturers anymore in Europe, but we have refurbishers and repairers that could bring back added value and economic value from China and the US for smartphones, tablets, laptops, and you reduce carbon emissions and you reduce the need of raw materials when you extend product lifespan. So it's a winning situation in every aspect.
But I'm talking to you with serious concerns today because the policy options envisioned in the European Product Act are not adapted at all to the refurbishment sector. And that was one of the objectives, but currently, as drafted, as envisioned, it would go against its objective. The industry is facing two major issues currently in Europe. First one, we have a shortage in supply, meaning that refurbishers are struggling finding used products to refurbish them. Why?
Because we have a waste management system based on recycling first and not reuse first. Consumers keep their products in drawers and recyclers attract products instead of reusing them. And so in that situation, refurbishers, in order to scale and to fulfill demand, they have no other choice than importing used products coming from mainly the United States and Japan. Used products that are exactly the same or equivalent to the ones sold and placed on the market in the EU market. And we're not talking about unique and strange products.
We're talking about main global consumers' IT products such as iPhones, Samsung Galaxy, laptops, tablets that are sold in the same way in the US, Japan, and EU. So the sector partly relies on these imports to refurbish them in Europe and give them a new life, a second life in Europe, with still environmental and economic benefits, even if it's not the best situation. Second issue that is quite related to this first one, this supply is legally at risk. Not only the EU supply, but imported supply. Why?
Because it was already mentioned by Reuse before, the new legislative framework is not adapted to second-hand goods and was designed for new products, meaning that when a product enters into the EU market, it should comply with current product requirements at the time of import, which is impossible for a used product, even if this product complied with EU requirements when it was sold in the US or in Japan when it was new, which is mostly the case in our sector. So that's the first one. And second point, the new legislative framework considers that only the manufacturer could provide conformity assessment and provide conformity documentation. You can't ask a refurbisher when he imports a used device to provide the full technical documentation because he did not manufacture the product. So that's the second issue.
And more generally, even for EU products, we had issues in regards to distributors' obligations. So that's the situation and that's what we've been raising since three years because it's urgent. We navigate in a gray zone. The sector is not fully compliant, let's be honest, but not because it doesn't want to be compliant, because rules are not adapted to second-hand. That's the situation.
Tanay ALEXANDRE
And we had a lot of hope in this European Product Act, but what we've seen in current policy options would worsen the situation. It explicitly states that used products' imports would be not allowed or nearly impossible, so keeping the current rules, which would be dramatic for the sector and would lower the access for consumers to refurbished products. So that's the first point. It's as if you ask an iPhone 13 to be an iPhone 16. It's impossible in its state.
So we've been proposing a framework, obligations and requirements that would fit second-hand while achieving and keeping safety requirements for these products.
The idea is simple, is to make sure that refurbishers would be able to prove that the product, when it was first sold as new in a non-EU country, was compliant with EU requirements at the time of the first sale. So comparable to what happens when you collect a used device in Europe, the refurbisher doesn't make sure that it's compliant with the current regulation, but just would make sure that it was compliant with the regulation applying when the product was sold as new. We want the same situation for imported supply. It's a transitional pathway because in the long-term strategy, the EU refurbishment sector and Back Market wants to rely on local supply. But here again, we have an issue because the European Product Act wants condition compliance of EU refurbished supply to manufacturers' guidelines, which is impossible because refurbishers are independent.
It's giving the key to your opponents in that way. I will stop here, I would be pleased to go further, deeper in our recommendations, but thank you for your attention.
Anna Cavazzini
Yeah, thank you so much for also giving these very practical examples of what we want to achieve and then it's probably counterproductive some of the things that are in the pipeline for the goals, but we have to then be really careful how to draft the law. Last but not least, I give the floor to and I welcome Mr. Ulrich Adam, Director General from Orgalim. Welcome.
Ulrich Adam
Thank you so much, Chair, and good morning everyone. Very pleased to represent Orgalim here. Orgalim represents a large manufacturing ecosystem: mechanical engineering, machinery, electrical engineering, electronics, ICT, and metal technology. Together, that's 2.7 trillion of aggregate turnover in Europe, 770,000 companies, one-third of all European goods exports. So a highly competitive, tech-innovative industrial ecosystem and a slightly different perspective to some of the things that have been presented so far this morning.
While we've talked a lot about the challenges in e-commerce and consumer goods, the Orgalim ecosystem is predominantly a business-to-business market, and our perspective on the European Product Act is that the Product Act needs to reflect the business-to-business realities, the perspectives, and make it work for our products in particular. The other element that Orgalim is not one single sector, one single technology, our members manufacture everything from industrial robots, machine tools, electrical equipment, sensors, digital technologies. So we really, our perspective on the EPA is one that comes with a really high sensitivity for the coherence and alignment between the horizontal rules and the sector-specific legislation. With that, I would like to share five points on the European Product Act, what we want to see, things that we believe are important to take forward, and I think it matches quite well with what we're hearing the Commission will present soon. Point one is don't change what works well.
I think not everything needs to be rediscussed. The NLF is a very great success story also for our industries, and lots of its core elements are still working well. So again, some mentioned evolution, not revolution, it's a perspective we share as well. The second point really is about the coherence and alignment. We need to future-proof the framework against unnecessary deviation and unrealistic timelines.
For that, we would call for an EPA coherence check for future product legislation to ensure that the EPA principles and requirements that any deviation to be properly justified. We would also call for a plausibility check for transition periods, recognizing that time is needed to develop standards, implement them, and carry out conformity assessments.
Third point, we really welcome the idea of the digital product passport. Again, this is a great invention that we fully support. We believe this is a very helpful tool for compliance and enforcement also in the B2B market. We believe we need a proportionate approach here. So we need an approach that takes into account implementation costs and complexities with the desired benefits.
And of course, there's some concerns, but we need to make sure that in no circumstances the DPP goes too deep or requires any disclosure of technical documentation, including IP rights obligations in that part of the DPP. For market surveillance, really, really important. We talk mostly market surveillance for consumer products, but again, it's highly important for professional products as well. The EU cannot, you know, drive up the rulebook if it cannot enforce it. And here we call for a much stronger focus in market surveillance also on business-to-business products.
So little to no resources, unfortunately, have been or are usually allocated to enforcing general non-compliance compared to the enforcement on safety requirements, meaning that our sectors, which are often the ones driving Europe's industrial competitiveness, suffer. We would like future market surveillance to recognize the business-to-business dimension more clearly and make sure that adequate resources are allocated to market surveillance across all product sectors and preserve effective channels through which industry can help authorities promote compliance. We are hopeful that again, the Commission will propose stronger cooperation and strengthen the cooperation between Member States and Union level. We are in favor of that. Responsibilities should be clearly defined so that they add value rather than duplicate national efforts.
Finally, we need to simplify what is unnecessarily complicated. Alignment and coherence again for us is the key point in ESPR to preserve the coherence between the horizontal and the sector-specific legislation. We understand the horizontal framework will be presented together with amendments to several specific sector-specific legislations. We are concerned that this will open the door, this could in the worst case open the door to inconsistencies between the horizontal framework and the amendments to individual legislative acts. So we need to keep a close eye on it.
I'm sure the Commission will do that in the proposal, but we also need to make sure that this is preserved when the proposal goes to Parliament and Council. So we have a concrete ask to the Parliament that, you know, the revision is an opportunity to tackle duplication and inconsistencies and overlaps. So we urge the Parliament to safeguard all of this and also by keeping the same negotiating team in place throughout the process. That would be very important. Finally, a word for us as well for standardization.
I would like to close with that. I think the definition of democracy is government, I think, for the people, of the people, by the people. I think standardization is very much common rules of the industry, for the industry, by the industry. And for us, this is absolutely strategically important in the Orgalim industries to make our complex and interconnected industrial ecosystem work. We understand and we share the view that there are challenges in the current standardization system with regards to speed, with regards to the whole system, the whole interaction between industry, CEN-CENELEC, the national standardizers, the European Commission.
This is not something new. We've been discussing this for several years. But I think now is the moment, and great to see that the proposal came out last week, to really make this joint effort and step up the cooperation and use the revision of the regulation to make things work for us again as huge exporters. As was mentioned by Andrea, the international first principle is absolutely key.
It's great that ISO IEC connection with CEN-CENELEC through the respective agreements is a real strength of the CEN-CENELEC system that we need to guard, and there should be no departures from this principle. Again, we are happy to work together to make this a success. Make sure that also I think there's a proper burden sharing in the expectations and the obligations for all the four main actors I think in the system. So we support the speeding up of the standardization system, but I think the KPIs and the measurable targets to deliver this must be applied consistently not only to the ESOs, the European standardizers, but also in case that happens to other standardization organizations. We also believe again that the CEN-CENELEC system, the established system, is the way to strengthen.
We understand that the Commission or the EU wants to preserve a slight optionality here in terms of another road to take in case the European standardization system by default cannot deliver. But again, I think we agree the hurdles for that should be high. This should not be a road taken too easily, let alone for the development of common specifications, which probably are not quite the definition of the common rules of industry by industry for industry as we see it in the CEN-CENELEC system. We look forward working with the Parliament on the issues moving forward. Thanks.
Anna Cavazzini
Great. Thank you so much to bring in also Orgalim's perspective on the different parts of the Product Act. And now we have again the opportunity to ask questions or come in as members. And I can just look around. Laura.
Laura Ballarín Cereza
Thank you. Thank you so much to the speakers. Thank you for this very interesting presentation. I would like to put two questions to Margherita Corrado from Ecommerce Europe. So your members include EU retailers that comply with the rules while non-EU sellers on marketplaces often do not do.
What would a level playing field look like and what responsibility should marketplaces carry? And also would you support making platforms legally liable for products sold by third-party sellers when they fail to verify the sellers on the product's compliance? If not, what alternative would make enforcement effective? And also to Mrs. Alexandra Tannai, as a marketplace for refurbished products, how do you carry out compliance and quality checks on sellers? Which of those practice could reasonably become a legal obligation for all online marketplaces?
Thank you.
Anna Cavazzini
Thank you so much. Elisabeth? Or you don't want to come in? Elisabeth? No?
Okay. Then probably I can come in with a question again on the standardization because I mean the speed was mentioned now by several of you as a problem. But probably you can elaborate a little bit more what is actually now the problem with the speed. So why does it take sometimes so long? And for example, the whole question now we had also the AI Omnibus here because the standards of the AI were not ready.
What is exactly the problem and how can we solve it if not via, you know, having the Commission taking over, which is what you guys not want? So how can we solve it because it's indeed a problem and I just want to understand where exactly the problem lies and how can we mitigate it? And then I would also just to understand a little bit better this access question. So what is exactly the advantage if it's a readable and not a downloadable solution, just to explain what the difference is because for me it's probably not so much a difference, but I want to understand why is this better for you or what is exactly behind? Yeah, these were my questions.
Thank you so much.
Alex, you don't want to come in? So no more MEP questions. Probably you can just, we have a second round of quick replies. Probably in the same order, we start with Margherita.
Margherita Cossaro
Yes, thank you very much, MEP Theresa Ballerin, for the question.
First of all, with regards to responsibilities of online marketplaces, well, I have to say that there are quite a lot of responsibilities online marketplaces already have and have been acquiring in the last few years. Some of them are still not completely... have not completely entered into force. So we're talking about a lot of new obligations, due diligence obligations that online marketplaces have to take on already. So much so that sometimes we really need to, let's say, list all of them and make sure that they're already coherent with each other. So yes, I think there's... the EPA is also... gives also a chance to basically go and fetch what the DSA, for example, already says about what the online marketplaces have to do.
But that's just one example. Then we can also speak about EPR, for example. That's an area where online marketplaces have been receiving and acquiring a lot of new obligations lately. So for us, let's say, the online marketplaces already have things to do. Some of them, indeed, we believe the issue there is not that they don't have responsibilities or responsibilities do not exist under EU law.
It's that, well, they're not, as I was saying, they're not incentivized to basically comply with them because enforcement is lacking. So again, for us, that's the biggest gap that we see today. And with regards to your question on liability, we, as I was saying, giving liability to whatever kind of actor that has no control... so we're talking here about product-related obligations... I don't think it's a fair or even, you know, a workable obligation then to give liability to someone that actually has no clue about whatever product lies behind an offer for a product that they have posted on their own platform. So I believe that... and so sorry, I see that the time is running, but I believe that the EPA also gives us a chance to, well, strengthen maybe the due diligence obligations that online marketplaces have, might have, with regards to product offers, because that's what we're talking about, not products. So yes, we'll be very happy to continue the discussion in that area, in that field.
Andrea Gulacsi
Thank you very much, MEP Cavazzini. Thank you, Chair. I'll start with the question of speed, and I think in that sense, what Orgalim mentioned as well, I think the new standardization regulation brings forward a very strong proposal on how to address that, and that's where we look forward to work with the Commission together. I think there are some practical and very concrete implications for speed. One is the sooner we can align strategically before a standardization request is issued, so the sooner this dialogue starts with policymakers, the sooner we can anticipate and produce standards.
And then on the very practical standardization work, this by industry, by civil society, by SMEs, for SMEs, consensus takes sometimes time, as you very well know as well. I think it's our European value, no? So that also impacts sometimes the speed, but that doesn't mean that there isn't a reform to be done on how standards are developed, and the Commission is bringing forward those proposals, both on the Commission side and on the European standards organizations. And that's something we do need to take into account. Equally, proliferating and having other standards development organization will not necessarily reduce that time issue, because that means establishing another platform, bringing experts together in another forum, so that will also add unnecessary time, in our view, to that.
So let's improve what we can on the speed because we realize standards need to be quick on the market. There are things in place that we're doing, but equally consensus sometimes takes time. So that's I think on the speed side. With regards to the downloadable, the copyright, of course there's some very particular legal issues with this. The concern the standardization community has is downloading a document means it's an uncontrollable version, it can be shared, it can be copied, it can be changed and that will really impact the safety aspect of standards that are captured in this document.
We don't know how the use of the document will be done by whoever downloads it and starts circulating it. Equally it's a question of trust and having one single source of trust if we have a read-only access to standards. So I think that's a very practical and I think a very coherent approach to copyright in Europe. Thank you.
Ulrich Adam
I think just adding to what Andreas said, I think there's some low-hanging fruit in the speed question, especially at the beginning of standardization and at the end and they have been, so you have been jumping the gun, but it's answering directly to CEN-CENELEC. So the low-hanging fruit is in I think in the request process and clearing that fast and having the early alignment and also in the late stage of the citation we've lost I think time. It's a relay race I think as well that we make sure, you know, when is the Commission holding the baton, when is it CEN-CENELEC? And then the hard, more difficult one is in the middle I think in the elaboration of the standard in the TCs and the consensus-based one and there I think we need to get our heads together, CEN-CENELEC, the industry and and the involved parties to to try to speed that up. But again, the CEN-CENELEC system is probably the best place as Andreas said because the expertise is there.
I think the alternatives wouldn't strike me as the natural place to deliver things faster.
Anna Cavazzini
And that was all you wanted to say anyhow? Because now we changed, no problem. Now Alexandre.
Alexandre TANAY
Thank you. So answering to Ballarín Cereza on quality and compliance checks for seller on refurbished products on Back Market. I think there are there are two questions in your question, first on quality for refurbished products and then on compliance and I would answer in this order. On quality of refurbished device on Back Market, we have two kinds of controls because of course quality is key in the sector. So consumer trust, if you don't have a qualitative product, consumer won't come back on refurbished products and would still buy new products.
So it's one key strategic pillar of the sector of Back Market. So first, when a seller comes in the platform, of course we have a many KYB checks to make sure that it's a legal entity, it has operations, etc. And then in the first weeks, we narrow and limit number of sales to the very minimum and we check, we do mystery orders, we check with the seller if if quality is there and match our guidelines because we have very strict guidelines. Then if it's okay, the seller can sell as many refurbished products as he can. But after that, even after that we do random checks to make sure that the what we call the defective rate, meaning on 100 refurbished products, what on how many products would have an issue, it could be a qualitative issue but also delivery issue etc.
And if there is a threshold that is overdue, we monitor and we see with the seller what happens.
But I think that's something that could be done only on dedicated marketplaces in one specific sector which is our case. Then your second question about how do we check compliance of products. First, as I said, we are not ensuring sales of products directly imported from outside the EU meaning that we are working with European sellers. So they are European companies having the responsibility of the product. Enfin some of them are in the room behind, they have plans, they have a legal team, they they weigh the product responsibility so they're here.
It's not it's not the case in some sectors, it's but here it's it's not the case. And then about compliance of second-hand products in general, what do you refer to because as I said, we don't have a compliance pathway for second-hand products. Does it mean that we need to check that a second-hand product has all the technical compliance? It's not possible today. It's not possible because they're not the manufacturer.
So what do we need to check in that case? That's why we urgently need to revise these rules and this question is the same whatever the product is sold on a marketplace, a physical store, a distribution channel by the classic distributor, a retailer. Thank you.
Anna Cavazzini
Thank you so much. I think it was really interesting. We had some very interesting points to also discuss and there sure will come back when we see at the end the Commission proposal and of course anyhow the standardization reform is already out, we also have a process already started here in the committee. But thanks so much. I think it's very, very helpful, super interesting to have all of your different inputs that will definitely inform our work.
So this concludes an excellent panel, an excellent public hearing and I want to thank all of you again. This concludes agenda item seven and of course probably we do one minute technical break, I say goodbye to you and then we start with the next item agenda eight. Okay dear colleagues, because we are a little bit running late, we directly continue. And if you have discussions, bilateral ones, probably you can do them outside. Thank you so much.
So now we continue with agenda item eight, that's our scrutiny session on the implementation of the customs reform. We want to have a little bit more insights on the Commission planning on the three euro temporary customs duty that is applied since 1st of July 26. And we also want to discuss, colleagues, if you have bilateral discussions, please do them outside because we have to continue our committee agenda. I think it's great that the Product Act is causing so much excitement but you can probably do it outside of the room. Thanks.
And we also have a delegated act, a delegated act that is also now in the process here in the European Parliament on an handling fee that will be applied as of 1st of November. So I am very happy that we have DG TAXUD here to present the actual plans. And the name is also on a different... Ah yeah, Vanessa of course. Hi, Vanessa Hernandez Guerrero, Head of Unit for Customs Legislation, DG TAXUD.
Welcome.
Vanessa Hernandez Guerrero
Thank you very much. Thank you, Chair, and thank you to this Parliament for the continued support to the customs reform that is now a reality. I have the impression I ruined a bit the party for the European Product Act. Just wanted to give you an update on two of the measures that are part of the customs reform and are directly linked to e-commerce. One of them is the imposition of the three euro customs duty.
The second one is the upcoming Union handling fee. The three euro is imposed on every parcel that comes to the Union and it's directly sent from a third country to a consumer. So it's very much part of the phenomenon that you were discussing before in the previous agenda point. The three euro duty applies from July 2026 and the Commission is meant to monitor the effect. We have data of the first two months, so July and August, and today, 15th of October, we should be getting the data for September, but I don't have the analysis yet.
And what we see is that the flow of goods, that means the parcels that are being sent directly to consumers from third countries, have decreased between 40 and 60 percent, depending on the comparison that we take. What does this mean? It does not necessarily mean that there are less sales. It means that they are not directly sent from the third countries. So it may happen that the same goods are being imported in big quantities and distributed from the EU to the consumers.
That means that all the rest of legal acts that do not only apply at the border but they apply in the internal market, they also need to consider this aspect, that even if these are goods manufactured in third countries, the Union surveillance should not stop at the border. There is a lot of work to do even when the goods are stored in the EU. So this is what we have observed so far, that having imposed three euro duty per item has an impact in the flow, but we do not know to what extent the flow has stopped or has simply changed model. Then we have the Union handling fee. The Union handling fee is not a duty.
It's to compensate the cost that the customs authorities must incur in order to provide the supervision services. The Union handling fee was established in the new Union Customs Code and then the amount established by the Commission in a delegated act. I understand that you have until the 21st of October to accept or refuse that delegated act that establishes the fee at two euro. The two euro are in addition to the three, so it means that every item sent to a Union consumer directly from a third country will be subject to five euro charges from the 1st of November 2026. Just to conclude, the fee is commensurate to the cost and the Commission has done an analysis of the cost that are included in the... that the customs authorities need to deal with.
The cost are the digital cost, I mean the digital systems both by the Member States and the Commission.
Then the human resources, that is the customs officials that are needed to control these these goods. The the equipment that is also being used in the in the control of these parcels and there we have only considered the Union financing, which is only a part of it. We have also included which would be the cost of increasing controls on these parcels and in essence we do have approximately five billion cost per year. With a quick calculation divided by the number of items that are expected, we come to this number to the two euro handling fee. We therefore in Commission opinion this amount is commensurate as the the Union Customs Code requires and therefore if the objection period runs without any objection by Council and Parliament from the first of November 2026 this handling fee would be applied on these parcels.
Thank you very much.
Anna Cavazzini
Thank you so much. We now have time for questions and answers and we start with Dirk.
Dirk Gotink
Thank you very much. This is a great combination because of course because of the Council traffic I missed the opening of the session today and there there was a feedback from the first working group on the on on customs but that was about this. So in that sense I can I can combine it. I think this is well this is obviously the first and most visible effect of the UCC reform. It is having an immediate and significant impact on trade flows.
The customs that we talk to confirm that and they see it in that the physical flows are really significantly down. We're talking about less than 46 percent 46 percent less in the Netherlands but an average I would say 30 40 percent. That means that only the three euros kills a toxic business model that is only profitable only profitable if it if you can trade tax free not respecting any kind of labor laws over there where they are produced and not respecting any kind of environmental rules and then getting into the European market without any controls. That's the only way those products are profitable. It's a bit like high frequency trading but then with physical products rather than with financial products.
So I think it's a great progress for the market for the health of our internal market that we are killing this toxic business model. The second problem that we wanted to achieve with this is that we cover the cost of increased controls because we've been cutting costs on customs and market surveillance for decades. And looking at the money that is coming in now the IMCO committee is adding six billion euros per year to the European budget. So we expect the Commissioner for budget to send us a thank you letter at least.
And some flowers for Laura. But then I have a very critical point to say that then if I look at the single market and customs program for the next MFF, that's seven years, total is six billion. So we're collecting six billion per year and the single market and customs program, which is not only customs and it's not only market surveillance, gets the value of one year. That's not the right balance. And I think there's a real need to reinvest in our customs and single market.
We talked about the Product Act. If we want the Product Act to work, we're going to have to invest in our market surveillance infrastructure. It's not going to function by itself. And we know how difficult the member states' budgets are. And a part of this money will have to go there instead of paying for the pensions of our dear EU staffers, which is what a lot of the money will be used for.
And there I think it is a critical, but not for Vanessa from the DG TAXUD side, but we need to push for bigger budget on that. On the two euros, I also think it's good we start with that because I know there was a push also to do more, to go higher, especially to get down the national contributions to the budget. So well done to the Commission that they have proposed this. And I think it will make our trade in Europe a lot healthier and it will also create the level, a bit more of a level playing field for a lot of our traders, which they've been looking for for a very long time because we need to support the good business and not the bad business, and that's what we're doing with these proposals.
Alex Agius Saliba
I will be speaking in Maltese since we have translation today. Jien ġej minn wieħed mill-iżgħar stati membri, Malta, pajjiż li jiddependi ħafna, speċjalment fejn jidħlu l-konsumaturi, jiddependu ħafna inkella meta wieħed jara dak li jinxtara fuq bażi offline mill-ħwienet tradizzjonali u dak li jiġi impurtat. Allura s-suq tagħna minħabba ċ-ċokon tagħna u li aħna m'aħniex parti mill-mainland Ewropea, ovvjament il-konsumaturi jagħżlu, speċjalment l-aktar konsumaturi vulnerabbli jagħżlu li jordnaw il-prodotti tagħhom minn barra mill-pajjiż u ħafna drabi, u kien hemm proporzjon tajjeb ħafna, kbir ħafna minnhom ukoll minn pjattaformi ukoll barra mill-Unjoni Ewropea. U din it-taxxa u l-handling fee għalija, għax kulħadd qed jitkellem fuq din it-taxxa mil-lat ta' protezzjoni tal-business Ewropea, u tajjeb li wieħed jipproteġi lill-industriji Ewropej, imma ħadd mhu qed jara din il-problema li ħolqot il-Kummissjoni Ewropea li qed tgħabbi lill-aktar konsumaturi vulnerabbli li dawn ovvjament huma sensittivi għall-prezz ukoll, li dawn spiċċaw u jgħiduli u fhemuni u l-Kummissjoni Ewropea forsi tfehmna daqsxejn għaliex jien għadni assolutament ma nistax nifhem liema taxxa fid-dinja hija proporzjonata meta inti tixtri oġġett ta' ewro u tħallas erba' ewro u tħallas ħames ewro issa bil-handling fee żejda f'taxxa bejn handling fee u t-taxxa li qed tiġi imposta. Allura tixtri oġġett ta' ewro u tħallas sitt ewro.
M'hemm l-ebda tip ta' proporzjonalità f'din it-taxxa inġusta li qed nerġa' ngħid qed tkisser l-aktar lill-aktar konsumaturi vulnerabbli li xorta dawk jixtru minn dawn il-pjattaformi. U jien immeraviljajt lili nnifsi, nibgħat ittra lill-Viċi President tal-Kummissjoni Ewropea Maroš Šefčovič rigward dan il-piż li l-konsumaturi Ewropej, speċjalment konsumaturi li ġejjin mill-gżejjer qed ikollhom iħallsu, u r-risposta tkun li din it-taxxa mhux qed titħallas min-nies, mhux qed titħallas mill-konsumaturi.
Mela min qed iħallasha din it-taxxa? Din hija taxxa ġdida li f'sitwazzjoni fejn għandna problemi u sfidi ekonomiċi u soċjali mifruxa fuq bażi Ewropea, din hija taxxa li mhux qed tweġġa' lill-kbir, lil min jiflaħ u jaffordja li jixtri l-prodotti tiegħu bi prezz aktar għoli. Qed taffettwa lil dawk il-konsumaturi li huma sensittivi għall-prezz u fl-aħħar mill-aħħar jagħmlu x-xirjiet tagħhom minn fuq dawn il-pjattaformi. Jiena m'għandi l-ebda problema li jkun hemm, u din hija kwistjoni oħra, dawk it-tliet ewro u aktar minn tliet ewro għax hemm, jiġifieri ma' kull prodott li tixtri għandek tliet ewro u tmienja u erbgħin ċenteżmu extra. Jiġifieri anka din l-issue ta' tliet ewro hija aktar minn tliet ewro dak li qed iħallsu l-konsumaturi.
Imma l-ewwel mistoqsija, jiena jekk ikollok handling fee u suppost din tintuża sabiex naraw li s-saħħa, is-sigurtà, il-kwalità tal-prodott ikun hemm aktar riżorsi fejn jidħlu l-istati membri, speċjalment l-awtoritajiet tal-customs sabiex naraw li l-prodotti jkunu abbażi tar-regolamentazzjoni Ewropea, emmek m'għandi l-ebda problema li inti jkollok investiment dirett fil-customs authorities ta' kull stat membru sabiex naraw li dak li dieħel fl-Ewropa jkun abbażi tar-regolamenti tagħna. Imma din it-tliet ewro u nofs fejn qed tmur? Qed tmur sabiex naraw li nsaħħu l-awtoritajiet fuq bażi lokali biex naraw li l-prodotti jkunu abbażi tar-regolamentazzjoni Ewropea li jipproteġu s-saħħa u s-sigurtà u l-kwalità tal-prodott li jidħol għand il-konsumaturi, jew qed immorru sabiex jiffinanzjaw ambizzjonijiet oħra li għandha l-Unjoni Ewropea? U nerġa' ngħid, once I fit-sol fejn tidħol din il-kwistjoni mhijiex is-soluzzjoni, speċjalment meta dawn il-pjattaformi bħal Temu, bħal Shein b'mod partikolari, jiena għamilt eżerċizzju wieħed fejn rajna sitwazzjonijiet fejn inti jkollok warehousing fi stat membru u emmek dawn qed iduru madwar ir-regoli li qed nagħmlu għax din inċapċpu ħafna li għamilna xi ħaġa kbira. U meta inti għandek warehousing fl-Ewropa Ċentrali, emmek il-prezzijiet qed ivarjaw mill-prezzijiet pereżempju li l-konsumaturi Maltin qed iħallsu għaliex ovvjament aħna gżira u hemm il-flus addizzjonali li l-konsumaturi Maltin qed iħallsu minħabba t-trasport.
U allura nerġa' ngħid din hija taxxa inġusta li qed tikkisser liż-żgħir u li qed tikkisser l-aktar lil dawk il-konsumaturi li ġejjin mill-gżejjer. Grazzi ħafna.
Anna Cavazzini
So, thank you so much. Probably just for me a direct reply. I mean, I'm very happy that you know the customs reform had such a overarching support in plenary in the Parliament and the whole Parliament, except some few exceptions, supported it. And I can understand that the Maltese problem is a very specific problem, but of course also it doesn't hold to imports from other European countries. You can have still e-commerce from other European countries and then you don't have the fee.
No, and then you don't have the fee because I mean what Dirk said I can completely agree. You know, if we import on a large scale non-compliant, damage, dangerous products from third countries, I think we should definitely not incentivize this.
So I'm a big fan of the of the fee. And I just wanted to stress one fact that we had actually in the working group, that I think we still need also the reporting back from Dirk actually, the question still on consumers. So can we basically, can the Commission ensure or work on the fact that some platforms illegally mention this fee on their prices? Because I think this looks really bad for consumers and we learned also that legally companies are not allowed to do that. So probably you can say something because then we can probably also avoid some of the, you know, confusion that some consumers are feeling not heard or whatever.
So probably you can answer to that. Anybody else? No. Then I give the floor back to the Commission.
Vanessa Hernandez Guerrero
Thank you very much. So yes, I perfectly understand that the consumers in smaller Member States and that have face higher transport costs feel this, they feel a more significant impact. It is important to to remember, yes, that the legal debtor it's not the consumer. It is either the platform or the seller and in a few cases the carrier. But of course it's a business cost that the platforms can decide to pass on to the consumer.
The reason why it is thought that this model requires a compensation to the customs authorities in the form of a fee is because it's much more expensive to supervise the parcels one by one and very inefficient than if they are stored in the EU. So you make reference to the warehouse and this is indeed the model that in general in the customs reform it is incentivized. Why? Because the market surveillance authorities, the customs authorities, they will supervise a huge amount of the same goods. If something is not compliant, it can be moved off the market immediately.
And the transport costs to a central warehouse in the Union are part of the business expenses. Then of course from the warehouse to the where the consumer is located is an additional cost. But we we favor a model of storage in the EU because we think it's much easier to control and to ensure the safety of the consumer and the compliance and the level playing field. So I think that what we are trying to do with the three euro and the two euro of the handling fee is to signal to consumers, well, it's not normal that you order something of eighty cents and it's directly sent to you from China. This it's not environmentally logical.
It's not logical that it did not have a tax and it pushed away European businesses that were dealing with distribution. The one of the previous speakers said we don't have manufacturers anymore in the EU. I don't know whether that's true, but even if that's the case, what we do have is distributors that care about the compliance of the goods and that can send the goods to the consumer. So I understand that there is a transition phase in which the consumers were used, they very quickly got used to these very cheap items. But I think that the platforms are adapting.
I want to believe that also in terms of compliance with the product regulation they are making an effort. And therefore we will see how this comes back to a to a situation in which the consumers have access to the same goods, but they are just logistically distributed differently from the EU where the Union customs authorities, customs and market surveillance authorities can control them in an easier and more efficient way. So I think that's that's really the goal behind. You were asking also where the revenue goes. Actually the VAT is this forty cents and this is national.
For the three euro it's Union resources. It means that seventy-five percent goes to the Union budget and then this goes back for the customs reform to a certain extent and twenty-five percent is for the Member States' budget.
So this is in essence it. Thank you.
Anna Cavazzini
Thank you so much for being here and also for addressing our questions. I think it's always important and we try to do more of them that we do scrutiny sessions in the IMCO committee to check where our legislation is going and of course we will repeat this again. And now as I mentioned we also have this new working group that is observing actually the implementation of the Union Customs Code reform. So thanks so much. This concludes agenda item eight and we come to our last agenda item for today, number nine, the discontinuation of digital products and services, issues at stake and possible solutions.
We will have a study presented and then an exchange of views on issues raised by the European Citizens' Initiative Stop Destroying Videogames where as you can remember we had actually a big hearing here in the committee with our colleagues from PETI and JURI and also we had a plenary debate where MEPs also spoke out and presented a lot of support to the European Citizens' Initiative because it also very well fills in in our work on the right to repair, on sustainable products, on long-liberty of products. So but of course we also learned from the Commission at the end it's also very difficult to implement but we are very happy that we have a study here today. I welcome Professor Teresa Rodriguez de las Heras Ballell who served as an external legal expert. She's a highly distinguished academic in the fields of commercial, international, private and consumer law and she's a full professor of commercial law at the Universidad Carlos III de Madrid and the current president of the European Law Institute. So we have the presentation of the study and then afterwards of course like usually the members can ask questions.
So the floor is yours. Welcome. Hi.
Vaida Gineikytė-Kanclerė
Good morning everyone. My name is also Vaida Nikitaitė-Kanslerė and I led the study in the part of Visionary Analytics so I will start the presentation but Teresa will join in. Thank you so much. Pleasure to be here and to present this to you today. I think we can start and move to the next slide.
Okay, so the problem for the study is summarized in the statement that for most consumer history a product kept working whatever happened to its maker. If you bought something you owned it but cloud services, software as a service, tethered products, connected devices and games as a service have changed that because they stay tethered to the provider's servers, updates, licenses and accounts and their working life is set by the provider's decisions now, not by wear and tear. So digital products that are free of DRM, which is digital rights management, have become a rarity and increasingly so. So we don't get self-contained copies anymore. And what most consumers currently have and often without even realizing because they clicked on the buy button is conditional access which can be very easily withdrawn.
So this withdrawal which we refer to here as discontinuation of digital products and services is now a structural feature of digital markets and its exposure is near universal as some of the figures on the slide help to illustrate. If we can move, thank you. For this study the committee asked when and how digital products are discontinued, what does that do to competition, innovation and consumers, how well the EU law protects consumers and what should be done about it.
So many aspects of these questions are quite novel and there have not been much systematized knowledge about it. We answered this with four streams of evidence. So first literature review, then a analysis of 83 purposefully selected documented cases of discontinuation that happened in the past 10 years or so. Then a stress test of EU consumer law against the contractual forms that digital products and services might come with, as well as interviews with 16 stakeholders. So the cases were selected purposefully to cover every mechanism that we saw in the public trackers of discontinuation, including well-managed shutdowns just to see how that takes place.
And the sample shows how the harms arise but not how often. So the study is qualitative in its nature but it's also empirics first. So we started from actual cases and built the analysis around them by classifying and conceptualizing. Now what we found. The 83 cases fall into five discontinuation scenarios.
And I must say here that this is a description of the sample that we worked in and not a statistic of the market landscape. But in our cases half of them were server-side shutdowns. So basically infrastructure behind the product goes offline and it's gone, as was the case with the most notable games that were the reason behind this citizens' initiative. A quarter of the cases that we analyzed were end-of-support cases. So the product runs on without security patches, without updates until it slowly dies.
Another type of discontinuing is bricking a device where a physical connected device dies with its cloud service and basically becomes a very non-eco-friendly and expensive ornament. The fourth scenario is where a developer platform shut down and the apps that built on it have to stop. I'm still on the previous slide, thank you. And in the fifth scenario of discontinuation was specific licenses are revoked while the broader platform itself carries on. And the fourth scenario here is specifically interesting because these look like disputes between businesses.
Discontinued products in these cases are for example a hosting service, a sign-in system, developer interface or cloud back-end that consumers never choose or never pay for, but consumer products are built on these layers. So when one is switched off, the failure cascades down to millions of end users and as we noted in the legal stress test with which Teresa will tell you about shortly, the liability here lies with the seller, which is not the optimal point in the value chain often. Then moving forward, why products are discontinued. We saw that seven causes recur in our cases and they fall into two broad groups. So the first group concerns the provider's own decision.
It can be a commercial failure where the product never reaches a critical mass. Those can be strategic pivots where a product itself is not failing but a producer decides to funnel its users to subscription model for example. And an acquisition where a bought product is simply closed. The other group of discontinuation cases is where the control is taken away from the provider. It can be insolvency, regulation or litigation, security incidents and force majeure for example a fire in a data center.
But most of the cases that we analyzed are voluntarily falling under the first group in which discontinuation is basically a commercial strategy. And the cause of discontinuation predicts the notice periods that consumers get to prepare for it. So planned exits gave usually one to three years, acquisitions 30 to 90 days and insolvencies of course none. Then we looked into the macroeconomic effects of these trends which are on the next slide please.
And here I think it's important to note that the study does not treat discontinuation as harmful in itself, because exits are how markets renew. But harms depend on whether retiring product returns its users to a contestable market, or if it funnels them into the market that the discontinuing firm controls. And where the second condition holds, switching costs and market power just grow, and locked-in users now pay twice: so first to migrate, and then again through higher prices. And dependent and second-hand markets then collapse, small firms usually bear the migration costs. And looking into the effects on innovation, in these situations cumulative innovation erodes when the base it builds on disappears, or is enclosed in the incumbent system.
And what we also see, at least in theory, that entry and investment then are deterred anywhere outside those incumbent ecosystems. And it's important here because what we see in the EU market specifically is that they often lack these conditions for a beneficial exit, because we know that very few EU firms can currently act as successors. So where users migrate is to the established and often non-EU platforms. And this is something that has broader implications, and some of them also link to the broader discussions of EU digital sovereignty and EU's competitiveness. And another important insight right here is that smooth migration, which is very convenient from the consumer point of view, can be even more damaging for competition than an abrupt shutdown.
Because when a firm makes moving to its own successor easy and moving to a competitor hard, then a moment when consumers can choose, they just smoothly move to the firm's own product, and often more expensive and often with even more lock-in. Then what consumers lose. Functionality and money in most cases, but these can often be at least partly recovered through refunds, substitutes or migration. Then data, safety and community are the rarer losses, in our sample of cases at least, but also the permanent ones. So no refund can rebuild the social graph that the user has built on a certain platform or deleted files.
And these harms stem from how products are built, not from consumers' misunderstanding what they bought. At the same time, consumers who click buy also do expect to keep the product, and they almost never learn the support horizon at the point of sale. And that expectation gap is where Teresa now takes over.
Teresa Rodriguez de las Heras
Thank you, Vaida. Good morning, thank you, Madam Chair, for the kind introduction, and good morning to the distinguished audience. We arrive now to the key question. So how the European law today protect consumer when discontinuation happens? And the primary finding of this study is very conclusive.
The European law today does not provide for a general duty on the trader to keep any digital service or product running. So what that means? Means that essentially that if there is reasonable notice in advance and the unused prepayments are refunded, that particular discontinuation scenario is lawful.
So this is the main statement. However, as you can see in the next slide, one of the most innovative contribution of this study, we believe that is this taxonomy, this typology of contract that has been developed around a functional approach. So what that means is designed around the idea that what are the expectation of the consumer and therefore what are going to be the real harm produced or provoked by the discontinuation. So taking that into account, I can nuance a little bit this general statement that I explained before. Because the key point here is that the level of protection that I mentioned before is quite low follows the contract, depend upon the specific contract.
So I would like to draw your attention to the slide. You can see the seven types of contract and then immediately you realize that in general, the protection received by the consumer is either weak or no protection at all or definitely partial. Only in two cases, that you can see the second and the third, we could say that the protection is strong, but even in those cases there are still gaps and deficiencies. There are still, for example, sunk investment that are not going to be recovered or may happen as well that the copy that the consumer has in its own device at the very end is not working properly or cannot be redownload again when is not according to the specific format. So there are still problems even in those cases where the protection is strong.
In other cases, if you can see the fourth and the two last, the protection is only partial. Why is that? Because essentially EU law is based on price-dependent remedies. When there is no price, it is outside of the scope or where the amount is very small, in most of the cases the enforcement is going to be not advisable at all. So we still have cases where the protection seems to be inadequate.
So, what is the proposal? If we go to the next slide, you see that our proposal is essentially not prohibit but regulate the exit. And that could be summarized around five key pillars. The first idea: instead of trying to prohibit discontinuation, that is completely unrealistic taking into account the market, probably is not advisable, this idea of continuity duties in general, the idea is let's regulate the exit. The second idea is let's regulate the exit basing on two level: a horizontal consumer law floor that is applicable cross-sector and only very specific sector-specific technical duties when is necessary, for example, in the video game sector.
The next idea is before legislating, probably now the key point is let's clarify the current legal framework, let's enforce the current legal framework in order to fill these gaps and only if it's not working well, let's legislate. How? Let's focus on those cases where the harm arising from the discontinuation or the shutdown is very severe, it is irreversible, or is out of the control of the seller. How can we do that? Next point: let's sequence this measure taking into account the current policy windows that are open.
And that gave me the opportunity to get to the next slide in order to conclude around three main ideas: how to do that and when to do that. There are essentially three policy options available that could be explored. The first one is not requiring any new legislation at all, is just to seize the opportunity of the fact that there are some code of conduct in the video game sector that could be used as the key point to start.
There are indeed updates on guidance and application of two other instruments that could be used. The next idea is definitely to take the opportunity of the Digital Fairness Act together with the review of the Sale of Goods Directive. And that could work very well for those recommendations that you can find in the middle of the slide among the 13 recommendations. And the last idea is let's close the circle using as well the liability component. And in particular because the PLD, the Product Liability Directive, is to be is going to be implemented in the coming weeks.
Let's use that implementation and transposition in the full extent as a mechanism to guarantee that the entire framework is completed. Vaida is going to complete the presentation with some final ideas.
Vaida Gineikytė-Kanclerė
Thank you so much. So if we could move to the final final slide, just the core messages to summarize. First, discontinuation is structural and most often it's a commercial decision. The harm comes from architecture and expectation gap and some of the harms are rare but cannot be undone. The EU law permits a shutdown on notice plus refund and protects least where consumers expect the most, exactly where they press the buy button.
The solution is to govern the exit. And finally, three windows are open now to take this action. Thank you so much.
Anna Cavazzini
Thank you so much for the excellent presentation and sorry again that I forgot to present you. We also of course welcome you very much, Vaida, here in in our committee. And I think, yeah, the study shows some very concrete ways forward that I really like. For example, closing some gaps without even opening new laws that we definitely have to look at. For us as committee it's always a little bit because we are not responsible for the code of conduct on the gaming thing, but of course we can politically ask this.
But of course, yeah, looking at the upcoming Digital Fairness Act and checking of where we also there can fill some gaps is I think an excellent idea. But let's move to the members. And we have online Dora David, yeah, because we know the EPP is on their study days, so we have very few MEP EPP MEPs, but Dora, so great that you connect online. The floor is yours.
Dóra Dávid
Presentation of the study. This is a tricky question. A few remarks. As you mentioned, in European law we have transparency that's important so consumers know what they can expect when they're buying a game. And we also have remedies in terms of refunds if the product is discontinued.
We need to make sure these are enforced. But neither of these solutions solve the problem that video games could disappear. And many of our citizens, over a million, think that games have an intrinsic value and they have a right to keep what they've purchased. So I think it would be reasonable for future games to have an end-of-life plan. I understand from developers that this that this is feasible without significant costs if if it's known from the start of the development.
So I have a question on the study because the study has a proposal to put in place exit mechanisms for games. And I wonder whether this this responds to the gamers' demand to leave games in a reasonably playable state. And if it does, then how would you implement this when a reasonably playable state or exit mechanisms mean different things for different games? And there are many different types of games which come in different shapes and sizes. And as you mentioned, there are also very different reasons for discontinuation.
And legally, we need to be very clear so that companies are able to actually implement this and that we have a workable solution. Thank you.
Maria Grapini
Mulțumesc, voi vorbi în limba română. În primul rând mulțumesc pentru prezentările făcute. Ne-au mai adus clarificări. Am două întrebări pentru dumneavoastră, sigur din perspectiva comisiei noastre pentru că avem piața internă dar și protecția consumatorului. Ați spus dumneavoastră că n-ar trebui să interzicem sistarea ci s-o reglementăm.
Ați putea să ne spuneți mai multe cum vedeți reglementarea sistării pentru că pentru asta sigur ar trebui să avem de ce nu poate un regulament din proprie inițiativă. Și al doilea lucru pe care vreau să vă întreb, președinta noastră a început cu a prezenta inițiativa cetățenească pe care noi am dezbătut-o în Parlament. Din perspectiva dumneavoastră, sunt convinsă că cunoașteți textul inițiativei cetățenești. Ce-am putea lua de acolo, care lucruri din inițiativa cetățenească pentru că știm bine noi nu putem ca și comisie rămâne la Comisia Europeană dacă dorește să vină cu o propunere de act legislativ. Din perspectiva dumneavoastră ce-am putea lua din acea inițiativă cetățenească pentru a putea să avem o reglementare până la urmă că asta era dorința inițiativei cetățenești.
Anna Cavazzini
Thank you so much to the two colleagues and then I give the floor back to you guys. You can decide yourself.
Teresa Rodriguez de las Heras
Thank you very much for for the questions. Let me start with the the first one about the video games. I would like probably as an academic to reply first from the feasibility of a particular approach. The question was about how to react to specific questions to specific concern in the video game sector. And one of the concern that we were handling during the preparation of the study is that even if from a market point of view and definitely from a consumer point of view identifying what a video game is seems to be probably easy and and very clear from a legal point of view and legislatively speaking could be a difficult and additional complexity in scoping.
It is not easy even if we believe it could be to define what is exactly a video game. We may have metaverse immersive experience that work as a video game. We could have video games that however are for medical training or they are for teaching or educational purposes. So this idea of video game in a very particular sector entertainment that we identify as a problem in the society can probably not be so clearly scoped and defined in the legal framework. And that is for us one of the reason why would be better and in our opinion more coherence and more elegant from a legal point of view to define a horizontal consumer law floor in all cases no matter how the digital service or the digital product is perceived by the consumer.
Vaida Gineikytė-Kanclerė
Only then we could work on sector specific idea or mechanism. I would like just to raise this point before we go to the second question that if I may Maria I give you the floor and then we come back please.
Of course. So if I understood correctly the second question was about how to govern the suspension. So I think here once again I have to refer to the scope of the study. We did not look into this very specific sector of gaming for entertainment but we looked into all different products and services.
And there is a huge variety and there are huge implications at various levels of the value chain of how these products are developed and how they are provided to the customers. So coming in with some very precise sectoral level regulation is not something that we actually looked into to be able to estimate its costs, its feasibilities and so on. So this is something perhaps what impact assessment should do. At this stage, it was important I think for us to show and demonstrate that games are not the only products that are being discontinued from which consumers suffer. This is a wider issue and the scope of remedies can also be very wide.
Teresa Rodriguez de las Heras
If I may add another point. There is also a probably not very satisfactory result of the study, but absolutely realistic. All these products are ecosystem dependent. And even in some cases the law could clarify and confirmed that the seller or the provider is liable, and is liable, however, the continuity remedy is unworkable because the seller or the provider is not the one in control of the back-end infrastructure that is permitting that particular video game, digital product or digital service to run at the same level of conformity. I'm saying that because even if the framework and the room for a specific legislation could be around reinforcing the remedies against the seller or against the provider, that is not guaranteeing that the expectation of total continuity can be indeed achieved.
Anna Cavazzini
Thank you, Madam Chair.
Thank you so much. We have time for a second round and I give the floor to Leila.
Leila Chaibi
Thank you Chair, I'm going to speak in French. Merci beaucoup aux auteurs de cette étude pour pour cette présentation. Votre étude étudie les cas d'arrêt de tous les produits et services numériques. Il y a un gros focus qui est fait sur les jeux vidéo et on vous comprend parce que il s'agit de d'un sujet d'actualité. Le principal enseignement de cette étude, on peut le résumer ainsi, malheureusement, c'est que pour la Commission européenne, l'intérêt des éditeurs est plus important que l'intérêt des joueurs et des développeurs.
Vous n'avez pas écouté ce que demandent les joueurs et notamment via l'initiative Stop Killing Video Games, et cela est confirmé par par cette étude. Je rappelle que la réponse à la Commission européenne suite à l'initiative citoyenne européenne Stop Killing Video Games n'a consisté qu'à demander un dialogue entre les parties et l'instauration d'un code de bonne conduite, c'est-à-dire aucune obligation légale. Et il me semble que c'est un crachat envoyé à la tête de, je rappelle, plus d'un million deux cent mille citoyens européens qui avaient signé cette initiative citoyenne européenne. Votre étude prouve également à travers ses recommandations que les demandes des joueurs sur le maintien en vie des jeux tués étaient bien légitimes, ces demandes, et qu'il était tout à fait possible de les transcrire en droit à travers le prochain Digital Fairness Act ou en modifiant les textes existants. Et je pense notamment à la directive sur les pratiques commerciales déloyales ou à la directive sur les contenus numériques.
Et ce qui m'a également frappé à la présentation de votre étude, c'est une forme de mépris qu'affichent quasiment sans vergogne les éditeurs pour leur communauté d'une part et pour les travailleurs du jeu vidéo. Ils considèrent les premiers, les joueurs, comme des vaches à lait finalement, et puis les seconds, donc les travailleurs des jeux vidéo, comme des variables à remplacer le plus rapidement possible par l'IA, par l'intelligence artificielle. J'en veux pour preuve un passage de l'étude : pour justifier la fermeture des jeux, les représentants de l'industrie évoquent la destruction créative de Schumpeter.
Tuer un jeu serait sain pour le marché, quelque chose de souhaitable. Ils ne se rendent pas compte de la violence de ces propos pour les joueurs et pour les travailleurs. Alors ma question, je vous la pose. Dans l'étude, vous dites que l'action législative devrait venir en cas d'échec de l'autorégulation du secteur. L'initiative citoyenne européenne, elle a été validée en janvier.
La Commission européenne a répondu en juin. Et depuis, il n'y a eu aucune annonce, aucune annonce de la part des éditeurs de jeux vidéo. Pouvons-nous dire qu'il est temps pour nous, élus européens, d'enfin nous saisir de cette question et de répondre cette fois-ci par la loi, par la régulation ?
Anna Cavazzini
Merci beaucoup. Ah, merci beaucoup. And I can add one last short question. In the right to repair, we have actually, if I remember well, regulated that there cannot be any software stops. So we cannot artificially shorten the lifetime of a product without, like, with not providing software updates.
Have you looked at this also, because I find this a quite interesting already first regulatory approach to say, okay, we cannot just shorten the lifetime of a product with, with digital discontinuance. So have you, I had not time yet to read your full study, so sorry if it's in there, but have you looked at this as well? So the floor is yours again. And I don't know if the Commission wants to also come in, let, give me a sign, if not, no problem.
Vaida Gineikytė-Kanclerė
Oh, yes, I think we did look into the right to repair directive for sure. And the finding there, I think, was that there are periods for how long the provider has to provide support, but once those periods end, the consumers are not safe anymore. So, yeah.
Teresa Rodriguez de las Heras
Yes, I just build on Vaida's response in the second question. The idea of updates can be relatively effectively embedded in the notion of conformity. So we have a strong notion of conformity in the European Union law. We suggest that this notion of conformity should be used in a more horizontal way. We insist on this idea for the purpose of coherence.
But as Vaida mentioned, everything is around the traditional legal standards of what is reasonably expected. So what are the reasonable expectation about the duration of that updates, and therefore this is the key and this is what is creating this feeling of the we don't know exactly how long this digital service is going to be provided. So again, conformity in our opinion is the concept that should be used. Second, uncertainty is linked to the idea of reasonable expectation that create indeed different expectation on the consumers. In relation to the first questions, we try in this study to promote more systemic-wise approach to the problem.
And that is the reason why we insist on this idea, all the legal system should work together consistently to provide a uniform solution in any case. Being a video game, being an immersive experience, being a software, being another kind of digital product embedded or or not. So we believe that this idea of coherent could provide more effective solution, including to the video game sector. That is why we avoid the idea of starting from a very specific video game that is approached from a self or code of conduct self-regulated, and we try to do exactly the opposite, the reversed approach. Let's start with the system as a whole.
Speaker 54
Let's include all that under the umbrella of digital service and digital product, and only when necessary, on top, we find the technical duties that specifically would satisfy the expectation in the in the gamers. So in a way, we confirmed this idea that an action is necessary, but probably in a multi-layer approach.
Anna Cavazzini
Thank you, and now I give the floor to the Commission, welcome also.
Martin Špýrýc
Thank you, Madam Chair. My name is Martin Špýrýc, I'm from DG Justice and Consumers. I'm here with my colleague Maciej Szymanowicz from DG Communications Networks, Content and Technology. So our two services, DG Justice and Connect, we were co-leading the work on the Commission's response to the mentioned European Citizen Initiative Stop Destroying Videogames, and we are working closely together as regards the follow-up actions to that communication. We would like to thank the experts of the IMCO Committee for their very interesting and comprehensive report.
Speaker 51
We are currently in the process of finalizing our application implementation report on the Digital Content and Services Directive, so your findings will be also very interesting to analyze in the context of this report, and we'll be also happy to use the findings of your study in our upcoming discussions with the video game sector as regards the announced preparation of the industry code of conduct to facilitate better conditions for consumers as regards discontinued games. In our response to the European Citizen Initiative, the Commission provided quite detailed analysis of the applicable legislation, so it contained its reasons why the Commission didn't consider an immediate legislative follow-up a proportionate solution. On the one hand, this is due to the fact that there are EU consumer protection rules which already protect consumers in this situation. The most important of these rules regarding the consumers' right to remedies are still quite new, they only apply from 2022, but due to transposition delays in quite a few Member States, probably even from 2023, so it has been only a few years since these new European rules adopted in 2019 are in application. Before these rules are actually applied in practice, it is too early to speak whether there are indeed legislative gaps.
That's why, as part of the follow-up actions, we also plan to work with our Member States' authorities, the consumer enforcement authorities and the stakeholders to raise awareness and to see how these rules can be better applied, because thanks to the application, we can also expect that the video game providers will be more careful and more forthcoming to the consumers as regards the conditions for terminating the games. But indeed, there were also other important aspects that the Commission had to take into account in formulating its response to the European Citizen Initiative. The video game sector as such is a very important sector for the European economy, and there is also a need to respect the intellectual property rights of the creators and authors. There were questions about and considerations around the costs that such obligations could generate, and also reasons related to increased cybersecurity and safety risks for players once video game providers cease supporting them. So it's a complex matter, requires a comprehensive follow-up.
As I mentioned, our two services are working closely together to provide this follow-up.
Speaker 52
We plan to start the preparations for the industry self-regulatory industry code, and also the mentioned other follow-up activities are in process. Thank you.
Anna Cavazzini
Thank you so much for also replying. And you can see there is, yeah, a lot of support, like I have said at the beginning, in this committee, but I think also in the whole Parliament for the goals of the European Citizens' Initiative. But I think your study also definitely helps to look in a more granular way what we can really do. So thanks so much for everyone. I think it was an excellent discussion, excellent study.
This terminates our agenda item nine. If there is not any other business, I can announce the next meetings. But you know it already. On the 4th of November, we have, to be confirmed, we have an ENVI-IMCO-TRAN joint meeting. And then on the 9th and 10th of November, we have our regular IMCO meeting.
And at 12 o'clock, we have our coordinators' meeting in this room. But I suggest we do a short break and start at 12. Thanks so much and have a great rest of the week and at some point also a weekend.