Bureau Européen des Unions de Consommateurs BEUC

48 submissions in the snapshot (31 from organisations), portal total 48. Feedback list on the portal.

6 of 31 organisation submissions analysed; the model reads them as: opposes 1 wants changes 5 25 without readable text, so not analysed.

• foodwatch NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Adopt a binding legislative instrument rather than relying on self-regulatory codes of conduct.

    foodwatch welcomes the Commission’s intention to tackle unjustified territorial supply constraints (TSCs), but considers that only a binding legislative instrument can be effective.

  • Introduce legislation identifying prohibited practices to clearly outlaw cross-border refusal to supply, resale restrictions, and unjustified price discrimination.

    Legislation identifying prohibited practices: This is the most effective option.

• Retail Ireland Business association, IRL; register: Trade and business associations model reads as: wants changes source
  • Introduce a targeted EU legislative instrument, specifically a Regulation based on Article 114 TFEU, to address unjustified Territorial Supply Constraints.

    The European Commission should introduce a Regulation, based on Article 114 TFEU, to address unjustified Territorial Supply Constraints and improve the functioning of the Single Market.

  • Establish a clear non-discrimination principle ensuring buyers are not subjected to unjustified differences in access to goods based on their location.

    The framework should establish a clear principle that buyers within the EU should not be subject to unjustified differences in access to goods based on their location of establishment.

  • Implement a targeted prohibition of harmful practices that restrict cross-border sourcing without objective justification.

    The Regulation should identify and address specific practices that restrict cross-border sourcing without objective justification, such as:

• Austrian Chamber of Labour (Bundesarbeitskammer - BAK) Other, AUT; register: Trade unions and professional associations model reads as: wants changes source
  • Adopt clear legislation that identifies prohibited territorial supply constraints and establishes deterrent consequences.

    Das gelingt nur mit klaren Rechtsvorschriften, die verbotene Praktiken identifizieren und abschreckende Konsequenzen festlegen.

3 more analysed submissions on the consultation page.

1,507 submissions in the snapshot (15 from organisations), portal total 1,507. Feedback list on the portal.

15 of 15 organisation submissions analysed; the model reads them as: opposes 6 wants changes 7 2 held back for review (low confidence).

• AI & Partners Company, NLD model reads as: wants changes source
  • Explicitly state children's rights under Article 24 of the Charter and UNCRC General Comment No. 25 in the text.

    Children's rights under Article 24 of the Charter and UNCRC General Comment No. 25 should be stated explicitly in the text.

  • Prohibit simulated intimacy and require crisis protocols for harmful content.

    Prohibit AI that: claims to be human; engages in romantic or sexual role-play; guilt-trips children or discourages human relationships; asks children to keep secrets.

  • Ban training models on children's conversations, emotional profiling, and in-chat advertising.

    Ban training models on children's conversations, emotional profiling and in-chat advertising.

• Electronic Frontier Foundation (EFF) NGO, USA model reads as: opposes source
  • Remove mandatory age gates for social media and video-sharing platforms that lead to privacy-intrusive age verification.

    1. mandatory age gates for social media and video-sharing platform, leading to privacy-intrusive age verification;

  • Reconsider safety by design measures that raise concerns about product-safety doctrines in speech regulation and federated services.

    2. certain safety by design measures, raising concerns about product-safety doctrines in speech regulation and their application to federated services; and

  • Address regulatory overlap with the EU's Digital Fairness Act agenda to avoid undermining consumer law.

    3. regulatory overlap with the EU's Digital Fairness Act agenda, risking undermining useful additions to the consumer law acquis.

• Faculty of Laws, University College London Academic or research institution, GBR model reads as: wants changes source
  • Address significant drafting errors and scope challenges arising from the reuse of Digital Markets Act definitions.

    Reuse of DMA definitions, which are designed for designation within, creates significant scope challenges.

  • Refine the overly broad risk criteria for Article 6 to avoid unintentionally capturing non-risky services.

    Risk criteria for Art 6 so broad to capture non-risky services, just because they are designed to incentivise interaction (as so many services are).

  • Clarify parental responsibility provisions to better account for complex family situations and domestic abuse risks.

    Parental responsibility is not held as digital data (e.g. court orders) for complex families, domestic abuse, etc.

10 more analysed submissions on the consultation page.

16 submissions in the snapshot (8 from organisations), portal total 16. Feedback list on the portal.

8 of 8 organisation submissions analysed; the model reads them as: wants changes 8

• Micro company, POL Company, POL model reads as: wants changes source
  • Provide for a single forum for the provision of services and define it with sufficient clarity to ensure legal certainty.

    In view of the ambiguity and the considerable dependence on the opinion of the court concerned, it is necessary, in accordance with the principle of legal certainty to which R 1215/2012 acquiesces, to provide for a single forum and to define it with sufficient clarity.

    machine translation by the Commission, original in PL
  • Make certificates needed to enforce a judgment abroad multilingual from the outset to avoid translation costs.

    Certificates needed to enforce a judgment abroad should be multilingual from the outset, such as multilingual death certificates.

    machine translation by the Commission, original in PL
  • Supplement Article 17 by consumer relations to simplify determining the competent court in the event of compensation by air.

    Article 17 should be supplemented by consumer relations, which are currently governed by the section of the contract of carriage, which makes it quite difficult to determine the competent court in the event of compensation by air

    machine translation by the Commission, original in PL
• Bundesverband ANUAS e.V. - HO für Mit-Opfer von Tötungsdelikten NGO, DEU model reads as: wants changes source
  • ANUAS suggests evaluating Article 7(2) and (3) also from the perspective of victims of serious acts of violence and co-victims of homicide.

    ANUAS therefore suggests expressly evaluating Article 7(2) and (3) also from the perspective of victims of serious acts of violence and co-victims of homicide.

    machine translation by the Commission, original in DE
  • The organisation recommends the introduction of more uniform European rules on jurisdiction and consideration of a narrowly circumscribed forum necessitatis.

    More uniform European rules on jurisdiction and consideration of a narrowly circumscribed forum necessitatis therefore seem appropriate.

    machine translation by the Commission, original in DE
  • ANUAS recommends that access to justice for victims of serious crime be included in the review as a separate assessment criterion and that cross-border enforcement channels be simplified.

    ANUAS therefore recommends, in particular, that access to justice for victims of serious crime be included in the review as a separate assessment criterion, that Article 7(3) be examined separately from the perspective of victims, that cross-border enforcement channels be simplified and that victims’ organisations be systematically included in the further impact assessment.

    machine translation by the Commission, original in DE
• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Consider trusted, machine-verifiable judicial status information as part of the modernisation review.

    We recommend that the review consider trusted, machine-verifiable judicial status information as part of this modernisation.

  • Measure end-to-end enforcement friction in the impact assessment.

    The impact assessment should also measure end-to-end enforcement friction, including verification time, procedural exceptions, legal cost, enforcement duration and the period during which claims, receivables or collateral remain economically unresolved.

  • Use identified material interoperability gaps to inform Horizon Europe 2028+ and related EU R&I priorities.

    Where material interoperability gaps are identified, they should inform Horizon Europe 2028+ and related EU R&I priorities, supporting cross-border pilots on trusted judicial-status interoperability before wider deployment.

5 more analysed submissions on the consultation page.

22 submissions in the snapshot (13 from organisations), portal total 22. Feedback list on the portal.

13 of 13 organisation submissions analysed; the model reads them as: supports 1 wants changes 12

• Aliapur Business association, FRA model reads as: wants changes source
  • Extend the right to deduct VAT and the simplification and harmonisation of the margin scheme to all second-hand tyres in all segments.

    we fully support the extension of the right to deduct VAT and the simplification/harmonisation of the margin scheme to all second-hand tyres in all segments (light and heavy vehicles).

    machine translation by the Commission, original in FR
  • Include heavy goods vehicle tyre retreading within the scope of remanufactured goods eligible for the new VAT regime.

    we fully support the inclusion of PL retreading within the scope of “remanufactured goods” eligible for the new VAT regime.

    machine translation by the Commission, original in FR
  • Exclude light vehicle tyre retreading from the favourable VAT regime until a reliable technical benchmark for retreadability exists.

    we do not support, at this stage, the inclusion of VL retreading in this same favourable regime.

    machine translation by the Commission, original in FR
• Micro company, DEU Company, DEU model reads as: wants changes source
  • Upcycling should be explicitly recognized as a distinct circular economic activity rather than being treated like simple second-hand resale.

    UPCYCLING should be recognised as a distinct circular economic activity.

  • The VAT system should be adjusted so it does not disadvantage businesses that use existing materials.

    The VAT system should not disadvantage businesses that use existing materials.

  • The administrative burden of the VAT framework must be simplified to accommodate micro-businesses and artists.

    The administrative system should recognise this reality. A circular VAT framework should be simple enough for a one-person business or small creative studio to use correctly without requiring disproportionate accounting resources.

• Universidad Complutense de Madrid Academic or research institution, ESP model reads as: wants changes source
  • Establish tax neutrality to remove bureaucratic barriers between refurbished and new goods.

    there is an urgent need to establish true tax neutrality that removes bureaucratic barriers on refurbished versus new goods.

    machine translation by the Commission, original in ES
  • Abolish the right of deduction for the destruction of viable goods and facilitate donation through harmonised exemptions.

    It is also imperative to abolish the right of deduction for the destruction of viable goods, facilitating donation instead through harmonised exemptions.

    machine translation by the Commission, original in ES
  • Make deductions for passenger cars exclusively conditional on zero-emission vehicles to decarbonise corporate mobility.

    Finally, to decarbonise corporate mobility, the new framework should make deductions for passenger cars exclusively conditional on zero-emission vehicles.

    machine translation by the Commission, original in ES

10 more analysed submissions on the consultation page.