Thankfully, 2022 was yet another busy but steady year for us. Globally, the Covid-19 restrictions were gradually cooled off but the war in Ukraine had started in February and global inflation kicked in. Global trade, EU financing, climate change and energy transition were all significantly impacted. So was consequently – to a lesser extent – our advocacy work.
The plethora of policy initiatives in the European Union, the UK and the US kept us and our clients busy. Our actions centred around EU policy advocacy in Brussels, Hungary and the US, business development in Spain and Hungary, and external evaluation of entities in Germany. Thankfully, Brussels Consulting’s clients continue to be coming from the private and the non-governmental sector. This year, we did not work directly with international or governmental institutions. In the following we would like to take stock of some of the policy advocacy activities in 2022.
The EU has been discussing the Energy Performance of Buildings directive’s revision for the past months, and we followed that closely. The revision has a twofold objective: contribute to reducing buildings' GHG emissions and final energy consumption by 2030, and ensure an adequate contribution to achieving climate neutrality in 2050. We focus on how this affects companies’ products and how they could contribute to this objective. To do so, we took part and monitored a number of workshops, events, parliamentary discussions, Council deliberations and had meetings with staff from the European Commission and representatives of EU member states. This provided us and our clients with the opportunity to better understand targets and the changing content of the draft, lobbying directions of the stakeholders, including the incorporation of indoor environmental quality and building automation references. On the side-line, we built up a deeper understanding of IEQ regulations globally.
Energy efficiency continues to be relevant to us and is also considered in the Energy Efficiency Directive’s recast. This proposal sets targets to increase energy saving, and to achieve those objectives by requesting Member States to put binding national actions in various sectors, including methods aimed at the Commission’s Ecodesign for Sustainable Products draft regulation. This is an overarching and important proposal for many products because in its scope also because of the introduction of the Digital Products Passport. The proposal is connected to the Commission’s draft aimed at empowering consumers for the green transition, the proposal on the harmonised conditions for the marketing of construction products, the carbon border adjustment mechanism (CBAM), the recent proposal for packaging and packaging waste regulation, the recent political agreement on the batteries and waste batteries proposal, and with the initiative on the right to repair.
Finally, we analysed all these initiatives with the aim to finding a common line, a sound and integrated perspective. Within the corporate sustainability sphere, we closely followed developments on the Corporate Sustainability Reporting Directive (CSRD). We also looked into the Corporate Sustainability Due Diligence Directive (CS3D), which outlines the future obligations to integrate due diligence into all corporate policies for EU limited-liability companies.
While green transition appears almost in all initiatives, digital transition and cybersecurity is also very present. The EU institutions were busy in that respect too: the recent NIS2 established a high common level of cybersecurity across the EU, involving requirements for risk management, reporting obligations and information sharing, and including the energy sector as a new "essential sector" under the law.
The NIS directive’s update was somewhat “accompanied” by other policy proposals in the digital sphere, namely the Data Act, the Artificial Intelligence Act, the AI Liability Directive, and the high common level for cybersecurity across the EU directive; which are all interesting for our clients. How industrial data is handled, what conditions there are for companies doing global business is equally important to the GDPR. What new responsibilities companies – that use smart technology in their solutions and products – have under the proposed liability rules represents no less urgency for stakeholders.
The year’s work results wouldn’t have been accomplished without the dedication and the incessant contributions from Juan, Monika, Inma and Antonella, and of course, our clients’ trust.
We are wishing a productive and happy new year to everyone.
Pál Belényesi and the team
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