Position papers

ETNO's position papers present its member-companies' views on a wide range of technical, regulatory and trade issues to European Union decision-makers, national governments and the general public.

They are developed either internally by ETNO working groups or, occasionally, in co-operation with third parties such as other industry associations.

Click here for definitions of ETNO Position Papers and Expert Contributions.

  • Position papers

    ETNO’s response to the EC public consultation on cybersecurity of digital products and ancillary services – Cyber Resilience Act

    ETNO welcomes the opportunity to provide complementary views to its response to the European Commission’s (EC) public consultation on the cybersecurity of digital products and ancillary services.

    25 May, 2022 Read more
  • Position papers

    ETNO Statement on the European Chips Act

    ETNO welcomes the European Commission’s proposal establishing a framework of measures for strengthening Europe's semiconductor ecosystem (Chips Act). A robust legal framework will respond to the need for a sustainable and resilient semiconductor supply chain across different geographies and ensure the EU’s place in the global supply chain.

    The severe disruption of global supply chains during the COVID-19 pandemic has demonstrated the EU’s heavy reliance on both Asia and the United States for the design and manufacture of chipsets that are used in products that are fabricated or imported in the EU. Chip shortages have impacted some industries more visibly than others. This situation is further exacerbated by the ongoing Russo-Ukrainian war, notably for raw materials in chipsets that are manufactured typically in the US.

    The Commission should take into consideration the needs of industry across all sectors. Although some industries that have been more visibly impacted by the recent chip shortages are in the focus, the importance of the ICT sector, and in particular of the telecoms industry, must not be overlooked.

    The telecoms industry provides the underlying enabling technology for a vibrant digital economy and society across the EU. As the industry evolves towards next generation technologies that are increasingly dependent, whether from a smartphone perspective or a network perspective, on cutting-edge chipset design and manufacturing, the availability of a diverse and resilient set of supply options will be crucial to ensure that future telecom networks and services contribute to strengthening the European semiconductor ecosystem.

    Enabling EU manufacturing capabilities by encouraging and supporting the enrichment of the entire EU supply chain, and thereby achieving more industrial independence from Asia and the US, will be important not only for smartphone chipsets, but also for server and telecommunications network infrastructure chipsets. With 5G and the advance of virtualised and disaggregated network architectures (e.g. Open RAN), the demand for state-of-the-art chipsets will increase even further. Additionally, development and supply of highly energy-efficient processors will be a significant enabler for environmentally sustainable IT devices and networks.

    A key success factor of the European Chips Act package depends on the skills and competences required, as well as on the colossal investments needed for such developments in the EU in order to enable a viable and dynamic EU semiconductor ecosystem that can compete globally.

    We look forward to further working together with decision-makers to streamline and focus the deliverables of the EU Chips Act package.

    11 May, 2022 Read more
  • Position papers

    ETNO’s submission to the public consultation on BEREC early call for input on BEREC Work Programme 2023

    ETNO welcomes the opportunity to provide early inputs towards BEREC’s Work Programme 2023. We believe that BEREC should in general focus on the ongoing tasks as mandated by EU legislation, as defined in the EECC, the Open Internet Regulation, roaming and intra‐EU calls, for example. We support BEREC’s commitment to establish structured cooperation mechanisms with EU institutions and other competent authorities.

    15 April, 2022 Read more
  • Position papers

    ETNO-GSMA-GIGAEurope response to the public consultation on the draft BEREC Guidelines on the Implementation of the Open Internet Regulation

    ETNO, the GSMA and GIGAEurope, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Draft Guidelines on the Implementation of the Open Internet Regulation. It is a crucial milestone to implement and enforce Regulation 2015/2120 on the Open Internet, especially in light of the European Court of Justice (ECJ) rulings concerning the interpretation of the specific Articles of the Regulation.

    14 April, 2022 Read more
  • Position papers

    ETNO response to the EC public consultation on sustainable consumption of goods – promoting the right to repair and reuse

    General considerations

    ETNO represents the main telecommunications network operators in Europe. In addition to the provision of access to communications services for consumers, our members provide mobile handsets to allow consumers to avail of the communications services to which they are subscribed.

    ETNO welcomes the opportunity to send complementary views to its response to the EC public consultation on sustainable consumption of goods – promoting the right to repair and reuse.

    5 April, 2022 Read more
  • Position papers

    ETNO-GSMA Statement Why filling the gap in supply chain management is a cybersecurity necessity

    Following the current decision to not directly capture all relevant actors of the ICT sector with the Directive on measures for high common level of cybersecurity across the Union (NIS2 Directive), ETNO and the GSMA would like to re-emphasise how important it is for the resilience of European critical infrastructure to leave no gaps in the supply chain risk management.

    17 March, 2022 Read more
  • Position papers

    ETNO response to EDPB Guidelines 01/2022 on data subject rights - Right of access

    ETNO welcomes the opportunity to comment on the draft Guidelines 01/2022. We highly value article 8 of the EU Charter of Fundamental Rights. The right of access for data subjects has been implemented by the members we represent since Directive 95/46/EC came into force. The members have looked closely at Article 15 GDPR and the corresponding considerations 63 and 64 when the GDPR came into force to determine whether any changes were necessary. The right of access has been actively exercised by data subjects without major problems or complaints for many years.

    17 March, 2022 Read more
  • Position papers

    Joint ETNO / GSMA response to BEREC Consultation on Net Neutrality Regulatory Assessment Methodology

    ETNO and the GSMA, who represent the telecoms sector in Europe, welcome the opportunity to comment on BEREC’s Draft Net Neutrality Regulatory Assessment Methodology. The methodology will provide important guidance on how to monitor Quality of Service (QoS) for access to the internet, which is a crucial milestone to implement and enforce Regulation 2015/2120 on the Open Internet.

    28 January, 2022 Read more
  • Position papers

    ETNO response to the draft BEREC Report on “a consistent approach to migration and copper switch-off”

    ETNO welcomes the possibility to comment on the draft BEREC report on a consistent approach to migration and copper switch-off.

    28 January, 2022 Read more
  • Position papers

    ETNO response to the RSPG Consultation on the draft Work Programme for 2022 and beyond

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the RSPG draft Work Programme for 2022 and beyond.

    6 January, 2022 Read more
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