Position Papers

Connect Europe's position papers represent the views of its member companies on a wide range of technical, regulatory, and trade issues. These papers are directed at European Union decision-makers, national governments, and the general public.

Position papers are developed either internally by our working groups or, occasionally, in cooperation with third parties such as other industry associations at the European and national levels. This section also includes materials from our previous association, ETNO.

15 Apr, 2022

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.

14 Apr, 2022

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.

05 Apr, 2022

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.

17 Mar, 2022

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 Mar, 2022

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.

28 Jan, 2022

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 Jan, 2022

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.

06 Jan, 2022

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.