Challenge

Alber & Geiger assisted a US Fortune 500 chemical company to tackle the issue of illegal trade of refrigerants. For years, illegal trade of old generation refrigerants in Europe, prevented and delayed the introduction of high-end, climate friendly solutions. In parallel, the ongoing revision of the EU F-Gas Regulation was not delivering the expected results on phasing down the use of HFCs, as stricter penalties and measures to control illegal trade could only be enforced on a Member State level.

Strategy

Our team therefore embarked on a legislative initiative in Germany, which would offer a national solution that would inspired other Member States to use the German law as a blueprint. Alber & Geiger enforced a strategy which appealed to all levels of the German political institutions and administration. We supported the proposal on the level of the federal government, while in parallel gathering support at various political levels. Moving forward successfully, we managed to get our arguments through to stakeholders also in the European Union.

Results

On a first stage, Alber & Geiger supported a draft legislation which was in favor of our client’s expectations. On a second stage, our team also saw through the clearance of the German legislation from the EU Commission and inspire other Member States follow the German path. Finally, we locked the support from the German upper house and rapporteurs of the lower house, succeeding in the eventual speedy adoption of the legislation, which will be hopefully used as a blueprint solution in the EU.

Challenge

Alber & Geiger assisted West Pharmaceutical, a US corporation and world market leader in medical devices, paving the way for PFAS ban exemptions for their products. The intention was to prevent disruptions in the supply of certain medical devices, where the medicinal products are inseparably connected with the devices, like it is the case with the diabetes pen or with vaccines prefilled in containers and syringes.

Strategy

Our team engaged in a multifaceted approach to safeguard the interests of the medicinal and medical devices. We provided strategic input during the consultation period with the European Chemicals Agency (ECHA), highlighting the unique needs and safety considerations of specific medical devices. This was followed by an extensive outreach to stakeholders within the European Parliament, the European Commission, and the EU member states. Our efforts focused on educating decision-makers about the indispensable role of PFAS in medicinal products and medical devices and the potential supply chain risks posed by a PFAS ban.

Results

Our advocacy efforts led to a pivotal development in the regulatory landscape on medical devices. Our targeted approach opened the door to potential derogations of several years for specific medical applications where there is substantial evidence that viable alternatives to PFAS do not exist. This ensures that essential medical devices remain available and effective, safeguarding patient care and industry stability.

Challenge

Dynamic currency conversion (DCC) is a currency exchange service that enables customers to pay in their home currency or in local currency according to their choice. It is offered at ATMs and credit card transactions in shops. The service providers had raised concerns over the card scheme behavior of credit card companies aimed at limiting competition in currency conversion services across several jurisdictions, including in the European Union.

They contacted Alber & Geiger to provide political support with the European Commission’s Directorate General for Competition on their repeated complaints over card schemes’ excessive rules, fees and compliance regimes. Moreover, the companies relied on Alber & Geiger to help them identify political avenues to raise their concerns in the European Union, via regulatory and legislative paths, in parallel to their competition channel.

Strategy

From the outset, we created a strategy that focused on three works streams: political support into the complaint with DG Comp, advocacy with lawmakers and officials to raise awareness of DCC and highlight concerns against credit card schemes, and finally, to build support with merchant, consumer and other sectorial associations that are affected by currency exchange services. 

Results

Our team was able to raise awareness of the situation on currency exchange services, informing officials and politicians on the differences between the model offered by the credit cards, and that offered by the DCC providers, putting the emphasis on the DCC currency exchange service that brings more transparency and consumer choice. Simultaneously, through regular exchanges with lawmakers we have laid the foundation for support for our amendments on the ongoing EU legislation on the cross border payment regulation and the payment service directive. Finally, we managed to shift alliances in support of the issues highlighted by DCC providers.