ERT response to EC consultation on draft Horizontal BERs and Guidelines

The European Round Table for Industry (ERT) welcomes the European Commission’s public consultation on its draft revised Horizontal Block Exemption Regulations (BERs) and Horizontal Guidelines published on 1 March 2022. The comments in this paper are focussed on pointing out key elements of the revised drafts which ERT believes need to be reconsidered by the European Commission.

The comments in this paper follow ERT’s previous contributions to the public consultations on the rules on horizontal agreements – specifically, ERT’s February 2020 Position Paper on Horizontal Cooperation, its November 2020 Response on competition policy contributing to the Green Deal and its October 2021 response to the European Commission’s questionnaire.