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 and GSMA response to the consultation on the Commission’s Delegated Regulation amending Regulation (EU) 2015/758 of the European Parliament and of the Council as regards the standards relating to eCall

    ETNO and GSMA represent the telecoms sector in Europe and worldwide. Our members are the companies responsible for deploying next generation connectivity, with the aim of meeting the European Commission’s digital decade connectivity targets, and in parallel, making important progress on the twin green-digital transformation.

    As operators of mobile networks, which carry eCall communications, we have long engaged with the European Commission, national governments, and regulators to discuss the future of eCall, knowing that the phasing-out of 2G/3G networks is already done in many parts of the world and well underway in Europe. We therefore welcome the Commission’s consultation on the draft Delegated Regulation. We would like to emphasize that the subsequent early adoption and entry into force of the Delegated Acts impacting both car manufacturers and PSAPs is of great importance for many reasons, resource efficiency, innovation transformation and in relation to spectrum. Indeed, spectrum currently used in legacy networks is refarmed for 4G/5G mobile networks, meeting increasing demand for high-speed connectivity and IoT solutions.

    Draft Delegated Regulation amending Regulation (EU) 2015/758

    We support the proposed approach where new vehicles, placed on the market after 1st January 2027 will be considered in conformity with the regulation where they comply with the technical specifications for packet-switched eCall.

    In this regard, we also express our strong support for the voluntary option for early adopters to be considered in compliance with the regulation should they decide to place new vehicles on the market supporting eCall in packet-switched networks after 1st January 2025.

    Immediate use of new standards

    The utmost priority of the forthcoming Delegated Act is for the standards and technical specifications cited therein to be made applicable as soon as possible. This is a key objective of the act and should therefore not be delayed by the additional requirement for standards to be transposed into national legislation before being able to be applied. We are therefore highly concerned about the proposal to defer the date of application of such standards in recital 7.

    Rather, we encourage the Commission and the Council to enable the immediate application of the cited standards and technical specifications upon entry into force of the Delegated Act, in the understanding that these standards have already been developed, approved and published for use in the EU internal market.

    This is also critical for the voluntary adoption from certain manufactures as well (as mentioned in our point above) which demand such predictability and assurance at the earliest possible.

    Long-term solution to eCall

    ETNO and GSMA have engaged in thorough discussions with relevant stakeholders, including the European Commission, since several years now to raise our concerns on the current eCall solution. The priority for all the participants in the ecosystem is on ensuring that new vehicles will be supporting packet-switched eCall in 4G/5G networks as soon as possible. With the current proposals for Delegated Acts well underway, we anticipate this to be solved urgently.

    Following, the conclusion of this urgent task, which benefits everyone involved and the European citizens, a long-term solution for eCall should be anticipated and planned for in the Commission’s future mandate from October 2024.



    ETNO, the European Telecommunications Network Operators' Association, represents Europe’s telecommunications network operators and is the principal policy group for European e- communications network operators. ETNO’s primary purpose is to promote a positive policy environment allowing the EU telecommunications sector to deliver best quality services to consumers and businesses.

    The GSMA is a global organisation unifying the mobile ecosystem to discover, develop and deliver innovation foundational to positive business environments and societal change. Our vision is to unlock the full power of connectivity so that people, industry, and society thrive. Representing mobile operators and organisations across the mobile ecosystem and adjacent industries, the GSMA delivers for its members across three broad pillars: Connectivity for Good, Industry Services and Solutions, and Outreach.

    22 November, 2023 Read more
  • Position papers

    ETNO-GSMA response to the European Commission consultation on eCall: Delegated Act on PSAPs

    Draft Delegated Regulation amending Delegated Regulation (EU) No 305/2013 supplementing Directive 2010/40/EU of the European Parliament and of the Council with regard to the harmonised provision for an interoperable EU-wide eCall.

    19 October, 2023 Read more
  • Position papers

    Joint Telecom Industry Statement on the Gigabit Infrastructure Act

    Our Associations ECTA, ETNO, GIGAEurope and GSMA Europe represent the European telecommunications industry. Our industry plays a crucial part in connecting European citizens and businesses and facilitating the EU green and digital transition.

    27 September, 2023 Read more
  • Position papers

    ETNO comments to the RSPG Draft Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Draft RSPG Opinion on the development of 6G and possible implications for spectrum needs and guidance on the roll-out of future wireless broadband networks.

    25 August, 2023 Read more
  • Position papers

    ETNO comments to the RSPG Draft Opinion on Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU

    The European Telecommunication Network Operators' Association (ETNO) welcomes the opportunity to provide feedback to the Radio Spectrum Policy Group (RSPG) Draft Opinion on the “Strategy on the future use of the frequency band 470-694 MHz beyond 2030 in the EU”.

    24 August, 2023 Read more
  • Position papers

    ETNO position paper: Substantiating Green Claims and Right to Repair

    Telecom operators have taken decisive measures to increase sustainability of their operations and increase circularity in their business, bearing in mind the objective of increasing the useful life of devices.

    17 July, 2023 Read more
  • Position papers

    ETNO statement on International Data Transfers

    In the last years, new regulatory frameworks that guarantee user privacy in the digital environment have been adopted worldwide, from Africa, to South America and Asia.

    17 July, 2023 Read more
  • Position papers

    GIGAEurope, ETNO & GSMA seek greater clarity on the media concentration screening mechanism in the European Media Freedom Act

    Industry associations representing fixed and mobile connectivity providers in Europe, GIGAEurope, ETNO and GSMA, wholly support the objectives of the European Media Freedom Act (EMFA) to protect media independence and plurality, which are essential for functioning democracies and markets. As the legislative process advances, however, we would like to take this opportunity to recall the importance of ensuring that procedures for screening concentrations in Articles 21 and 22 provide the requisite legal certainty for companies with media-related services in their portfolios

    Drawing on related EU instruments,[1] GIGAEurope, ETNO and GSMA respectfully propose to reinforce Articles 21 and 22 of the EMFA proposal with the following technical details to ensure efficiency, predictability, and a clear division of responsibilities across the different regulatory bodies involved in this process.

    As investors and operators of Gigabit and 5G connectivity networks across Europe, our members play an important role in delivering audiovisual media services to EU citizens. The absence of the above procedural details on assessment timelines and safeguards for commercially sensitive information in the EMFA’s concentration screening mechanism could contribute to substantial delays and divergent procedures. This may lead ultimately to a more fragmented business landscape and unintentionally disincentivise valuable investment in the EU.


    For questions or clarifications on this joint statement, please contact:

    [1] See, for example, the EU Merger Regulation and the FDI Screening Regulation.

    17 July, 2023 Read more
  • Position papers

    ETNO and GSMA input for the Call for Evidence on virtual worlds (metaverses): a head start towards the next technological transition

    ETNO and GSMA welcome the opportunity to provide input to the European Commission’s Call for Evidence on virtual worlds and the technologies driving the transformation towards the next technological transition.

    11 July, 2023 Read more
  • Position papers

    ETNO-GSMA position paper: European Spectrum Policy for the Digital Decade – options for the new Radio spectrum policy programme

    Global events over the last three years have reminded us that advanced telecom networks are essential if Europe is to be successful in its pursuit of global leadership in the digital economy, remaining secure and resilient in the face of unpredictable global threats, and able to achieve its migration towards net-zero.

    Digitalisation will revolutionise the global economy over the next 10 years, by transforming everything from transport, manufacturing, healthcare, education, energy management and public services. By 2030, digital technologies and connectivity will be the very fabric of our societies and economies. The ubiquitous availability of high speed, low latency 5G connectivity will drive this revolution - and it will be those regions of the world that deploy 5G first that will be positioned for global success in creating and controlling these new digital environments and economies. Europe is in a “lead or lose” situation. Our strategic interest is to lead the future of connectivity. As European telecom operators, we work to stay ahead of the curve in roll-out of 5G and FTTH, development of new network and cloud technologies, digital inclusion and the twin green-digital transition.

    The EU’s Digital Decade envisages full 5G or 5G equivalent coverage by 2030, which means ensuring digital equality and inclusion for all European citizens and businesses no matter where they are. Mobile broadband has been proven to be a catalyst for GDP growth[1],[2], as a basis for social inclusion and wellbeing and a powerful tool in the fight against climate change. [3] As Europe seeks to emerge from the uncertain environment of the pandemic and deliver the twin digital and green transition, mobile has an important role to play in connecting everyone and everything everywhere.

    The important question is how do we deliver on this vision? While most countries in Europe have deployed commercial 5G services, and nearly two-thirds of operators in the region have launched 5G networks, it is clear that there are large differences between Member States, between urban and rural areas and most worryingly between Europe and other leading regions.

    Data headset 2

    Moreover, ‘full’ standalone 5G — where 5G is also deployed in the core of the network — is needed to deliver the promise of the technology. We remain far from that point in the EU, and significantly behind the leading countries. Asia Pacific leads the way in terms of live standalone 5G deployments, while such services are only now starting to be deployed in a few EU Member States.


    In addition, 5G coverage is just one high-level indicator by which to measure the Union’s progress. It is also necessary to consider 5G adoption, capacity, quality of service (QoS) and investment levels especially in comparison with other regions. Furthermore, in those areas with larger rural or dispersed populations there is a danger that a lack of sufficient 5G services will compound inequalities in poverty, social exclusion and digital skills.

    Europe already has an investment gap in telecom networks and services (€174 billion as estimated by the EC[5]), in conjunction with overall declining or flat revenues in the sector, returns below the cost of capital, weak market valuations and high levels of debt. In our view, policy change can help shape a future in which Europe innovates, grows and stays in control of its connectivity. However, reversing the downward trend in mobile investment in Europe requires a set of remedies - including radical reform of spectrum policy - to recreate an environment that can recover investor appetite for the sector and rehabilitate a healthy investment capacity for the sector.

    At a time when telecom networks are widely acknowledged as critical network infrastructure (CNI) and enablers of the twin digital and green transition, the sector faces serious challenges that, if not addressed, will prevent Europe from establishing itself as a digital leader for the coming decades.

    Critically, this must include, from a spectrum policy perspective: prolonging existing licences to align with investor timeframes; preventing distortive or inefficient awards for new spectrum; minimising the cost burden of annual spectrum fees; and securing a pipeline of new harmonised mobile spectrum bands (such as 6 GHz) to accommodate future traffic demands in an energy and cost effective way – the RSPP therefore must take a more pro-investment approach and ensure the broad spectrum provisions already in the European Electronic Communications Code (EECC) are clarified further to achieve a more harmonised approach to licensing and more concrete and ambitious investment outcomes across the Union.

    Furthermore, with 5G networks having much greater minimum scale at local level[6], consolidation is essential. While consolidation falls under the competence of DG-COMP, it is imperative that also through the RSPP, the RSPG and DG-CNECT set out clearly why the scale which can be achieved through consolidation is necessary for 5G deployment as it will benefit consumers and speed up the achievement of the EU Digital Decade’s targets.

    We elaborate on our positions in the paper. For questions and clarifications regarding this position paper, please contact Xhoana Shehu (shehu@etno.eu), Policy Manager at ETNO, and Emma O’Toole (eotoole@gsma.com), Senior Manager, Spectrum at the GSMA Europe.


    [1] The Mobile Economy 2023, GSMA, March 2023

    [2] The Socio-Economic Benefits of Mid-Band 5G Services, GSMA, February 2022

    [3] Mobile Industry Impact Report: Sustainable Development Goals, GSMA, September 2022

    [4] Austria, Bulgaria, Finland, Germany, Italy and Spain, GSMA Intelligence

    [5] Exploratory consultation - The future of the electronic communications sector and its infrastructure, European Commission, February 2023

    [6] A large majority of investments are made in assets that need to be geographically close to end users

    3 July, 2023 Read more
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