3.1 Amendments related to the grounds for opposition 

In contrast to the discretionary power of the opposition division under Art. 114(2) or Rule 116 (see E‑IX, 2.10), Rule 80 establishes the non-discretionary, substantive requirement that anyAny amendments made in opposition proceedings must be occasioned by the grounds for opposition specified in Art. 100. Not admitting late-filed amendments on the basis of arguments of procedural efficiency or non-convergence should not therefore rely on Rule 80. That is to say, amendments are admissible only if they represent a genuine attempt to overcome a ground for opposition. However, the ground for opposition does not actually have to have been invoked by the opponent. For example, in opposition proceedings admissibly opened on grounds of non-patentability, the patent proprietor can also submit amendments to remove added subject-matter. The replacement of one independent claim as granted by multiple, e.g. two, independent claims each directed to a respective specific embodiment covered by the independent claim as granted is admissible if such a replacement is occasioned by a ground for opposition specified in Art. 100 (see T 223/97). Amendment of the claims in opposition proceedings may require amendment of the description (see D‑V, 5).