Branchehuset
Branchehuset a joint federation for the Danish Sanitary, Heating, Steel and Metal Wholesale Trade( Rørforeningen, Stålforeningen and Metalforeningen)
ID: 316954696153-62
Lobbying Activity
20 Aug 2025
In Branchehuset we acknowledge the concern that the current CBAM-rules might lead to a future increase in imports of downstream products from non-EU countries. However, we are concerned about the potential burdens and consequences of such an extension and wish to highlight that the full impact of the current scheme has yet to be realized. In addition, we would like to stress the urgent need to address outstanding legal certainty of the current CBAM regulation e.g. lack of legal acts ahead of any expansion of the scope - leaving even more European companies in judicial and economical limbo. They are unable to estimate their future cost due to the uncertainty of the actual price of CBAM certificates. In Branchehuset we are painfully aware that free trade in the global market is under pressure, and we acknowledge that current disruptions of the global value chains could lead to further dumping of goods on the European Market. However, the growing reliance on defensive trade mechanisms - from antidumping measures and safeguards to CBAM regulations - is creating an increasingly complex regime of rules, heightening the economic uncertainty that European importers must navigate. We would thus recommend that considerations regarding the extension of the scope of the CBAM regulation would lead to serious reconsiderations regarding the measures being used, and we strongly recommend that the Commission investigate the possibility of replacing the current reporting system with a carbon adjustment duty. For instance, drawing on experience from the antidumping system to significantly reduce the administrative burdens of the CBAM rules. It is also our hope that the Commission will extend the simplification agenda aimed at European industry to cover European companies taking part in global value chains. At the very least, serious improvements of TARIC database to make a more user-friendly overview of the different defensive trade mechanisms, safeguards, sanctions, rules, and regulations covering the different goods.
Read full responseResponse to European Water Resilience Strategy
4 Mar 2025
Branchehusets comments on an EU-strategy for water resilience Branchehuset welcomes a new EU-strategy for water resilience. We recognize that the European Member States face different challenges regarding climate change, water scarcity, pollution, flooding, and drought that might require diversified solutions across the member states. We do however believe that we can achieve the best and most sustainable solutions if we work closely together, and we thus support a horizontal strengthened European approach to water as a whole. Water is a scarce resource in large parts of the world and the European Union. Clean and healthy drinking water even more so. In addition, costs for securing clean and healthy drinking water are increasing. As a Danish actor in the drinking water supply chain, we are therefore pleased with the strengthened focus on improving access to clean and healthy drinking water in the EU, and we support a risk-based approach to handling drinking water quality. We agree that implementation is lagging and generally support further harmonization of rules and regulations to allow for the free movement of water and goods in contact with water. Implementation efforts regarding the Drinking Water Directive are ongoing but different national interpretations and missing guidelines are creating a lot of legal and economic uncertainty amongst European businesses. We would thus like to call on the European Commission to ensure the effective implementation of the EU Drinking Water Directive and prevent market uncertainties through; acceleration of the harmonisation of test methods, accreditation of an adequate number of conformity assessment bodies to ensure sufficient testing capacity, clear rules for the transition phase and timely issuance of product certificates. It is our hope that this could provide certainty about the implementation of the directive and would incentivise the European industry to keep and invest in the production of the drinking water appliances within the EU. It is furthermore our belief, that a harmonized and standardized approach to risk assessment, monitoring and quality management increases water quality and reduces costs for handling drinking water at the benefit of both consumers and businesses.
Read full response