China Chamber of Commerce to the EU
CCCEU
The China Chamber of Commerce to the EU is an active bridge-builder that helps Chinese enterprises in Europe chart the way for increased China-EU economic interaction.
ID: 490366039271-16
Lobbying Activity
Meeting with Simone Ritzek-Seidl (Cabinet of Commissioner Apostolos Tzitzikostas)
8 Dec 2025 · Exchange of views
Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and Xiaomi Technology Netherlands B.V. and
15 Jul 2025 · Automotive sector and EU trade developments
Meeting with Zaneta Vegnere (Cabinet of Commissioner Valdis Dombrovskis)
5 Feb 2025 · EU-China economic and trade relations
Meeting with Roman Arjona (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and A.P. Møller - Mærsk A/S
17 Dec 2024 · Recent economic developments in EU and US
Meeting with Vladimir Prebilič (Member of the European Parliament) and EU-China Business Association
25 Sept 2024 · Reception of Chinese Mission to the EU
Response to Carbon footprint methodology for electric vehicle batteries
28 May 2024
China Chamber of Commerce to the EU (CCCEU) represents more than 1.000 Chinese enterprises operating across europe. We welcome the opportunity to comment on the European Commissions public consultation regarding the carbon footprint methodology for EV batteries. The forthcoming implementation of carbon footprint declaration requirements for electric vehicle batteries, set to be enforced 12 months after the delegated regulation comes into force, presents a novel and substantial challenge for the automotive and battery industries worldwide. To address this challenge effectively, it's crucial for the EV battery supply chain to swiftly familiarize itself with the EU's calculation rules and gather the necessary compliant data. However, given the complexity of data collection and calculations, there may be some initial confusion and disruption. Therefore, we kindly request the EU to offer clarification on certain aspects of the process at the earliest convenience. Attached, you'll find our more detailed feedback.
Read full responseMeeting with Valdis Dombrovskis (Executive Vice-President)
23 Sept 2023 · Economic situation in China
Response to The reporting obligations during the transitional period of the carbon border adjustment mechanism.
11 Jul 2023
The China Chamber of Commerce to the EU (CCCEU), representing about 1,000 Chinese companies operating across the EU, is grateful for the opportunity to provide comments and insights on the draft Implementing Regulation on Carbon Border Adjustment Mechanism (CBAM) reporting obligations during the transitional period. The CBAM requires foreign operators to learn and apply, within 18 months, a calculation methodology primarily based on the complex monitoring rules of the EU Emissions Trading System (ETS). However, the current draft implementation regulation falls short of providing the necessary clarity and legal certainty, considering that the first reporting quarter is merely three months away. To prevent a chaotic and challenging transitional period for producers, importers, and EU authorities alike, we urge the Commission to promptly provide sufficiently clear rules. Given the difficulty in comprehending the CO2 calculation methods, we strongly recommend that the Commission provide detailed guidelines with working examples to illustrate the calculation. Please find our detailed feedback in the attached document.
Read full responseResponse to Detailed procedures for addressing distortive foreign subsidies
6 Mar 2023
The China Chamber of Commerce to the EU (CCCEU) covers around 1,000 Chinese companies operating in the EU. The chamber and its members welcome this opportunity to provide feedback on the draft of the Implementation of the Foreign Subsidies Regulation (FSR) and recognise the Commissions effort in setting out the rules for applying the FSR. However, the CCCEU has expressed concerns about the new tool targeting foreign subsidies allegedly distorting the internal market of the EU since the release of the White Paper by the Commission in this respect. These concerns are multifold, including the market openness of the EU towards foreign investments in the near future, the sound justification for any new and separate legal framework in addition to the existing mechanisms, the legal certainty that the new instrument could provide, the disproportional burdens the new instrument would impose on them that would unjustifiably impede legitimate business activities or unnecessarily increase the transitional cost, and most importantly, the potential discriminatory implementation of new instrument towards Chinese businesses, which in turn distorts the level playing field. Despite the strong opposition of various stakeholders which share the same concerns, the new tool was adopted and published in December last year. The adopted FSR turns out to amplify the above concerns. Notwithstanding, in view of the upcoming application of the FSR, the CCCEU supports the Commissions effort to provide more clarity regarding the practical and procedural aspects related to the application of the FSR for the purpose of addressing some of the above concerns. The CCCEU reiterates that an open and competitive market governed by non-discriminatory and clear rules is in the interests of all economic operators doing business in the EU. This requires that these rules and concepts are unambiguous, that any obligations arising from these rules to be assumed by economic operators are reasonable and proportionate to the objective to be achieved, that the procedure is transparent and fair, and that the rights of defence of the parties to such procedure are sufficiently safeguarded. The draft FSR Implementing Regulation (IR) together with its enclosed two annexes, published by the Commission on 6 February 2023, is the first step taken by the Commission in attempting to clarify the information required in the notification forms for concentrations and public procurement procedures. The draft IR also lays down rules on the calculation of time limits, on the access to the file and on the rights of the parties. According to the Commission, the draft IR would ensure the effectiveness of the Commissions proceedings as well as provide legal certainty to the procedural rights and obligations for the economic operators subject to FSR. In this submission, the CCCEU presents the views and concerns of its members with respect to the draft IR, as well as more generally the FSR regarding its implementation as from 12 July 2023.
Read full responseResponse to Effectively banning products produced, extracted or harvested with forced labour
30 Nov 2022
The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance collaboration of Chinese businesses in Europe. Following the release of the draft proposal for a Regulation on prohibiting products made with forced labour on the Union market on 14 September 2022, the CCCEU would like to present the views of the Chinese business community in Europe, in particular on behalf of its members. The CCCEU and its members support the goal of promoting good working conditions, labour standards, and corporate sustainability, in the belief that companies can play an important role in helping achieve these objectives. It has been already asserted in our feedback to the proposal for a Direction on Corporate Sustainability Due Diligence (CSDD) that the CCCEU recognises the overall importance of promoting decent work and responsible corporate behaviour throughout global trade and supply chains. However, the proposed framework raises a number of concerns from our members. In essence, we believe that this Proposal prohibiting products made with forced labour, as it stands now, contains a number of shortcomings which, if not addressed, could eventually hinder the Commissions goals of reducing forced labour in the world and of promoting sustainability standards. More specifically, we identified some issues related to the overall policy coherence with other EU legislation, including the CSDD, and to the legal certainty which shall be guaranteed to economic operators. At the same time, the CCCEU believes that the legal text should include more guidance on many aspects pertaining to the concrete implementation and operational details of the forced labour ban, especially the risk indicators of forced labour and the due diligence requirements. For this reason, we invite the Commission to reconsider these aspects and to revise the Proposal accordingly. For our detailed position and concrete suggestions on the Regulation on prohibiting products made with forced labour on the Union market, please see the document attached.
Read full responseResponse to Sustainable corporate governance
23 May 2022
The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance collaboration of Chinese businesses in Europe.
Following the release of the draft proposal for a Directive on Corporate Sustainability Due Diligence (CSDD), the CCCEU would like to presents the views of the Chinese business community in Europe.
The CCCEU and its members share the view that companies play a key role in building a sustainable economy and society. We recognise the overall importance of promoting sustainable and responsible corporate behaviour throughout global trade and supply chains. As such, we are supportive of all international and multilateral initiatives when it comes to the respect for human rights and environmental protection.
However, even though the CCCEU agrees with the ultimate objectives that the CSDD pursues, after carefully listening to our members and other Chinese companies active in the EU we would like to highlight that the proposal, as it stands now, raises a number of concerns. In essence, we believe that it contains a number of shortcomings, which are likely to create unbalanced, disproportionate and ambiguous obligations for all business operators, including the CCCEU members. As such, the CCCEU also worries that these obligations will eventually impede the Commission’s target of creating more legal certainty and a level playing field for all businesses in the EU. Therefore, we invite to the Commission to reconsider these aspects and to improve the proposal accordingly.
More specifically, our members stressed the need to harmonise the enforcement of the Directive in the EU Member States, thus limiting the potential fragmentation across different legal systems, which in turn would lead to competitive advantages or disadvantages for companies located in different EU countries, to the detriment of the level-playing field. In addition, more attention should be dedicated to better defining the legal concepts underpinning the proposal, starting from ‘established business relationship.’ Likewise, it is important to better specify the scope of application of the CSDD, which is found to be broad and difficult to implement practically. Lastly, serious concerns arise with regard to excessive administrative burdens and disproportionate liabilities on companies, which pair up with an insufficient transition period for businesses to adapt to the transposed due diligence rules. In this regard, the most problematic aspect of the CSDD Proposal is that it requires subject companies to exercise due diligence along the entire value chain, both directly and indirectly, at a level which goes beyond their control.
For our detailed position and constructive suggestions on the Directive on Corporate Sustainability Due Diligence, please see the document attached.
Read full responseResponse to Alignment of EU rules on capital requirements to international standards (review processes)
15 Feb 2022
The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance collaboration of Chinese businesses in Europe.
Following the release of the draft proposals for the revision of Regulation (EU) No. 575/2013 (Capital Requirements Regulation, or CRR) and Directive 2013/36/EU (Capital Requirements Directive, or CRD), known together as the CRD6/CRR3 package, the CCCEU would like to presents the views of the Chinese business community in Europe, in particular on behalf of the companies active in the banking and financial sector.
The CCCEU highly appreciates and supports the European Commission’s efforts to strengthen banks’ resilience and enhance financial stability through the CRD6/CRR3 package, in the belief that this will also ensure the EU’s objective of continued and adequate financing for the its economy.
However, after carefully listening to the voices of our members and of other Chinese companies active in the EU, we would like to caution the EU institutions with regard to the package, since we believe that it should be carefully calibrated, designed and implemented in a way that does not, unintentionally, constrain banks’ ability to support the EU’s economy.
On the one side, we believe that the EU institutions must ensure the new rules’ consistency with the international regulatory framework. On the other side, we see that the new requirements may have adverse effects on the economic and financial activities of banks and financial operators, both in the EU and in third countries.
More specifically, the proposed reforms to the EU banking rules raise some concerns among our members in relation to the treatment of third-country branches (TCBs). In the attached document, we argue that TCBs bring tangible benefits to the EU’s economy and have limited impact on the EU’s financial stability.
For this reason, we also suggest that the rules in the new package should take these elements into account and should avoid creating a burden for TCBs in the EU. In fact, we believe that, shall the new EU banking rules create a burden for TCBs in the EU and continuously rise their operating costs, this will undermine the attractiveness of investing in the EU’s financial industry for foreign banks and financial operators.
For our detailed position and suggestions on the CRD6/CRR3 package, please see the document attached.
Read full response3 Feb 2022
The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance the collaboration of Chinese businesses in Europe.
Following the release of the draft proposals for the revision of Regulation (EU) No. 575/2013 (Capital Requirements Regulation, or CRR) and Directive 2013/36/EU (Capital Requirements Directive, or CRD), known together as the CRD6/CRR3 package, the CCCEU would like to presents the views of the Chinese business community in Europe, in particular on behalf of the companies active in the banking and financial sector.
The CCCEU highly appreciates and supports the European Commission’s efforts to strengthen banks’ resilience and enhance financial stability through the CRD6/CRR3 package, in the belief that this will also ensure the EU’s objective of continued and adequate financing for the its economy.
However, after carefully listening to the voices of our members and of other Chinese companies active in the EU, we would like to caution the EU institutions with regard to the package, since we believe that it should be carefully calibrated, designed and implemented in a way that does not, unintentionally, constrain banks’ ability to support the EU’s economy.
On the one side, we believe that the EU institutions must ensure the new rules’ consistency with the international regulatory framework. On the other side, we see that the new requirements may have adverse effects on the economic and financial activities of banks and financial operators, both in the EU and in third countries.
More specifically, the proposed reforms to the EU banking rules raise some concerns among our members in relation to the treatment of third-country branches (TCBs). In the attached document, we argue that TCBs bring tangible benefits to the EU’s economy and have limited impact on the EU’s financial stability.
For this reason, we also suggest that the rules in the new package should take these elements into account and should avoid creating a burden for TCBs in the EU. In fact, we believe that, if the new EU banking rules create a burden for TCBs in the EU and continuously rise their operating costs, this will undermine the attractiveness of investing in the EU’s financial sector for foreign banks and financial operators.
For our detailed position and suggestions on the CRD6/CRR3 package, please see the document attached.
Read full responseMeeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson)
14 Jan 2022 · Presentation by CCCEU of its 2021 Report and discussion on developing green economy in the EU
Response to Addressing distortions caused by foreign subsidies
20 Jul 2021
The China Chamber of Commerce to the EU (CCCEU) is a non-governmental organisation founded in Brussels in 2018 by Chinese invested corporations based in Europe. The CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual understanding and dialogue between China and the EU, and to bridge the existing gaps and explore ways to enhance collaboration of Chinese businesses in Europe.
The CCCEU participated in the public consultation on the EU White Paper on distortive foreign subsidies in September 2020. We are pleased to see that some of our comments were taken into consideration by the European Commission and are reflected, either fully or partly, in the proposal for the draft Regulation, in particular those related to the thresholds triggering the investigation, to the balancing test, to the right of defence, and to redressive measures, among others.
On the other hand, we would like to caution the EU institutions with regard to the increasing obstacles and barriers that this draft Regulation will pose to foreign companies, including our members, which are operating in the EU and/or participating in concentration transactions and in public tenders in the EU Single Market.
After settling in the EU and contributing to the EU’s economic growth for many years, the CCCEU’s members would appreciate that the European market could remain open, competitive and fair. We also support the EU’s initiative to ensure the level playing field in the EU internal market, because it is beneficial for the market itself. However, any policy tools introduced and adopted by the EU institutions shall also ensure legal certainty for the business community, and openness and fairness in the market. They should avoid having a discriminatory impact on foreign companies, or leading to new distortions by offering privileges to EU locally owned companies, for instance in acquisition transactions or procurement processes.
In this feedback, we elaborate on the specific problems embedded in the draft Regulation, which fall into two main categories: those pertaining to the lack of legal certainty, and those related to the possible discrimination of foreign companies vis-à-vis European companies. For our detailed position, please see the document attached.
Read full responseMeeting with Michele Piergiovanni (Cabinet of Executive Vice-President Margrethe Vestager), Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)
1 Mar 2021 · Discussion around 2020 CCCEU Recommendation Report
Meeting with Damyana Stoynova (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)
16 Feb 2021 · Virtual meeting on EU’s green economy and Climate change
Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)
8 Jan 2021 · CAI