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Confederation of Danish Industry

DI

The Confederation of Danish Industry is Denmark's largest business organization representing 20,000 private enterprises.

Lobbying Activity

Meeting with Stine Bosse (Member of the European Parliament, Rapporteur for opinion)

30 Jan 2026 · ECF

Meeting with Christel Schaldemose (Member of the European Parliament)

11 Dec 2025 · 2026 and the political dynamics

Meeting with Christel Schaldemose (Member of the European Parliament)

9 Dec 2025 · EU’s lægemiddelpakke

Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and The Danish Chamber of Commerce and

8 Dec 2025 · Address to the cleantech MFF roundtable: An EU Budget for a Stronger, Cleaner and More Sovereign Europe – Recommendations from Danish Investors, Business Community & Civil Society

Danish Industry urges simpler, more practical EU Taxonomy rules

5 Dec 2025
Topic — The European Commission is reviewing rules for sustainable investment classification and reporting.
Message — DI recommends aligning technical criteria with corporate group-level reporting to avoid double regulation. They propose using ISO14001 standards for manufacturing and broadening the definitions for recycled materials.123
Why — Danish companies would face lower administrative burdens and more predictable compliance requirements.4
Impact — Sustainability leaders lose their market advantage if benchmarks shift from best to widely available technology.5
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Meeting with Niels Flemming Hansen (Member of the European Parliament, Rapporteur)

5 Dec 2025 · Digital omnibus and Small mid-caps

Meeting with Stine Bosse (Member of the European Parliament, Rapporteur for opinion)

4 Dec 2025 · ECF

Meeting with Stine Bosse (Member of the European Parliament)

6 Nov 2025 · Water policy

Meeting with Leopoldo Rubinacci (Deputy Director-General Trade)

3 Nov 2025 · EU trade policy

Meeting with Ekaterina Zaharieva (Commissioner) and

3 Nov 2025 · Investments into innovation

Meeting with Yvo Volman (Director Communications Networks, Content and Technology) and Confederation of Finnish Industries EK and Confederation of Swedish Enterprise

24 Oct 2025 · Data Union Strategy – Digital Omnibus

Meeting with Stine Bosse (Member of the European Parliament, Shadow rapporteur)

16 Oct 2025 · Revision of chemicals legislation in the Defence Readiness Omnibus - widened defence exemptions in REACH, CLP, BPR & POPS

Meeting with Niels Flemming Hansen (Member of the European Parliament, Rapporteur)

15 Oct 2025 · Small Mid-Caps and Omnibus 4

Meeting with Christel Schaldemose (Member of the European Parliament)

15 Oct 2025 · Omnibus

Response to Digital package – digital omnibus

14 Oct 2025

Europe has long been at the forefront of regulation and requirements in the digital sector with the aim of creating a safe and secure environment for the use of digital technologies, as well as strengthening digital security against growing threats. While the intention is both right and necessary, the volume and complexity of the legislation has increasingly led to uncertainty and burdens for European businesses. This has left the European continent with deteriorating digital competitiveness, and as geopolitical tensions increase, the need for digital sovereignty is growing. Regulatory simplification is therefore not only a means to reduce the burden on businesses and strengthen the economy it is a strategic necessity. Strengthening Europe's position in the global technological race requires simpler and more targeted regulation that supports innovation, protects value chains and strengthens resilience. Ultimately, it is about ensuring Europe's competitiveness, security and independence. The need for a digital omnibus package that brings together and simplifies existing regulation is therefore urgent. Regulation remains a necessary tool to strengthen our common resilience, but action is needed that not only reduces administrative burdens for businesses but also strengthens trust in the EU regulatory process and makes the European market more attractive for investment while contributing to the goal of more digital sovereignty. Only in this way can we create a framework that both protects and promotes innovation and competitiveness. At Danish Industry (DI) we see the digital omnibus as an opportunity to revise current and future legislation with the aim of creating simplification and harmonisation, proportionate and risk-based regulation, postponement or phasing in where the legislation is provisional or not ready for implementation, as well as uniform enforcement across the board. In this paper, DI presents the Danish business community's contribution to how we can create a set of rules that support rather than inhibit innovation, investments and competitiveness. The paper focuses on the general issues and recommendations that cut across the digital regulatory areas and also makes specific proposals for concrete regulatory changes within the EU regulation of artificial intelligence, cybersecurity, data and product legislation based on examples that Danish companies have contributed. Therefore, the paper will contain both recommendations for measures that can be implemented here and now, and recommendations targeted at the future legislative process as well as future fitness checks and omnibus packages in the EU. In addition to the core legislation for the digital domain, the digital omnibus should also take into account relevant changes from previous omnibus packages, in particular omnibus 4 regarding information obligations and the use of common specifications in product legislation. At the same time, the digital omnibus should refrain from introducing changes that fall under the broader product legislation, as the EU framework is currently under review and should not be changed in isolation for the digital area. We hope that the paper can support the further work on the digital omnibus and hopefully contribute to the simplification of the legislation that ensures that companies can drive digital development forward and contribute to Europe's global competitiveness and digital sovereignty.
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Danish Industry Urges EU to Prioritize Energy Efficiency in Heating Strategy

9 Oct 2025
Topic — EU strategy to accelerate decarbonisation of heating and cooling sectors through renewables.
Message — The organization requests focus on reducing energy demand through building renovation, accelerating heat pump deployment and electrification, and unlocking waste heat potential. They emphasize the importance of cooling infrastructure and call for consistent implementation of existing energy directives without duplicative requirements.1234
Why — This would support their manufacturing members' competitiveness while reducing energy costs and compliance burdens.5
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Danish Industry Urges Binding EU Electrification Target with Monitoring

9 Oct 2025
Topic — Action plan to increase electricity's share in final energy consumption through switching from fossil fuels.
Message — The organization requests that the 32% electrification target for 2030 be incorporated into the Governance Regulation with mandatory Member State reporting. They emphasize commitment to the Grid Package and enforcement of electricity market regulations to enable system flexibility.123
Why — This would provide investment security and regulatory stability for private investments in industrial electrification.4
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Danish Industry urges protection for aid recipients from recovery

6 Oct 2025
Topic — Revision of EU rules exempting certain state aid from prior approval.
Message — The organization requests stronger legal certainty and protection for aid beneficiaries from repayment demands when authorities fail to comply with block exemption rules. They argue beneficiaries acting in good faith should be protected by legitimate expectations, with Member States bearing the risk of rule violations.1234
Why — This would shield small companies from repaying aid due to government errors.56
Impact — Competitors lose protections against distortive aid improperly granted by Member States.7
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Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath) and Confederation of Finnish Industries EK and

2 Oct 2025 · Data protection and privacy

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Ørsted A/S and

18 Sept 2025 · Erhvervsnetværk - Sustainability omnibus

Meeting with Sigrid Friis (Member of the European Parliament)

17 Sept 2025 · Chemical legislation and circular economy

Meeting with Martin Engell-Rossen (Cabinet of Commissioner Dan Jørgensen)

16 Sept 2025 · Grids package, permitting and competition

Meeting with Stine Bosse (Member of the European Parliament)

15 Sept 2025 · REACH revision

Danish Industry calls for flexible nature rules and water pricing

4 Sept 2025
Topic — The EU is proposing a framework to manage accelerating climate change risks.
Message — DI advocates for nature-based solutions and better pricing for water risks. They seek unbureaucratic links between nature protection laws and urgent climate adaptation projects.123
Why — Reduced regulatory hurdles would lower costs for building infrastructure near protected areas.4
Impact — Environmental groups risk seeing crucial biodiversity protections sidelined for climate adaptation projects.5
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Danish Industry warns Commission against power grab in digital proposal

2 Sept 2025
Topic — Amending product legislation to allow digital documentation and common specifications.
Message — DI supports enabling digital documentation but demands consistent application across all product regulations. They urge the Commission to limit its powers over common specifications or remove them entirely.12
Why — Expanded digital documentation would significantly lower administrative costs and simplify logistics for Danish manufacturers.3
Impact — Global exporters face higher costs if EU-specific specifications replace international standards, requiring redundant documentation.4
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

DI appreciates the opportunity to provide input to the impact assessment of the NLF. We support the update of the framework building on its strengths and long-term benefits, and the intention to work towards a broader update of the entire European Quality Infrastructure ie. harmonised framework for developing EU harmonization product legislation, including rules relating to standardisation, accreditation and market surveillance by Q2 2026. To develop a robust framework for the future we believe changes need to be legislative and allow for continuous updating to stay future proof. Although improvements to the Blue Guide or targeted amendments might also be helpful, DI believes an update of the system would also serve the purpose of ensuring commitment from all stakeholders to how we regulate (and enforce) single market rules on products. Therefore, we believe the update should be in the form of Regulations, also when it comes to Decision 768/2008 EC, if possible. For more details see enclosed reflections on what the Impact Assessment should explore.
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Danish Industry urges fast-track permitting for energy infrastructure

5 Aug 2025
Topic — Measures to accelerate upgrade, digitalisation and expansion of European grid infrastructure.
Message — The organization requests fast-track permitting for energy infrastructure including hydrogen and electricity projects, standardized grid connection fees, and enabling industrial energy communities. They argue long queues for grid connections are slowing electrification significantly.123
Why — This would reduce delays and costs for connecting industrial electrification projects to the grid.45
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

31 Jul 2025

The Danish Industry (DI) is Denmarks largest business and employers organization. DI represents more than 20.000 small and big companies from virtually all areas of the Danish business community across the country. DI manages both employer interests and political interests of our member companies nationally and globally. DIs registration number in the EU Transparency Register is 5749958415-41. DI welcome the opportunity to comment on the Commissions consultation of rules on services of general economic interest (SGEI) to facilitate affordable housing which involves state aid. DI's comments attached in a PDF-document may be published and does not contain confidential information.
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Meeting with Kristoffer Storm (Member of the European Parliament)

22 Jul 2025 · Pharma

Response to Revision of the Standardisation Regulation

17 Jul 2025

DI appreciates this opportunity to provide input for the IA on the Standardisation Regulation. Please find our contribution in the enclosed document.
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Meeting with Christel Schaldemose (Member of the European Parliament)

14 Jul 2025 · Omnibus package

Confederation of Danish Industry urges faster approvals and procurement caution

8 Jul 2025
Topic — The initiative aims to accelerate industrial decarbonisation while maintaining European competitiveness and productivity.
Message — DI recommends empowering member states with one-stop shops and parallel approval mechanisms to fast-track projects. They argue financing should rely on EU initiatives rather than national state aid. They also advise that Buy European criteria must be implemented gradually to avoid supply chain disruptions.123
Why — Streamlined permitting would slash the two-year wait for projects, lowering investment risks and costs.45
Impact — Public buyers and SMEs could face higher administrative burdens if resilience criteria are poorly implemented.6
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Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

3 Jul 2025 · Water Resilience Strategy

Meeting with Pernille Weiss-Ehler (Cabinet of Commissioner Jessika Roswall)

3 Jul 2025 · Water Resilience Strategy

Meeting with Stine Bosse (Member of the European Parliament)

1 Jul 2025 · Budget, environment and water policy

Danish Industry urges EU to slash bioeconomy regulatory barriers

23 Jun 2025
Topic — The EU is consulting on a strategy for a circular, climate-neutral, and competitive bioeconomy.
Message — The organization calls for revising novel food and animal byproduct regulations to remove barriers to innovation. They advocate for an ambitious Biotech Act and better financial support for scaling up biorefining. Additionally, they suggest incentivizing the use of wood in construction to store carbon.123
Why — Proposed revisions would shorten time-to-market for new products and lower administrative costs.456
Impact — Manufacturers of fossil-based materials would lose market share to bio-based alternatives.7
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Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Eni S.p.A. and EuropeanIssuers

23 Jun 2025 · ESRS revision and EFRAG progress report

Danish Industry demands broad Biotech Act with strong IP protection

11 Jun 2025
Topic — The EU proposal aims to accelerate biotech product transitions from labs to markets.
Message — DI urges a broad scope covering medical, food, and industrial sectors with streamlined approvals. They demand that intellectual property rights remain untouched and benchmarked against high global standards. Additionally, the group seeks better access to capital for scaling up late-stage production.123
Why — Streamlined approvals and rigid IP rules would protect high-value research and speed up sales.45
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Meeting with Sabine Weyand (Director-General Trade) and

2 Jun 2025 · Exchange of views on the current geopolitical and trade situation

Meeting with Niels Fuglsang (Member of the European Parliament) and Danish Trade Union Confederation EU Office

2 Jun 2025 · Meeting on omnibus

Meeting with Villy Søvndal (Member of the European Parliament)

2 Jun 2025 · Interests of Danish Industry

Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur)

2 Jun 2025 · Due Dilligence

Meeting with Asger Christensen (Member of the European Parliament)

2 Jun 2025 · Competitiveness

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

2 Jun 2025 · Dinner with Danish Industry

Meeting with Niels Flemming Hansen (Member of the European Parliament)

21 May 2025 · life science and Competitiveness

Meeting with Niels Flemming Hansen (Member of the European Parliament)

14 May 2025 · Meet the MEP - Study tour

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

13 May 2025 · Priorities for the upcoming Danish Council Presidency

Meeting with Morten Løkkegaard (Member of the European Parliament, Shadow rapporteur) and European Biosolutions Coalition

13 May 2025 · Biotechnology & Biosolutions

Response to Quantum Strategy of the EU

9 May 2025

- Quantum technology is no longer solely a research domain but a strategic geopolitical competition. The EU has a strong starting point and should focus on the entire value chain from research to application. - Strategic partnerships with like-minded countries are essential to safeguard Europes technological sovereignty and innovative capacity. At the same time, the EU must act as a global player without international cooperation, we cannot win the global technology race. - Regulation should be approached with caution, as the technology is still immature and evolving rapidly. - Technological development should take place on its own terms. Therefore, no special requirements should be imposed on technological development, such as requiring it to be based on sustainability, the green transition, gender equality, etc. Doing so would limit technological progress, and Europe would lose the technological race. If one wishes to address specific issuesfor example, those related to the green transitiontargeted innovation calls can be made to address specific problems. - Europe's competitiveness needs to be strengthened particularly through improved access to risk capital, which is vital from the startup phase to global scaling. - There is a need to stimulate demand for quantum technologies through high-risk innovation projects. - Coordination of quantum-related activities across the EU should be enhanced to ensure that investments are optimized and aligned with member states' strengths. - Finally, we must ensure research across the full quantum technology stack from basic science to applied research and support interdisciplinary areas such as mathematics, chemistry, and computer science. The shortage of qualified talent in STEM and ICT fields is a real challenge for the emerging quantum industry.
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Meeting with Wopke Hoekstra (Commissioner) and

7 May 2025 · Discussion on the future of the European industry

Meeting with Niels Ladefoged (null Energy)

2 May 2025 · EU policy on energy efficiency

Meeting with Arba Kokalari (Member of the European Parliament) and Confederation of Finnish Industries EK and Confederation of Swedish Enterprise

28 Apr 2025 · Single market strategy

Meeting with Christel Schaldemose (Member of the European Parliament)

28 Apr 2025 · NFA

Response to EU Emissions Trading System - update of Verification and Accreditation Regulation (AVR), Batch 2

22 Apr 2025

DI appreciates efforts to give clear coherent methodologies in the ETS implementation guiding documents. Specifically, we will regarding non-CO2-emissions recommend striking a good manageable balance between environmental integrity and administrative burdens for operators. We also support efforts to become the first climate neutral region globally. For some hard to abate sectors, climate neutrality sooner rather than later will be a challenge. In that view, we understand that efforts to reach EU climate neutrality collectively in 2050 is a community objective in which all sectors must contribute with consideration of available affordable technologies. And with a full picture of the sectors decarbonization routes and contributions to 2050 based on cost-competitiveness for the EU as a whole. We will support further efforts to decarbonize the EU through a continued post-2030 regulatory framework that unleashes potentials and cost-efficient opportunities in the various sectors. The 2026 revision of the EU ETS will be of key importance, including efforts to include negative emission and thus incentivize a cost-efficient technology neutral EU-framework fitted for climate neutrality. Answering these questions will further assist sectors to plan their investments in climate in the future.
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Meeting with Villy Søvndal (Member of the European Parliament)

16 Apr 2025 · Defence Industry

Meeting with Roxana Mînzatu (Executive Vice-President) and

10 Apr 2025 · Meeting on labour market matters and preparedness

Danish Industry urges clearer materiality thresholds in EU Taxonomy reporting

26 Mar 2025
Topic — Initiative to simplify and reduce costs of EU sustainability reporting for companies.
Message — DI recommends clarifying that individual activities under 10% are immaterial to avoid burdensome reporting. They also suggest excluding 'Minimum Safeguards' to prevent double regulation with existing CSRD rules.12
Why — These simplifications would lower compliance costs and ease documentation requirements across complex value chains.3
Impact — Transparency groups lose granular data if companies collectively report or exclude smaller business activities.4
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Meeting with Maria Luís Albuquerque (Commissioner) and

24 Mar 2025 · Dinner at the House of Danish Industry and roundtable discussion

Response to EU rules on medical devices and in vitro diagnostics - targeted evaluation

21 Mar 2025

Please find attached the feedback on the EU rules on medicial devices and in vitro diagnostics from Danish Industry
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Meeting with Sigrid Friis (Member of the European Parliament)

21 Mar 2025 · Biosolutions (Vision for Agriculture and Food)

Meeting with Henrik Dahl (Member of the European Parliament)

20 Mar 2025 · Competition

Meeting with Rasmus Nordqvist (Member of the European Parliament)

18 Mar 2025 · Closed roundtable on circular economy

Meeting with Stine Bosse (Member of the European Parliament) and EuropaBio

14 Mar 2025 · European health policy

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

11 Mar 2025 · E-Commerce Communication

Meeting with Niels Fuglsang (Member of the European Parliament)

11 Mar 2025 · Meeting on energy

Danish Industry urges EU to simplify public procurement rules

7 Mar 2025
Topic — The consultation evaluates the effectiveness and relevance of EU public procurement directives.
Message — DI requests reducing administrative burdens to make the public sector an attractive customer. They advocate for uniform enforcement and oppose raising procurement thresholds for small businesses.12
Why — Streamlined rules would reduce transaction costs and simplify cross-border contract bidding.3
Impact — Third-country bidders face rejection if their low prices stem from state subsidies.45
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Response to European Water Resilience Strategy

4 Mar 2025

DI welcomes an EU WRS as outlined in the political guidelines for the present Commission Water is a natural resource fundamental for human activities and nature processes. To make balanced opportunities for all, we must leverage all activities and uses in a use-and-protect-nexus in the management of water resources. The value of water should be recognized between water users and be integrated in all decisions related to the use or protection Member states should recognize the value of water in reference to financing investments in water infrastructure and water management, and it must influence the work towards better financing of indispensable action in this sector. An ambitious implementation of WRS is essential and should be reflected in the upcoming EU Multiannual Financial Framework. The two newly revised directives, UWWTD and IED, will provide procedures for a safer and expanded treatment of wastewater from households and industry, if applied well and timely by member states. Faster implementation will accelerate reaching the target of 'restore and protect the broken water cycle'. Also, the new DWD and the regulation on reuse of treated wastewater in agriculture will help to provide a risk-based approach to comprehensive water resource management scheme. As all these set of rules have their own targets, an "omnibus" can be developed to link them for the purpose of a general water management scheme. Climate impact on water is prevalent both flooding and droughts, with Europe as the most affected continent. These conditions can reduce production and disrupt supply chains and security. Ensuring water resilience is critical for maintaining the competitiveness of European industries, as reliable water resources are essential for production processes, innovation, and sustaining economic activities. Water scarcity and extreme weather events can disrupt industrial operations, leading to increased costs and reduced competitiveness on the global stage. It entails new green-blue urban landscapes and solutions to solve this sort of water challenges. The EU water resilience strategy should also target global challenges with water. Sharing of European, sustainable water solutions and know-how will be key in EUs external relations thereby preventing migration to EU and reducing conflicts Water loss in distribution networks must be reduced to ensure a larger volume for consumers. It causes over-abstraction and unnecessary energy use. Instruments and techniques for this are already available. Water demand and supply should be leveraged for all sectors on a regional level. A reasonable mapping of demands and supply of drinking water and water with quality for only technical use is a transparent way to help both demand side and supply side how to develop solution to solve the demand & supply challenge in water stressed regions. The new INCITE-initiative within the IED can act as a platform for sharing water-efficient technologies l industry sectors to promoting wider dissemination. Water efficiency in all water demanding sectors. is crucial as more activities will need water in the future, e.g. the sectors in focus delivering to a larger self-supply in Europe of mined materials, electronic chips etc. Considering water management schemes, a one-size-fits-all-solution will not meet the needs throughout the various regions of Europe; geography, hydrology, demography and economic conditions as well as climate conditions are different from north to south and east to west. A regional or even RBMP-level approach will be needed. The regional approach will have to be determined both from stakeholders and economic activities as from hydrological parameters, which is different form the approach in the WFD today. It is essential to continue the significant efforts in research and innovation on water within the EU context, as it will become the future. Further and even more critical, the water sector will need more skilled personnel.
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Meeting with Rasmus Nordqvist (Member of the European Parliament)

4 Mar 2025 · Middag / studietur om Circular economy

Meeting with Per Haugaard (Head of Representation Communication)

4 Mar 2025 · EC and DI met as an introduction meeting. Topics discussed concerned the DSA and possibilities to send evidence, a Member State taskforce for online marketplace enforcement, and potential for upcoming events lead.

Meeting with Sigrid Friis (Member of the European Parliament)

3 Mar 2025 · Climate and environment exchange of views

Meeting with Dan Jørgensen (Commissioner)

3 Mar 2025 · European competitiveness and Clean Industrial Deal

Meeting with Sigrid Friis (Member of the European Parliament)

25 Feb 2025 · Omnibus proposal

Response to Delegated act on primarily used components under the Net-Zero Industry Act

20 Feb 2025

Please find our feedback on the delegated act on primarily used components under the Net-Zero Industry Act below: Delegated act on primarily used components under the Net-Zero Industry Act From a climate perspective, the right solutions are included, e.g. CCS, CCUS, and CO2 transport, etc. solutions. So are bio-solution technologies. There is apparently not as much focus on end-use products such as solutions that promote green cement, or other forms of innovative solutions to develop new product types. In relation to the specific and primary components included in Net-Zero technologies, we would like to clarify the importance of power semiconductors, also called 'IGBT modules', which should be included under the category "Energy system-related energy efficiency technologies". Power semiconductors are the backbone of Variable Frequency Drives (VFDs), inverters, and converters, which are critical technologies for energy savings in industry, renewable energy, and mobility. VFDs enable precise control and management of electrical energy, minimizing energy loss and maximizing efficiency. In industry, VFDs, driven by power semiconductors, play a central role in reducing energy consumption in motor-driven systems. Motor-driven systems together account for 56% of the overall electricity consumption in the EU and VFD's total potential in the industry can result in an energy saving corresponding to between 1.8% and 4.4% of the EU's total energy reduction target. In renewable energy production, such as solar cells, wind turbines, and energy storage, inverters and converters ensure an efficient energy transformation, for example from DC-AC or AC-DC, in renewable energy production such as solar cells. In addition, power semiconductors are a central component in critical technologies such as electric cars, charging infrastructure, power grids, and electrolysis. There are currently no available alternatives to power semiconductors in the aforementioned technologies, underscoring its critical function. This is mainly due to its unique ability to switch and control high currents and voltages with minimal losses. Power semiconductors contribute directly to several net-zero technologies and its inclusion as a primary and specific component will help enable the ambition of a production capacity of 40% of net-zero technologies and ensure strategic autonomy in the EU. Based on the above, an inclusion of power semiconductors, also called 'IGBT modules', is desired under the category 'energy system-related energy efficiency technologies' in delegated act Ares(2025)528655 as a 'primarily used' component and in implementing act Ares(2025)545490 as a 'specific' component.
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Response to Implementing Act on non-price criteria in renewable energy auctions

20 Feb 2025

Please find the Confederation of Danish Industry's input on the NZIA Implementing Act on non Price Criteria attached.
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Meeting with Christel Schaldemose (Member of the European Parliament)

20 Feb 2025 · de danske fødevarevirksomheders perspektiv

Meeting with Niels Flemming Hansen (Member of the European Parliament)

20 Feb 2025 · Food Drink dialogues

Meeting with Niels Flemming Hansen (Member of the European Parliament)

20 Feb 2025 · Meeting the new CEO if Danish indutrie of Food

Meeting with Sigrid Friis (Member of the European Parliament)

20 Feb 2025 · EU food and agriculture legislation

Meeting with Niels Flemming Hansen (Member of the European Parliament)

19 Feb 2025 · Omnibus

Meeting with Stine Bosse (Member of the European Parliament)

19 Feb 2025 · EU Africa policy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

19 Feb 2025 · E-commers (Temu and Shein)

Meeting with Christel Schaldemose (Member of the European Parliament)

17 Feb 2025 · Omnibus package

Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Novonesis A/S and International Biocontrol Manufacturers' Association

4 Feb 2025 · Collect stakeholders input for the SMET project on authorisation of biosolutions

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Confederation of Finnish Industries EK and Confederation of Swedish Enterprise

4 Feb 2025 · Roundtable with Nordic Business : Industrial vision for a post?2030 Energy and Climate Framework.

Meeting with Niels Flemming Hansen (Member of the European Parliament)

3 Feb 2025 · Omnibus

Meeting with Dan Jørgensen (Commissioner)

1 Feb 2025 · Discussion on energy policies

Response to Single Market Strategy 2025

31 Jan 2025

Danish Industry supports the need of an EU strategy on the Single Market. We believe it is important to have a strategy that focuses on the fundamentals that is often forgotten, especially the internal market for goods, and aspects that are not new, the internal market for services and the underlying governance tools. We have enclosed our Nordic position paper when it comes to the internal market for products. Please also be aware of the link to a more specific paper in this document to our paper on the New Legislative Framework. Below we will focus on additional points for consideration: 1. Commission enforcement of MS market surveillance Stronger EC enforcement of the MS obligations to do market surveillance on the ground is needed. Only if the MS do what they are supposed to, market access conditions can be fair. At the same time attention must be given to the different nature of various requirements. Guidance before sanctioning is key in new areas of compliance where experience is limited. At the same time rough traders need to be identified and sanctioned without hesitation. Collaboration between MS must be strengthened to optimize resource allocation and appropriate application of existing tools ensured (IMI/ICSMS, TRIS, SOLVIT, SMET). 2. New Legislative Framework (NLF) NLF needs to be updated to remain relevant. That means it needs to take into account the life cycle aspect, processes and the complexity of new business models (see specific paper). Furthermore, it needs to ensure a common framework for the implementation of the Digital Product Passport and foresee regular updates of the framework to accommodate future needs, including integration of other rules related to products ESPR, packaging, REACH. 3. Standardisation In the context of updating the NLF, a targeted revision of the Standardisation Regulation that will allow the private public partnership on standardisation to be preserved is needed. Without a well-functioning standardisation system, no NLF, no well-functioning internal market for goods. 4. Harmonized EU product regulation beyond NLF: Newly adopted legislation like ESPR and PPWR comes in the form of regulations which is positive. However, they don't apply NLF consistently. Furthermore, the national labelling rules should be brought in line as soon as possible. Also waste sorting regimes need alignment and would benefit from harmonization, as well as guidance on language requirements and how they can be fulfilled digitally. 5.Simplification of reporting obligations We support the simplification of reporting obligations related to sustainability underway, and point to the need for a similar exercise when it comes to reporting of vulnerabilities and incidents related to cybersecurity under NIS2, DORA, GDPR, CRA. 6. Services: Focus still needs to be on improving the implementation of the Services Directive, rather than new proposals, and to ensure the Services Directive is considered in all new legislations. A thorough screening of permitting, licencing and authorisation schemes should be carried out within prioritized areas. We suggest starting this vertical approach by exploring servisitaion of manufacturing. Challenges here are related to posting of workers, social security and regulated professions, but also linked to digital services regulated as part of newly agreed legislation on AI, data and cybersecurity. 7. Single Market Enforcement Taskforce (SMET) etc. SMET should be strengthened to ensure sufficient capacity for resolving unnecessary barriers on the internal market. More should be done to communicate about the possibilities it provides among MS and stakeholders and the results obtained. The same holds true for SOLVIT and TRIS. At the same it is important the Commission acts if the voluntary tools proof not to be effective to ensure businesses' internal market rights. Criteria should be developed for when the Commission should be obliged to start infringement procedures.
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Meeting with Dan Jørgensen (Commissioner)

16 Jan 2025 · European competitiveness and decarbonisation

Meeting with Dan Jørgensen (Commissioner)

16 Jan 2025 · Situation on European competitiveness and decarbonisation

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and BUSINESSEUROPE

15 Jan 2025 · Business Europe Dinner - Reboot Europe

Meeting with Henning Ehrenstein (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Confederation of Finnish Industries EK and

14 Jan 2025 · Single Market Strategy

Meeting with Henrik Dahl (Member of the European Parliament)

10 Jan 2025 · exchange of views

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur)

12 Dec 2024 · Animal Transport

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur)

11 Dec 2024 · Meeting on European competitiveness and the 2024 annual competition policy report (INI)

Meeting with Kristoffer Storm (Member of the European Parliament, Shadow rapporteur)

4 Dec 2024 · Pharmaceutical Legislation

Meeting with Niels Flemming Hansen (Member of the European Parliament)

28 Nov 2024 · Biosolutions

Meeting with Niels Flemming Hansen (Member of the European Parliament)

19 Nov 2024 · EDIP

Meeting with Villy Søvndal (Member of the European Parliament)

19 Nov 2024 · Møde med DI om udenrigspolitiske prioriteter

Meeting with Morten Løkkegaard (Member of the European Parliament)

18 Nov 2024 · Upcoming Legislative Agenda of the ITRE Committee

Meeting with Christel Schaldemose (Member of the European Parliament)

12 Nov 2024 · Biosolutions

Meeting with Niels Flemming Hansen (Member of the European Parliament)

11 Nov 2024 · Deforestation regulation

Meeting with Christian Ehler (Member of the European Parliament)

7 Nov 2024 · Industrial Policy

Meeting with Kristoffer Storm (Member of the European Parliament)

5 Nov 2024 · Reporting Requirements

Meeting with Sigrid Friis (Member of the European Parliament)

30 Oct 2024 · EU environmental policies

Meeting with Stine Bosse (Member of the European Parliament) and The Danish Chamber of Commerce

24 Oct 2024 · European industrial policy

Meeting with Christel Schaldemose (Member of the European Parliament)

23 Oct 2024 · general European agenda

Meeting with Sigrid Friis (Member of the European Parliament)

23 Oct 2024 · Upcoming term

Meeting with Henrik Dahl (Member of the European Parliament) and American Chamber of Commerce to the European Union

23 Oct 2024 · Exchange of views

Meeting with Sigrid Friis (Member of the European Parliament)

16 Oct 2024 · Upcoming term

Meeting with Stine Bosse (Member of the European Parliament)

15 Oct 2024 · European consumer protection - TEMU

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

10 Oct 2024 · Better regulation, patents and midcaps

Meeting with Niels Flemming Hansen (Member of the European Parliament)

27 Sept 2024 · Priorities for the mandate

Meeting with Niels Flemming Hansen (Member of the European Parliament)

27 Sept 2024 · Industry policy

Meeting with Stine Bosse (Member of the European Parliament, Committee chair) and European Patients' Forum (EPF)

26 Sept 2024 · European health policy

Meeting with Sigrid Friis (Member of the European Parliament)

23 Sept 2024 · Upcoming mandate

Meeting with Niels Flemming Hansen (Member of the European Parliament)

19 Sept 2024 · Industry policy

Meeting with Villy Søvndal (Member of the European Parliament)

11 Sept 2024 · General discussion on Defence and Security

Meeting with Niels Flemming Hansen (Member of the European Parliament)

11 Sept 2024 · Defence

Meeting with Morten Løkkegaard (Member of the European Parliament)

9 Sept 2024 · Platform regulation and consumer protection

Meeting with Morten Løkkegaard (Member of the European Parliament)

9 Sept 2024 · DSA enhancements

Meeting with Niels Flemming Hansen (Member of the European Parliament)

9 Sept 2024 · Biosolutions

Meeting with Morten Løkkegaard (Member of the European Parliament)

3 Sept 2024 · New parliamentary seating

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

26 Jul 2024 · EU competitiveness, industry, climate and energy policy

Meeting with Stine Bosse (Member of the European Parliament)

24 Jul 2024 · European industrial policy

Meeting with Per Clausen (Member of the European Parliament)

24 Jul 2024 · Det kommende mandat, den Danske arbejdsmarkedsmodel, grøn omstilling

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

16 Jul 2024 · Green deal and industrial policy in light of European elections

Meeting with Sigrid Friis (Member of the European Parliament)

16 Jul 2024 · Upcoming mandate

Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

20 Jun 2024 · General discussion

Meeting with Florika Fink-Hooijer (Director-General Environment)

6 Jun 2024 · Priorities under the next Commission Exchange on industry solutions on water challenges.

Meeting with Pernille Weiss-Ehler (Member of the European Parliament) and Central Denmark EU Office

30 May 2024 · WMM KIC

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

19 Apr 2024 · Exchange on EU competitiveness

Response to Evaluation of the European Food Safety Authority (EFSA) 2017-2024

8 Apr 2024

The Danish Food & Drink Federation thanks for the opportunity to contribute to this call for evidence. Please refer to attached file for comments. We thank you for considering these comments.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur) and Novo Nordisk Foundation

21 Mar 2024 · Directive on Medicinal products for human use

Meeting with Christel Schaldemose (Member of the European Parliament)

20 Mar 2024 · Net zero infrastructure

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Ørsted A/S and

1 Mar 2024 · Energy market Also present: ESABCC, Think Europa, the Danish Council on Climate Change

Meeting with Morten Løkkegaard (Member of the European Parliament)

29 Feb 2024 · Green Transition

Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

15 Feb 2024 · Proposal for a targeted revision of the Waste Framework Directive

Response to Evaluation of the Regulation 2019/515 on the Mutual Recognition of Goods

26 Jan 2024

The Confederation of Danish Industry (DI) appreciates the opportunity to respond to the Call for Evidence on the Regulation on Mutual Recognition. Please find our response in attachment.
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Meeting with Morten Løkkegaard (Member of the European Parliament)

12 Jan 2024 · Late Payments

Meeting with Morten Løkkegaard (Member of the European Parliament)

12 Jan 2024 · Biosolutions

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

30 Nov 2023 · Physical meeting - Discussions regarding the EU tax and customs policies

Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

29 Nov 2023 · Blue Deal

Meeting with Zaneta Vegnere (Cabinet of Executive Vice-President Valdis Dombrovskis)

17 Nov 2023 · wind power and wind markets

Response to Drinking water - conformity assessment procedure

16 Nov 2023

The Danish Industry, DI, welcomes the possibility to submit our feedback in the public consultation regarding the implementation of Drinking Water Directive. We welcome an EU implementation of common regulation on this market to take place and fully support the overall objectives of the directive and support a suitable implementation. Our comments are mainly related to 'procedure and methodologies for testing and accepting final materials'. Regarding the timeline for the implementation of a procedure and methodology for testing and acceptance of materials, we find that too many details are still missing in order to meet the suggested deadline after 3 years for companies to be ready for an application and to have criteria ready for assessing and accepting materials. First of all, there is a lack of laboratory capacity and time to develop the accredited test methods. Establishing test laboratory capacity requires large investments and is a time consuming procedure. In order to establish more accredited test laboratories and to ensure tests can be performed across laboratories with the same results, an inter-laboratory round robin tests have to be run and results must be evaluated. And if the test results are not corresponding the test methods need to be revised and the programme to be re-run before a conclusion can be reached. Accessibility to laboratory capacity should be ensured across Europe in order to ensure a level playing field for all European economic operators. Some Member States have no current infrastructure for approval of Drinking Water installations and accreditation of certifiers are needed which is another time consuming task requiring investments. For SME companies time should be given to adapt to the new certification scheme and build up the necessary competences and capacity. In general we do not support optional test methods and support choosing the methods giving the most reliable and repeatable test results as suggested in annex item 3.4 and 4.2.3:. Transparency on methods and acceptance criteria are needed for both manufactures and distributors in order to avoid confusion on the market. Test methods and acceptance criteria must be based on sound science and the analyses should not risk ending up with test results having error margins up to 10 times, which has been seen in one of the tests suggested. Requirements for data with such uncertainty should be left out until sufficient reliability in the methods have been reached and the science behind can explain and suuport the proportionality. Analytic methods and capacity have to be in place in order to prove compliance and the requirement will lead to important products to disappear from the market in case the expire date will not be prolonged. For several substances no analytical methods are developed and agreed upon, yet. This seems to be the case for PFAS, which is an inhomogeneous and enormous group of organic fluor compounds, where no accredited test exist, yet and where we do not have the knowledge of possible levels to be reached. Further the Arvin substances from degradation of certain antioxidants are being subject to an ongoing study, and the values for such substances should not be included until we have seen the report of the study. . In Denmark as well as in other Member States we do not use chlorinated water for tap water and we therefore ask for a different approach between products intended for specific use in chlorinated water and standard drinking water products. Further the chlorinated water used by the laboratories as test water when testing products for chlorinated water must be specified with regards to the chemicals used and their concentration. We appreciate that guidance documents will answer some of the outstanding questions on how to handle some of the details and await these. We hope you will invite some of our knowledgeable industry members to be part of this work.
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Meeting with Niels Fuglsang (Member of the European Parliament) and Confederation of Finnish Industries EK and

13 Nov 2023 · 2040 Climate Target: Why The EU Must Maintain Climate Leadership

Meeting with Karen Melchior (Member of the European Parliament) and Novo Nordisk A/S

7 Nov 2023 · Intellectual Property Rights

Meeting with Niels Fuglsang (Member of the European Parliament)

6 Nov 2023 · Grøn Omstilling

Meeting with Karen Melchior (Member of the European Parliament)

3 Nov 2023 · Discuss Intellectual Property Right

Meeting with Bergur Løkke Rasmussen (Member of the European Parliament)

31 Oct 2023 · Late Payment Regulation

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

27 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Christel Schaldemose (Member of the European Parliament)

26 Oct 2023 · paradigm shift in industrial policy

Meeting with Asger Christensen (Member of the European Parliament, Shadow rapporteur for opinion)

24 Oct 2023 · Agriculture

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur) and Novartis International AG and

13 Oct 2023 · Directive on Medicinal products for human use

Meeting with Niels Fuglsang (Member of the European Parliament)

11 Oct 2023 · Multiple-vote share

Response to Adjusting size criteria for inflation in the Accounting Directive to define micro, small and medium-sized enterprises

6 Oct 2023

DI The Confederation of Danish Industry welcome the revision of the size criteria in light of the high inflation in the recent years. We find the adjustment of the monetary size criteria with around 25% as proposed by the EU-Commission to be appropriate and support the effort to achieve simple and meaningful size criteria and thus supports the proposed thresholds. The effort is one of many needed initiatives to reduce the administrative burdens and compliance obstacles in the EU. Adjusting the size criteria is a significant relief for those companies that are currently at or just above the thresholds, which according to our calculations would be around 700 thousand companies (se calculations below). However, we would like to highlight, that we believe further measures are needed as the other 18 million companies are also in need for reliefs in administrative burdens. We thus support the EU-Commission focus in for instance the SME Relief Package, where 55% of the SMEs point at administrative burdens as the biggest challenge. We would suggest that the EU-Commission as a start also considers the following elements: 1) Adjustment of the # of employees size criteria. We believe there is room to increase these thresholds in article 3 of Directive 2012/34/EU as well: o Micro from 10 to 15 employees o Small from 50 to 75 employees o Medium from 250 to 750 employees Given the requirements and administrative burdens associated with the different sizes of companies, we believe this adjustment reflects the increased complexity of the regulation. We also believe these adjusted thresholds would not imply a significant loss in information being accessible to the public. Looking for instance at the CSRD-reporting requirements, the companies benefitting from the increased thresholds by being relieved from the mandatory reporting requirements would still be required to provide information in the value chains as part of the B2B business relations but would to a higher degree focus on the relevant and essential information needed. We also believe the thresholds should be consistently applied across the EU-regulation in order to reduce the complexity of identifying the individual thresholds in different legislations, for instance in VAT legislation. 2) Having a holistic approach to reducing administrative burdens, for instance by removing reporting requirements being obsolete due to the reporting under the CSRD. To this end, we welcome the anticipated initiative from the EU-Commission as announced in the SME Relief package by establishing across the Commission services standardised means of mapping reporting requirements in existing legislation or administrative arrangements and in new proposals as we believe this a key measure to identify and remove/streamline reporting requirements. On the specific proposal, we have a technical comment relating to the calculation of the burden reductions and the number of companies benefitting from the revised thresholds. The technical comment is illustrated in the attached document, but does not change our support to the proposal.
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Meeting with Bergur Løkke Rasmussen (Member of the European Parliament, Shadow rapporteur)

2 Oct 2023 · European Port Strategy

Response to Evaluation of Standardisation Regulation (EU) No 1025/2012

29 Sept 2023

The Confederation of Danish Industry response to the Commission Call for Evidence for an evaluation of Regulation 1025/2012 Regulation (EU)1025/2012 plays a key role in the New Legislative Framework. It has been paramount to the well-functioning of the Internal Market. Further integration of the Internal Market and European resilience requires of the regulation to allow for the timely development of standards, regardless their relationship to EU-legislation and policies or not, and for the alignment between European and international standards. Decoupling of international standards from European counterparts must be avoided to ensure European competitiveness. Easier publication of international standards must be ensured. Despite multiple attempts to solve the issues related to the timely development and publication of harmonized standards, challenges continue to exist. Although these challenges for most parts seems to be related to the implementation of the current regulation, they may also call for improvements to the text to provide for legal certainty. More firm deadlines for deliveries in the supply chain of standards from the outspring to their publication in the OJEU for all involved parties may be needed to speed up the process, as well as escalation mechanisms to facilitate that deadlines are met. Emphasis is needed to make participation in standardisation to experts as attractive as possible to ensure the European system is not abandoned. The success of the European standardisation system rests on the broad participation of experts representing all stakeholders. Increased participation of national competent authorities would also improve market surveillance competences at national level. Also, the proportionality of measures implemented since the James Eliot ruling to protect the Commission against liability need to be reassessed considering the implications for the speed to market of standards and the potential loss of market relevance. The standardisation system should continue to be market driven at the same time as solutions to the geopolitical challenges must be developed. Opening of the regulation can have significant impact on the future of the internal market and global trade, and the ability for Europe to become technological sovereign as well as a standard setter. Therefore, the regulation should not be opened for revision unless a high-quality impact assessment justifies it, and a competitive check proves it adds to European competitiveness. At the same time efforts to strengthen trust in the system must continue. This includes only restricted use of common specifications according to well defined criteria and as a last resort. The questionnaires to be developed for the consultations should allow for stakeholders to evaluate the progress made through the already implemented measures to solve the backlog of standards not published in the OJEU as well as reporting the challenges the stakeholders active in standardisation still experience and how they believe the challenges can be solved. DI looks forward to contributing to the consultation and would welcome an invitation to engage also in the targeted consultation. Mette Peetz-Schou Leading Senior Advisor meps@di.dk +45 40373728
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

18 Sept 2023 · Directive on Medicinal products for human use

Danish Industry urges EU support for carbon capture value chain

31 Aug 2023
Topic — This consultation examines strategic policy options for deploying industrial carbon management technologies.
Message — The organization urges the Commission to de-risk investments for companies across the entire value chain. They request a solid infrastructure backbone to transport carbon between European member states. The industry also seeks clear standards and storage licenses for both offshore and onshore sites.123
Why — Expanding cross-border infrastructure allows Danish firms to monetize their excess carbon storage capacity.4
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Meeting with Erik Poulsen (Member of the European Parliament)

19 Jul 2023 · Taxonomy & Sustainable Finance

Danish Industry urges simpler rules for environmental claims

18 Jul 2023
Topic — EU proposal requiring companies to substantiate green claims using specific footprint methods.
Message — DI requests simple rules to prevent companies from avoiding green communication. They oppose mandatory third-party certification and want animal welfare excluded. Rules should align with existing Danish guidelines to ensure consistency.123
Why — Reducing documentation and removing certification requirements would lower administrative costs.4
Impact — Animal welfare groups lose by having ethical concerns removed from assessments.5
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Confederation of Danish Industry urges alignment of sustainability reporting rules

7 Jul 2023
Topic — The consultation concerns the first set of European sustainability reporting standards.
Message — The organization requests that the Commission align sustainability reporting with financial sector rules to avoid double reporting. They propose adjusting guidelines so that non-reported immaterial data is treated as a qualified zero by banks.12
Why — This would prevent companies from facing duplicative and uncoordinated data requests from financial institutions.3
Impact — Transparency advocates lose access to detailed environmental data due to higher reporting thresholds.4
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Meeting with Christel Schaldemose (Member of the European Parliament, Shadow rapporteur for opinion)

27 Jun 2023 · NZIA

Meeting with Niels Fuglsang (Member of the European Parliament)

22 Jun 2023 · (APA) Cyber Resilience Act

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

20 Jun 2023

The Confederation (DI) supports the proposed amendment. An extension of the application date to 1 August 2025 is needed to ensure radio equipment covered by the relevant legislation can continue to be placed on the market after 1. August 2024. The extension takes into account the challenges linked to the novelty of developing the needed standards. Furthermore, it recognizes the fact, that application of 3rd party notified bodies is not a relevant alternative to allow market access given the lack of such capacity and the time and skills needed to boost it, regardless notification will be based on accreditation or not. Notified bodies under the RED don´t have the needed cybersecurity expertise and have to get access to the right skills before the process of notification even can start. Furthermore, the national accreditation bodies might not have necessary expertise either. Furthermore, there is a skills shortage in the area in general. As there is a risk the harmonized standards are still not publish in the official journal by 1 August 2025, DI encourages the Commission to develop common guidelines for the notification of notified bodies for cybersecurity under the RED delegated act. It will help ensure sufficient capacity in the market, the needed quality of the services provided and a level playing field between notified bodies, should the application of notified bodies be needed(due to lack of published harmonized standards) or wanted by economic operators bringing radio equipment on the market.
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Rud Pedersen Public Affairs Brussels

16 Jun 2023 · Democracy Festival of Denmark

Danish Industry Calls for Voluntary Electricity Market Contracts

23 May 2023
Topic — This consultation seeks views on reforming the European Union's electricity market design rules.
Message — The organization recommends a technology-neutral approach to grid operation and insists that price support contracts remain voluntary. They also urge removing mandatory state-backed guarantees for power purchase agreements to prevent market distortion.123
Why — A market-driven approach avoids administrative burdens and prevents artificial price imbalances for energy companies.4
Impact — Vulnerable households and smaller businesses could lose direct price protections during future energy crises.5
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Meeting with Christel Schaldemose (Member of the European Parliament, Shadow rapporteur for opinion)

23 May 2023 · (APA) NZIA

Meeting with Niels Fuglsang (Member of the European Parliament, Shadow rapporteur for opinion)

15 May 2023 · (APA) Critical raw materials

Meeting with Margrete Auken (Member of the European Parliament, Shadow rapporteur)

4 May 2023 · UWWTD

Response to Virtual worlds, such as metaverse

2 May 2023

The Confederation of Danish Industry support the European Commission with their upcoming initiative on virtual worlds. However, it is crucial that the Commission maintains an appropriate balance, ensuring equitable distribution of benefits across value chains, industries, and users. It is imperative that the EU framework fosters, rather than hampers, competitiveness, and the drive for continued innovation in this rapidly evolving domain. Please see attached our position paper.
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Meeting with Karen Melchior (Member of the European Parliament)

2 May 2023 · Roundtable Discussion

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

2 May 2023 · Discussion with stakeholders on major challenges to kegs and large appliance transport packing in suggested regulation; including Carlsberg, IBEC, BSH Hausgeräte GmbH, ZVEI, DI and Danish Embassy to Bruxelles

Meeting with Margrethe Vestager (Executive Vice-President) and

25 Apr 2023 · Net Zero Industry Act and bio solutions

Danish industry warns against costly new chemical labelling requirements

30 Mar 2023
Topic — The EU is revising rules for classifying, labelling, and packaging hazardous chemical substances.
Message — DI requests that grouping substances for classification follows strict scientific principles. They also oppose new minimum font sizes for large packaging and demand aligned transition periods.123
Why — This would prevent massive expenses for new industrial printers and administrative burdens.45
Impact — Consumers in smaller markets may lose access to certain specialized products.6
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Meeting with Karen Melchior (Member of the European Parliament) and Volvo Car Corporation AB and A.P. Møller - Mærsk A/S

14 Feb 2023 · Conference with Nordic Confederations of Industries and NGOs on CSDDD

Meeting with Ilan De Basso (Member of the European Parliament) and Confederation of Finnish Industries EK and Volvo Car Corporation AB

14 Feb 2023 · Seminarie

Meeting with Emma Wiesner (Member of the European Parliament) and Confederation of Finnish Industries EK and Confederation of Swedish Enterprise

14 Feb 2023 · Regler för företagens ansvar i värdekedjan (due diligence)

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Confederation of Finnish Industries EK and Confederation of Swedish Enterprise

14 Feb 2023 · Corporate Sustainability Due Diligence

Meeting with Niels Fuglsang (Member of the European Parliament)

7 Feb 2023 · Energy

Meeting with Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

6 Feb 2023 · Competitiveness, Inflation Reduction Act, state aid, 30 years of Single Market, energy policies

Meeting with Niels Fuglsang (Member of the European Parliament)

1 Feb 2023 · Tax issues

Danish Industry seeks longer timeline for cyber security rules

23 Jan 2023
Topic — The consultation addresses mandatory cybersecurity requirements for digital products sold within the EU.
Message — DI requests extending the implementation period to 48 months and relaxing the 24-hour incident reporting window. They also argue that detailed software lists should remain confidential to prevent hackers from identifying vulnerabilities.123
Why — Extended deadlines and simplified reporting would reduce the enormous pressure on companies to comply.45
Impact — Public safety agencies lose immediate visibility into exploitable vulnerabilities if reporting is delayed.6
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Meeting with Marta Balossino (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

19 Dec 2022 · Trade and Technology Council, Inflation Reduction Act, state aid, sovereignty fund, 30 years of Single Market

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

28 Nov 2022 · Strategy for Sustainable and Circular Textiles

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager) and Orgalim – Europe's Technology Industries

28 Oct 2022 · EU Chips Act, SMEI, Data Act.

Danish industry urges global alignment on new chemical hazard classes

18 Oct 2022
Topic — Revision of EU rules on the classification, labelling and packaging of hazardous chemicals.
Message — DI calls for hazard classes to align with international UN standards to protect competitiveness. They recommend adopting the WHO definition for endocrine disruptors and using validated data to avoid repeat studies.12
Why — The organization would avoid redundant testing expenses and gain legal certainty through clearer definitions.34
Impact — Chemical users and regulatory bodies lose if safety communication becomes ambiguous or inconsistent.5
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Meeting with Christina Holm Eiberg (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

8 Sept 2022 · Current geopolitical challenges.

Response to Review of the de minimis aid Regulation

12 Jul 2022

The Commissions call for evidence aims to address two main aspects in the de minimis regulation: the amount of the de minimis threshold; and the transparency requirements. The Confederation of Danish Industry (DI) welcomes the opportunity to comment on this public consultation. The comments below may be published and does not contain confidential information. Ad. the amount of the de minimis threshold: Regarding de minimis aid threshold DI has previously held that the current levels should be maintained. Especially in sectors with overcapacity – in combination with many smaller undertakings – even small aid amounts could risk creating distortions of competition and affecting trade between Member States. However, considering inflation for 2014-2030 and reflecting economic developments DI can support an increase of the threshold to no more than 250.000 Euro. Ad. the transparency requirements: DI believes that a mandatory central register will increase transparency and lower administrative burden and legal uncertainty for companies that are currently subject to a self-declaration system. This is particularly important for small and micro-enterprises, which usually have less capacity for administrative tasks. A mandatory register will also be beneficial for larger companies structured in groups, where de minimis aid must be cumulated at group level. Hence, DI highly welcomes a mandatory central register because it will significantly reduce administrative burdens for companies and reduce the risk of exceeding ceilings. To further increase transparency DI believes it would useful that Member States should report to the Commission on the application of the de minimis regulation on a yearly basis. Such annual de minimis reports should be made public on the Commission’s website. This would make it easier to assess and analyse the overall level and effect of de minimis aid on competition in the different member states. Supplementary comments DI believes there should be a reference to the European Court of Justice's Deggendorf case-law in the de minimis regulation article 1, clearly stating that de minimis aid will not be applicable to companies, which are subject to an outstanding recovery order following a previous Commission decision declaring the aid illegal and incompatible with the common market. Such a reference would be in line with the Commissions intention to integrate the Deggendorf principle into all forthcoming State aid rules and decisions. Hence, DI would propose the following wording of a new article 1 (f): “This Regulation shall not apply to aid which do not explicitly exclude the payment of individual aid in favour of an undertaking which is subject to an outstanding recovery order following a previous Commission decision declaring an aid granted by the same Member State illegal and incompatible with the internal market.” DI would also suggest introducing a state aid hearing officer to safeguard the effective exercise of procedural rights throughout state aid proceedings before the Commission. A similar hearing officer initiative already exists in merger and antitrust proceeding. DI believes it would be useful to elaborate on the notion of aid to export-related activities, (which is excluded from the de minimis regulation), because the interpretation of what constitutes export aid seems to create problems in practice for some aid granting authorities. Finally, more should be done to raise awareness of the State aid rules in general and to help Member States, businesses and citizens interpret the rules. The platform e-State Aid Wiki, the Q&A-portal between the Commission and the Member States, could play a more important role in this respect, for example by publishing the questions and answers (whilst respecting confidentiality) not only for public authorities but for all stakeholders, and by providing clear information about relevant procedures. DI's full response (in English) is attached.
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Meeting with Frans Timmermans (Executive Vice-President)

30 Jun 2022 · European Green Deal and energy transition

Response to Sustainable Products Initiative

22 Jun 2022

Confederation of Danish Industry supports the proposed Ecodesign for Sustainable Products Regulation (ESPR). Overall, we find that the proposal if implemented according to the good intentions will strengthen the Single Market, push for more circular products in the EU and create more transparency in the value chain. However, the success of the implementation of the ESPR depends the proportionality of the specific requirements - on keeping administrative burdens to a minimum, protecting confidential business information and a strong market surveillance effort in the Member States. Please see attached for further reflections.
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Danish Industry warns complex fuel rules may block investment

17 Jun 2022
Topic — This consultation defines how to calculate greenhouse gas savings for renewable transport fuels.
Message — Danish Industry requests simpler formulas and aligned regulations to ensure rules are workable. They also want permission to allocate different emission intensities to various fuel types.12
Why — Clearer regulations would provide the certainty needed for firms to finalize major investments.3
Impact — Environmental advocates lose if inconsistent rules permit greenwashing of hydrogen and fuel products.4
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Response to Single Market Emergency Instrument (SMEI)

11 May 2022

General comments (more detailed comments included in the attached PDF) The Confederation of Danish Industry (DI) supports the European Commission’s ambi-tion to enhance the resilience of the Single Market’s four freedoms in future times of cri-sis. We agree that crisis-mitigating measures should be readily available – under strict criteria – and swiftly applied. This requires a clear legal framework at EU level. In this regard, we welcome the upcoming proposal for a Single Market Emergency Instrument (SMEI). The scope of SMEI should be narrow and focus on the protection of the Single Market freedoms under specific crisis conditions. SMEI should also facilitate an open dialogue among the European Commission, Member States and key stakeholders in order to ad-dress unforeseen crisis-related challenges in a swift and coordinated manner. Conversely, the scope of SMEI should not be broadened to also include objectives related to the EU’s industrial, trade or health policies. In DI’s opinion, it is important to avoid duplication. Enhancing the strategic independence of Europe’s economy is better ad-dressed with dedicated legislative and non-legislative tools in their relevant policy do-mains. Consequently, SMEI should be sharply focused on short-term, crisis-related resil-ience of the Single Market. The provisions of SMEI should be designed with proportionality in mind, e.g. with re-gards to crisis-related obligations for companies. Furthermore, the instrument’s defini-tion of “crisis” must be clear and precise, even as it encompasses different types of crises. European companies have faced persistent burdens brought about by “temporary” crisis measures becoming de facto permanent – both in Europe and abroad. Examples include trade restrictions imposed as a response to the global financial crisis in 2008 and per-petual suspension of border-free travel within parts of the Schengen Area. SMEI should be carefully designed so as not to impose such long-lasting barriers to any of the four freedoms once a particular crisis has passed. Finally, DI would like to emphasize the central importance of pan-European and interna-tional value chains for European businesses and their employees. SMEI should do as much as possible to maintain the conditions for open and flexible flow of goods, compo-nents, and employees across borders. Any tools that seek to respond to a crisis by limit-ing the availability of such value chains must be proportional, thoroughly justified, and short-lived in nature.
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Response to A New European Innovation Agenda

10 May 2022

Innovation is a key element in dealing with the green and digital transition as well as solving societal challenges. Innovation needs to be done easily without regulatory barriers. The initiatives described have the potential to increase the innovation power of the EU and has our full support. Innovation is particular required in areas that support the green transition. Biosolutions represent such an area. Not only are biosolutions an area undergoing rapid development, in Europe and abroad, it is also a sector which holds significant potential as an enabler for sustainability in sectors such as the food sector, agriculture and industry. Unfortunately, the current EU regulatory landscape is not fit for purpose to facilitate innovation. The enclosed comments specifically focus on biosolutions, however the same political messages are relevant for a range of sectors and EU policy areas.
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Meeting with Mauri Pekkarinen (Member of the European Parliament) and Confederation of Finnish Industries EK and

2 May 2022 · Current EU industry affairs

Meeting with Christel Schaldemose (Member of the European Parliament) and Confederation of Finnish Industries EK and

2 May 2022 · industri- og konkurrencepolitik

Meeting with Morten Petersen (Member of the European Parliament)

20 Apr 2022 · Fit for 55 Package

Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

6 Apr 2022

The Confederation of Danish Industries (DI) appreciates til opportunity to comment on the proposed amendments to the standardization regulation (EU) 1025/2012. The amendments strengthen the national delegation principle. It is a principle that DI supports as it is a well-proven principle that also increases inclusiveness of societal stakeholders and SMV's. Although we understand the rationale behind the amendments and support them, we also have concerns we believe need to be considered finalizing the wording and when implementing the text. Our main concern relates to the impact the amendments will have on the attractiveness of participation in European standardization for those parties who will lose influence, when the national delegation principle is applied across the board. Their contributions to the development of state-of-the-art technical solutions in the form of hEN’s are significant. Their importance when it comes to ensuring global take-up of the European standards and their integration into non-EU national law equally high. We need to ensure the new text allow for them to contribute to the development of the published harmonised standards and ensure they remain interested in participating under the new voting rules. Important aspects in this regard are agility of the system, fast speed to market in the form of published harmonised standards and a degree of flexibility when it comes to interpretation of formal requirements the standards need to fulfill (content and design). If we do not succeed we risk undermining European standardization to the benefit of international standardization, which would be counterproductive to the overall aim of the standardization strategy, including the amendment of the standardization regulation. Due to the great impact the changes potentially have on the deliverables of European standardization one could argue for the need for a more thorough assessment before the changes are implemented.
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Meeting with Margrethe Vestager (Executive Vice-President)

29 Mar 2022 · Current European Affairs.

Response to Amendment on Own Resources Decision

4 Mar 2022

New own resources DI considers the green and digital priorities of the EU’s budget and recovery plan to have great importance for growth and competitiveness. Therefore, DI agrees with the need for sufficient resources at EU level that ensure stable funding for strategic investments. However, possible new own resources should not lead to higher taxation of companies. The number of new own resources at EU level should therefore be limited and offset in the taxation of companies at national and local/regional level. Companies are already paying taxes and levies at local/regional, national and EU level. If more layers of taxation are applied, it will complicate how to politically decide on tax level adjustments. Revision of EU Emissions Trading System (ETS) DI supports further tightening and enlarging the ETS proposed by the Commission. Increasing ambitions in the ETS will facilitate larger CO2-reductions and increase revenues from auctioning of allowances. Today, most of these revenues are circulated back to the member states based on their respective shares of CO2-emissions in 2005-2007. DI supports the inclusion of transportation and buildings into the ETS regulation - so-called “ETS2”. The proposal from the Commission to create a Social Climate Fund financed via auctioning revenues from ETS2 is sensible. It is important to direct the fund towards green initiatives like energy efficiency, renovation, and electrification rather than passive income support. DI would therefore like to see further assessments of the fund and the coherence to other EU funding mechanisms. Carbon Border Adjustment Mechanism (CBAM) DI welcomes the objective of CBAM, namely adding a CO2-price signal to non-EU competitors who operate in the EU, thereby ensuring a level-playing field for ETS installations and an incentive to reduce emissions in companies outside the EU. However, it is key to maintain full carbon leakage protection during and after implementation of CBAM. DI therefore supports the proposal in the draft CBAM report to assess the impact on the EU’s exports and competitiveness. This review of competitiveness should be integrated into, or combined with, the proposal to set up a reservation and review mechanism of the phase-out of free allowances in the draft ETS report. DI also urges that revenues from CBAM are used with similar objectives as the revenues from auctioning of ETS allowances. Today, member states receive a national share of the ETS auctioning revenue. CBAM revenues should be distributed to member states based on similar principles. DI urges the Commission to present an impact assessment of changes in revenue streams when CBAM is implemented. Reform of the international corporate taxation framework Pillar One of the OECD/G20 Inclusive Framework international tax agreement will reallocate the right to tax a share of residual profits of the world’s largest multinational businesses from the country of residence to the market countries. The Commission proposes an own resource equivalent to 15% of the share of the residual profits of in-scope companies that are reallocated to member states. The residual profits constitute the tax base, and we therefore assume that the 15% is of the tax calculated on this base. However, some member states will lose net tax revenue following this reallocation of taxing right to the market countries. These member states will thus already give up more tax revenue than they get back. Continued support for the international tax agreement is extremely important for the sake of international legal order and cannot be taken for granted. Forcing member states that are already losing on Pillar One to give up an even larger share of tax revenue as an EU own resource does not seem fair and could jeopardize support for the international agreement. For these reasons, DI is very skeptical about the proposal to use Pillar One of the international agreement as basis for a new own resource for the EU.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Confederation of Danish Industry (DI) on call for evidence on EU Waste Framework DI strongly supports the measures in the Waste Framework Directive and the political commitments in the European Green Deal and the Circular Economy Action Plan the crux of which we consider ensuring high quality recycling. Representing close to 20.000 Danish companies, we believe that more and better recycling has economic as well as environmental potential for Europe. Essential to reach the potential is strengthen the Single Market for secondary resources. We recommend including the following themes in a review of the WFD in order to strengthen the Single Market and circular economy in Europe through high quality recycling: • Harmonized waste collecting and sorting criteria in the EU. From producers’ perspective as well as from recyclers’ perspective scale is essential. Harmonized criteria will make it easier to market the same products and packaging across the EU. For recyclers harmonized collecting and sorting criteria will equally improve the business case of recycling, making secondary resources more attractive as commodities, furthering the circular economy. • Harmonized criteria for modulated fees in EPR schemes. National regulation to promote specific materials or designs are effective barriers to the Single Market. While DI supports extended producer responsibility as a method to implement the producer pays principle, we find that implementation across the different member states must be conducted in a harmonized way, not least when it comes to the modulated fees. • Modernizing the waste hierarchy. Differentiating the category of ‘recycling’ to differentiate between high and low quality of recycling will lead us closer to the ideal of the circular economy, reducing the demand for new resources, delivering on environmental and climate goals as well as making more (secondary) resources readably available for companies. • Waste prevention targets. Waste prevention targets will incentivize member states’ initiatives to further circular economy and help boost incentives and initiatives to promote moreGreen Public Procurement and more circular business models. • Better documentation for waste treatment across countries. A lot of waste is shipped from one country to the other in order to be recycled and sometimes through a number of waste facilities. This is good. However, we need an effective common way in which to document the treatment of the waste in order to make sure what amounts of waste have been recycled to which level of quality. We recommend that the WFD provide a detailed way in which to provide this documentation, thus making it easier and cheaper for all the facilities across the EU to set up their plants to provide that level of documentation as well as increasing overall confidence in the documentation.
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Response to Review of the general product safety directive

4 Oct 2021

To whom it may concern, On behalf of the Confederation of Danish Industry, I would hereby like to submit our comments on the Commission's proposal for a General Product Safety Regulation (attached). DI supports the European Commission’s initiative to update the existing General Product Safety Directive (GPSD) as well as its transformation into a regulation (GPSR). There is a need to improve the rules regarding product safety in the Single Market while simultaneously ensuring a more consistent implementation. However, the current proposal goes far with regards to the products covered as well as the obligations for economic operators to be imposed. Furthermore, DI fears that the new regulation would lead to unnecessary complication of the rules that govern product safety in the Single Market. In the attached document, we touch upon several concrete elements in the proposed regulation that DI deems particularly problematic. Please do not hesitate to get in touch about any questions you may have. Best regards, Stanislav Stanchev
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Danish Industry urges digital labels to simplify chemical information

20 Sept 2021
Topic — This consultation addresses the simplification and digitalization of chemical labels in the EU.
Message — DI suggests hazard labels keep as a minimum those elements important for safe use. Mandatory elements should be reduced, with further information like translations kept in a digital format.12
Why — This approach would reduce administrative costs and improve the competitiveness of the EU chemicals industry.3
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Response to Revision of the Machinery Directive

16 Aug 2021

Please enclosed find comments by the Confederation of Danish Industry.
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Response to Standardisation Strategy

9 Aug 2021

Please enclosed find the contribution of the Confederation of Danish Industry.
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Response to Revision of Non-Financial Reporting Directive

14 Jul 2021

DI generally supports a more consistent and comparable sustainability reporting on a global level. We therefore believe that the review of the former Non-Financial Reporting Directive as proposed with the CSRD is very timely. It should be recognised that with the NFRD, the EU went to the forefront of sustainability reporting. The proposed CSRD is a very significant second step, that can potentially bring the EU back into the forefront. However, we do believe that there are important balances and considerations that need to be observed in order to achieve this aim in the most cost-efficient manner. We are highly concerned that the some of the choices taken in the proposal on specific issues will rather turn the reporting into a very costly compliance exercise essentially resulting in a set-back in the reporting in Denmark – and in Europe. Consequently, we would like to focus the attention on important details that - if adjusted - we believe will ensure the balance and also ensure that the end result will not only provide a more robust reporting, but will also support the transition of the economy. These details are outlined in the attached document and covers the following areas: - The importance of ensuring that sustainability reporting provides value – not only data points - Development of European principles based reporting standards - Distinct regulation for listed and non-listed companies is desirable - Specific concerns regarding the removal of exemptions for consolidation - Specific concerns regarding the areas of reporting
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

DI and our more than 16.000 member companies, all in the non-financial sector, are committed to integrating sustainability in the core of their business strategy and models, and the Taxonomy Regulation can – if designed appropriately - effectively support the efforts to finance the Green Deal ambitions. However, the disclosure requirements can also undermine the purpose and not only create a compliance burden by itself but also undermine the financial reporting in the process. Therefore, finding the right balance is essential, and we do not believe the current proposal strikes the right balance. In our comments below we suggest a way forward that provides the information necessary for the investors and also support the transition based on the proposed delegated act without giving the non-financial business any undue burdens and without undermining the financial reporting. Our key points are the following: The level of detail in the suggested, mandatory templates in Annex II for the KPIs of non-financial undertakings goes beyond what is necessary for the financial market participants to fulfill their reporting requirements. We believe that o Taxonomy eligible and aligned activities should be reported as one line including specification on the substantial contribution criteria o Taxonomy eligible but not aligned activities should be reported as two numbers (the absolute value and the proportion) only (similar to non-eligible turnover). No further details should be mandatory o Non-eligible turnover should be reported as proposed. The length of the investment plans for the first period should be allowed to align with 2030-targets. These are the targets many companies works towards. It should be noted, that the actual percentages of Capex/Opex still depends on actual expenditures and without this alignment we may actually see delays in investments until the point where the investments can be covered by the plan. The DA does not reflect the need to include materiality assessments well-known throughout the financial reporting. We believe that the reporting requirements should be better aligned to the financial reporting requirements. For instance the IFRS 8 on segment reporting operates with a 10 percentage threshold before identifying individual segments. A similar approach is needed when discussing the activity level reporting (if retained). Without this, the reporting will not only become very detailed but will also expose business-sensitive information, especially for innovative and new initiatives. Further, this level of reporting detail is not needed for the financial market participants and was not envisaged in the agreement. The requirements for providing the key performance indicators covering the previous five reporting periods (article 9(3)) poses a number of challenges given the dynamic nature of the underlying taxonomies. The issues about comparability needs to be addressed in the delegated act. We do not believe that companies should be required to recalculate KPI’s for previous years when the taxonomies are adjusted – and therefore the DA need to explain how to communicate the dynamic nature of the underlying criteria (and consequentially the challenges in comparing the KPI’er for a five year period). The definitions in the delegated act regarding CapEx and OpEx are not clear and leaves business with more questions than answers, making it extremely difficult to build up the reporting. Transitional measures: We are supportive for the necessary transitional measures proposed in the DA. With the current timing of the delegated act combined with the following formal approval process, non-financials are not in a position to report in detail on the financial year of 2021. Simply providing the proposed details will pose a challenge. More fundamentally, the proposed reporting regime is not supported by the current internal reporting structures, and in many instances new internal reporting structures have to be build.
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Danish Industry warns against EU-only chemical hazard labelling

31 May 2021
Topic — The EU is revising rules for classifying, labelling, and packaging chemical substances and mixtures.
Message — Hazard identification should not cause chemical exclusions without risk assessments and socio-economic reviews. The EU should align with global UN standards instead of creating separate hazard classes.12
Why — Global alignment prevents trade barriers and avoids costly re-labelling across the supplier chain.34
Impact — Citizens and environmental groups lose early protection from harmful effects like endocrine disruption.56
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

31 May 2021

DI welcomes the possibility to submit our feedback. In general, DI - advices the Commission to strive for a coherent regulation of chemical risks across regulations and to avoid overlapping regulation for chemicals - acknowledges that REACH is the data generating regulation and supports the wish from the Commission to let data on e.g. environmental footprint flow into sustainability measures - reminds the Commission that a stronger enforcement across Member States is needed to ensure fair competition - welcomes the effort to improve the availability on documentation of health and environmental impacts of chemicals for industries along the supplier chain. Revision of the registration requirements: Introducing a parameter on environmental footprint in the registration process of chemical substances might support industry’s need for reliable data on the production and documentation of sustainable products. This would however require a methodology that also takes relevant steps of the lifecycle into considerations. Requiring Chemical Safety Reports on smaller tonnages (1-10 tpa) would be an extra burden on industry. Specifically, it would hamper innovation by setting a requirement which will disincentivise experimentation and delay innovative products to enter the market. Registration of polymers will be a new challenge to several industries and should be limited to groups of polymers of concern. The data set required for registration of such polymers should be designed for polymers and be specific on health and environment in order not to put on unnecessary burdens on industry by requiring all parameters in the standard data set for registration. Obtaining data on all parameters would be an extremely demanding process with high costs, long time horizons and a large number of test animals without necessarily generating data to the benefit of society. Introduction of a Mixture Assessment Factor (MAF): The Commission and ECHA suggest introducing a generic Mixture Assessment Factor to take possible combination effects into account. A generic MAF is not preferred. An impact assessment is needed to evaluate where appropriate and relevant to protect consumers against cocktail effects. Revisions of the provisions for dossier and substance evaluation: In general, DI welcomes development and acceptance of reliable non-animal tests. We encourage the Commission to ensure research funding for the development of reliable in-vitro tests to replace animal tests in order to speed up the registration process and give industry and society access to a faster decision on tests, lower costs, and swift access to relevant data. Decisions on additional testing requirements at member state levels should be made in a transparent and consistent way. Reforming the authorisation and restriction processes: DI supports the Commissions wish to review the authorisation and restriction process and to push the regulation from authorisation into restriction of the most hazardous chemicals. Restrictions might be better placed in other regulations than REACH taking in mind that overlapping regulation should be avoided. When allowing essential uses of certain substances in consumer products, it will be imperative to allow specific uses of specific substances and not to exclude specific sectors from using specific groups of chemicals. A transparent process for assessing essentiality should be established to ensure regular updates that reflect the development of the society and available technologies. Revisions of provisions for control and enforcement One of the top priorities for both EU and DI is to ensure a level playing field for European industry when protecting consumer’s health and the environment from hazardous chemicals. DI reminds the Commission that a stronger enforcement across Member States is needed to protect equal market conditions, and to ensure that non-EU products fulfill the same standards when entering the European market.
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Meeting with Asger Christensen (Member of the European Parliament)

11 Feb 2021 · Tobacco Products Directive

Response to Revision of EU rules on food contact materials

29 Jan 2021

CONFEDERAtION OF DANISH INDUSTRY (DI) FEEDBACK ON ROADMAP TO REVISE EU RULES ON FOOD CONTACT MATERIALS The Confederation of Danish Industry (DI) appreciates this opportunity to provide feedback and support the revision of rules on FCM. In brief, DI: - Strongly supports harmonization of the rules regulating FCMs put on the European market in order to safeguard the health of citizens and strengthen the internal market. - Advices the Commission to consider mandating Nordic-style declarations of compliance for all FCM, including harmonized testing regimes. - Reminds the Commission that enforcement is needed, especially when it comes to FCM sold directly to EU citizens from countries outside the EU. - Advices the Commission to strive for a coherent legislative framework that promotes sustainability across policy initiatives, also for FCMs DI SUPPORTS FULL HARMONIZATION OF FCM RULES DI commends and supports the prioritization of FCM in the Farm to Fork strategy, The Chemicals Strategy for Sustainability and other policy initiatives. Industry organizations and businesses have long advocated for a higher degree of harmonization, which will lead to decreased costs of doing business and increased protection of consumers. DI recommends the Commission follow option 1 listed in the inception impact assessment and expand on the existing regulation 1935/2004. It has been documented that the “positive list approach” to regulating of polymers, and additives in polymers, is cumbersome. But it provides legal certainty for businesses and equal footing for all producers on the market. A reprioritization of evaluation efforts and allocation of appropriate funds to EFSA and other bodies would go a long way to ensure positive lists become exhaustive, scientifically sound and up to date. We believe this avenue will provide the greatest benefits in terms of health and an efficient internal market. DECLERATIONS OF COMPLIANCE (DoC) DI fully supports the move to improve quality, accessibility and reliability of data in the supply chain of FCM. With harmonized rules, ensuring compliance will become simpler for businesses. Standardized DoC’s will reduce transaction costs and heighten the protection of citizens, but it requires a clear and unambiguous set of rules. Therefore, DI recommends the Commission investigates if mandating standardized compliance schemes is a realistic option. The Nordic countries operate with DoCs for all FCM based on a combination of national legislation and EU-rules, but a further harmonization, including harmonized testing regimes and substance thresholds, would strengthen the legitimacy of declarations. The Nordic DoC scheme could serve as a starting point when exploring the potential paths towards standardized DoC’s. CONTINUED AND STRENGTHENED FOCUS ON ENFORCEMENT Harmonization of rules and standardization of DoC’s will go a long way to ensure compliance. But enforcement and willingness to apply sanctions in cases of non-compliance is needed. Enforcement is a national competency, but EU has proven tools such as the RAPEX system can assist national authorities. Additional modes of supporting national enforcement authorities should be investigated. SUSTAINABILITY WITHOUT COMPROMISE The top policy-objective of both DI and the EU is to move towards a sustainable, circular and equitable economic system, which works for both people and planet. Sustainable production, consumption and recycling of packaging and other FCM play a central role in delivering on this promise. However, the health and safety of citizens cannot be jeopardized in the name of sustainability. Therefore, DI insists that the Commission takes into account the coherence between food-safety and sustainability legislation to ensure that unwanted and unknown substances are not recycled or reused in FCM. This includes limiting the use of recycled materials in food contact to those that do not pose a threat to human health.
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Meeting with Margrethe Vestager (Executive Vice-President)

29 Jan 2021 · COVID19 recovery plan

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Please find in attachment the submission to the consultation by the Confederation of Danish Industry.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

DI, the Confederation of Danish Industries, appreciates the opportunity to comment on the Commissions Roadmap regarding the evaluation of the New Legislative Framework (NFL). Our response to the consultation is organized as follows: 1. General considerations regarding the NLF 2. Reflections regarding the questions the Commission suggests the evaluation includes Please see the attached file for our comments. Furthermore, DI wants to express our support for the contributions of BusinessEurope and Orgalim.
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Meeting with Margrethe Vestager (Executive Vice-President)

6 Nov 2020 · Europe's digital transformation

Meeting with Nicolas Schmit (Commissioner) and

29 Oct 2020 · Pact for Skills Roundtable with the tourism sector

Meeting with Thierry Breton (Commissioner) and

29 Oct 2020 · Pact for Skills: Roundtable with tourism sector

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Thank you for this opportunity to briefly comment on this combined evaluation roadmap/inception impact assessment. DI would like to emphasize the key role of energy efficiency in building a carbon neutral EU economy. The current state of affairs indicates, that implementation must be improved in many Member States. Identifying market failures and barriers is an important first step to yield the cost efficient EE potentials in the various sectors in EU's and the Member States sectors. For DI, the current EU 2030 target design is a plausible point of departure. DI support increasing EU's 2030 climate ambition to at least 55 per cent. Further deployment of energy efficiency solutions and renewable energy is no regret options - just like efforts to increase electrification and and sector integration. Energy efficiency can be the glue that allow the EU to continue its decarbonization - provide the economic EE potentials in industry and buildings are identified and harvested. Lack of finance, guidance and training must be dealt with, and is not addressed sufficiently by an overall EE target. Likewise EU's energy renovation wave is key to set free further potentials to modernize EU's building stock, improve the climate impact of buildings as well as the functionality for its users. DI believe there is a room to further increase EU's renewable and energy efficiency targets as part of an increase EU climate ambition. Those targets must together form a cost-effective and cohererent target system - and the EU ETS should play a key role as well. Considerations to increase the scope of the EU ETS with some kind of inclusion of transport and building into the EU ETS must be considered - identifying pros and cons. Market price signals cannot stand alone - and further qualitative measures like education, information etc. is important. Also, efforts to better understand the footprints of materials and circular economy potentials is of utmost importance. The many findings and recommendations in the 14 Danish Climate Partnerships' identifies energy efficiency lessons learnt, further technical and economic potentials. DI will be pleased to share these findings and to engage in constructive dialogues with the EU-Commission and other interested stakeholders.
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Response to Revision of the Urban Wastewater Treatment Directive

8 Sept 2020

Confederation of Danish Industry (DI) fully supports the Commission’s initiative to revise the UWWTD and its road map for an impact assessment. The UWWTD should contribute to a clean and more circular/resource efficient and climate adapted economy in EU. DI supports that the overall context of the UWWTD is linked to the EU Strategy for Energy System integration supporting energy efficiency, and energy production. Furthermore, the revised UWWTD will support the Circular Economy Action Plan on recovery of resources. Updated environmental targets and measures will support the fulfilment of the WFD and contribute to the 2030 Biodiversity Strategy. DI supports the list of problems that the initiative aims to tackle. Concerning the contaminants of emerging concern (CEC), it is important to consider how the UWWTD can contribute to the WFD goals. It is important to study if actions towards point sources or actions towards diffuse contamination of wastewater are to prefer. The Commission should study a differentiated approach on how this issue is best tackled. If point sources could be reached through installation regulation (e.g. IED), if it is a question of regulation of products, or if it will be the best solution environmentally and financially if the CECs are treated at the WTP. It is important to study if central or decentralized solution should be applied. A risk-based model is a good approach leaving operators to implement the most efficient multi-purpose measure in their local area along with the fulfillment of environmental targets of the directive. It is important that the water sector is supported by a strong and sustainable financial structure, securing recovery of costs and sufficient investments in the necessary infrastructure and management. DI supports the list of objectives and policy options to take up and investigate in the impact assessment. We would like to emphasize overflows in wastewater systems. Recent Danish research has shown new and more price efficient methods using modern monitoring systems. As mentioned, a cost recovery regime to support investments, maintenance end management is crucial. The evaluation of the directive recovered that several member states lack behind in the implementation of the existing directive. The wastewater sector in Europe still lacks investments. The establishment of a Green Taxonomy for water and marine resources could support channeling investments into the sector, if the Green Taxonomy for water og circular economy will also address wastewater. Methods for fulfilling updated monitoring obligations and updated reporting requirements should be open for digitalization and use of sensors. Furthermore, implementation and use of modern digitally based management systems is a basis for a higher energy efficiency in WTP, optimized water treatment operations, and lower greenhouse gas emissions. Monitoring and reporting are also facilitated with digital solutions. DI agrees with the initiative to improve recovery of resources from wastewater streams to support the circular economy also considering the Sewage Sludge Directive and where its “aquis” is taking over. Energy audits and recommendations for treatment plants could be an efficient tool to raise efficiency in the sector. Benchmark tools can help operators to identify the best solutions and tools. The wastewater sector should be streamlined to tackle its contribution to climate gasses emissions; e.g. CO2, N2O.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

Sewage sludge from municipal wastewater treatment plants contains beneficial nutrient for agriculture as well as potentially harmful substances. Especially, this counts for phosphorous which is a non-renewable resource and therefor important to move forward to a circular economy. But at the same time, we need to protect humans and the environment from harmful substances. The existing sludge directive is among the oldest pieces of legislation in EU, and certainly need a revision to cope with todays knowledge on substances and their effects. We would like to stress that there is an interlink between the revision of the Urban Wastewater Treatment Directive (UWWTD) and the Sludge Directive, as sludge is a result of the treatment processes at the treatment plant. Therefor the sludge directive must include limit values for not only heavy metals (that needs significant reductions) but also environmental harmful organic substances introduced in the UWWTD and maybe even pharmaceuticals as well. This must be based on solid scientific evaluation of the introduced substances. A revised directive should in addition promote extended use of anaerobic digestion. Production of methane from sludge provides the water sector with a climate benefit to society when used as an energy source and helps to reduce greenhouse gas emissions overall. DI therefor recommend an update in order to secure public acceptance and to protect the environment and humans - and the movement towards a circular economy
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Response to Chemicals strategy for sustainability

19 Jun 2020

The Confederation of Danish Industry (DI) represents more than 10.000 member companies of very different size and sectors, but all are committed and focused on sustainability and green growth. DI have developed a plan for the year 2030 which supports the Danish government’s ambitions to reach a CO2 reduction target of 70%. Chemicals play a big part in achieving that goal. Therefore, we welcome The Commission’s roadmap for a chemicals strategy for sustainability. It is our core belief, that the only way to achieve a true circular and climate-neutral economy is to close the loop and recycle materials without worrying whether legacy chemicals will hamper this ambition. DI is a member of the European chemical industri council (Cefic) and thus support the organization’s response to the roadmap. The central chemicals regulations at EU level (REACH, CLP, BPR, PIC etc.) have paved the way forward, but as the roadmap suggests, several challenges need to be corrected, particularly for SME’s, who find it difficult to comply with the data requirements. Further digitalization is part of the solution, but it should be introduced in a realistic way making it possible for SMEs to see themselves as part of the solution and give them the incentive for the extra effort needed. Small innovative startups which will be part of the European economy in the next decade, need help to comply with all the legislation, they should not be overly burdened. We find it particularly useful that the roadmap mentions simplification and strengthening of the legal framework. Downstream users of chemicals need transparency in their efforts to comply. Whether a substance is on the market in the foreseeable future is at the core of some of Europe’s most innovative businesses, which are expected to deliver the solutions needed in the green economy. We should strive for substitution of the chemicals that can be replaced in innovative ways, either by other less harmful chemicals or by designing products in new ways. Some chemicals, however, have technical and physical properties that cannot be substituted in a meaningful way, and if we truly want to implement technologies such as carbon capture utilization and storage, we need access to these properties.
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Meeting with Margrethe Vestager (Executive Vice-President)

19 Jun 2020 · To discuss industrial policy.

Response to A EU hydrogen strategy

8 Jun 2020

Please find attached DI Energy’s response to a EU Hydrogen Roadmap . The Confederation of Danish Industry has the following identification number in the EU Transparency Register: 5749958415-41
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Response to Strategy for smart sector integration

8 Jun 2020

Please find attached DI Energy’s response to a future EU strategy on energy sector integration. The Confederation of Danish Industry has the following identification number in the EU Transparency Register: 5749958415-41
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Response to EU rules on industrial emissions - revision

17 Apr 2020

The feedback from Confederation of Danish Industry is attached as a file.
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Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

7 Feb 2020 · Digital policy

Meeting with Margrethe Vestager (Commissioner)

26 Sept 2019 · Meeting on current European topics

Response to Fitness check of 2012 State aid modernisation package, railways guidelines and short term export credit insurance

7 Mar 2019

Fitness check - 2012 State aid modernisation package, railways guidelines and short-term export credit insurance The Confederation of Danish Industry (DI) is the largest Danish private business association. DI is funded, owned and managed entirely by 10,000 companies within manufacturing, trade and service industry. In its capacity of trade organization DI ensures that the Danish business community has the optimum basis for competing, developing and manufacturing in Denmark and internationally. DI welcomes the EC-Commissions fitness check of the 2012 State Aid Modernisation package and the in-depth analysis and evaluation of the state aid rules in an open dialogue with all interested stakeholders. DI will be pleased to participate in the process. The EC's state aid rules play an important role in the regulation of the internal market. State aid control is the result of the need to maintain a level playing field for all undertakings in the internal marked, no matter in which Member State they are established. Hence, DI endorses a transparent and effective state aid control. When a member state chooses to grant state aid, DI believes that the aid should continue to be well designed, targeted at identified market failures and objectives of common interest and least distortive. Regarding block exempted aid it should be noted that the Commission previously has revealed important compliance gaps, especially when it comes to block-exempted measures directly implemented at country level. Therefore, DI believes it is very important to further increase state aid discipline. In principle DI agrees, that actions before national courts can offer an important means of redress, which can bring immediate relief to the complainant affected by unlawful State aid. However, private enforcement is still quite limited. DI would urge the Commission to publish a guide/vademecum on the enforcement of State aid law at national level. The guide should address locus standi, damages etc. and present the information in a simple and comprehensive manner targeted undertaking. Such a guide would be a very useful tool for undertakings to safeguard free and fair competition throughout the Single Market. It is also central to raise awareness of the state aid rules at national level. Furthermore, it is important that the Commission continues its efforts to ensure a global level playing field, when subsidies granted by a third country would lead to a distortion of competition. In this regard DI endorses the Commissions active work on making trade agreements with substantive provisions on state aid. These are important steps towards better subsidies control taking into account the global situation. If further information is needed DI would be happy to elaborate on its views. Best regards, Morten Qvist Fog Senior Advisor and Head of Public Procurement Law
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Confederation of Danish Industry urges removal of titanium dioxide classification

8 Feb 2019
Topic — This consultation concerns proposed amendments to the chemical classification, labelling and packaging regulation.
Message — The organization requests removing titanium dioxide from the current legislative update. They demand a full impact assessment to evaluate alternative regulatory options.12
Why — This would avoid increased waste management costs and protect products' ecolabel status.3
Impact — Health advocates lose labels warning about potential respiratory hazards from dust inhalation.4
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

In general, the IED is working well in Denmark. We have known the legal basis for many years. The permission scheme in Denmark was the idea behind the IPPC - the predecessor to IED. We think it will be difficult to do a full evaluation of the IE di-rective. According to the directive it can take up to four years to implement a new BREF. During the last few years a large hand-ful of BREFs have been adopted, but the four year implementa-tion period is not yet over. Several BREFs are still not drafted and adopted. It will be difficult to evaluate seriously, what have been the environmental effects of the directive - and that must at the end be the most important issue. Regarding the procedural issues and the administrative bur-dens from the IED we have more experience - see attached document.
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Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and The Danish Chamber of Commerce and

6 Nov 2018 · DSM general, eCommerce, data, copyright

Response to Legislation on end-of-life vehicles - evaluation

1 Nov 2018

Dansk Industri (DI) ser revideringen af ELV-direktivet som en god mulighed for at sikre større harmonisering af den nationale implementering i alle EU-medlemslande. I forbindelse med revision af ELV-direktivet opfordrer DI til, at Kommissionen trækker på erfaringer inden for WEEE-området. Her er der etableret et europæisk netværk med navnet EWRN (European WEEE Registers Network). I dette netværk arbejder medlems-landenes relevante myndigheder og udførende instanser for, at WEEE-direktivet bliver implementeret nationalt med den størst mulige harmonisering mellem landene. Dette for at sikre en ensartet lovgivning for producenterne, hvoraf hovedparten driver paneu-ropæiske aktiviteter. Ensartet implementering i flest mulige lande giver en større effekti-vitet for producenterne. Et lignende europæisk samarbejde i forhold til både ELV- og BAT-direktiverne, vil gøre det lettere at samordne aktiviteter bl.a. i forbindelse håndtering af free-riders eller i for-hold til konkrete scopinganalyser. Både i forbindelse med WEEE-området og fremadret-tet i forhold til ELV og BAT anbefaler DI, at man i stedet for et uformelt netværk, som EWRN, opretter formelle netværk til koordinering af implementering og udveksling af erfaringer mellem landene. Reglerne i det nuværende ELV-direktiv fungerer som et godt værktøj til at fremme mere miljøvenligt design samt genanvendelse og genbrug af ELV. Regler i ELV-direktivet kan håndhæves i væsentlig bedre grad, end hvad der sker i dag i de enkelte medlemslande. Bedre håndhævelse af eksisterende regler vil derfor bringe os tættere på det overordnede formål.
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Meeting with Margrethe Vestager (Commissioner)

4 Jul 2018 · EU Current Affairs

Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

9 May 2018

Please see the consultation response from the Confederation of Danish Industry in the attached document. Best regards Lars Frolov-Hammer Leading Senior Advisor
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Meeting with Margrethe Vestager (Commissioner)

10 Apr 2018 · EU Current Affairs

Response to Proposal for a Regulation on Enforcement and Compliance in the Single Market for Goods (Goods package)

19 Mar 2018

Please find enclosed the Confederation of Danish Industry's response to the public consultation on the Goods Package and the proposal for a Regulation on Enforcement and Compliance.
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Response to More and better mutual recognition for the single market for goods (revision Regulation (EC)764/2008) (Goods package)

19 Mar 2018

Please enclosed find the contribution tof the Confederation of Danish Industry to the public consultation on the Goods Pacakge, specifically the proposal for a Regulation on Mutual Recognition
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Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

31 Jan 2018 · Commission's priorities for the rest of the mandate.

Meeting with Margrethe Vestager (Commissioner)

19 Dec 2017 · EU Current Affairs

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

13 Dec 2017 · Priorities of the Juncker Commission for the rest of the mandate.

Response to Evaluation of the Urban Waste Water Treatment Directive 91/271/EEC (UWWTD)

8 Nov 2017

The Confederation of Danish Industry (DI) welcomes the Commission's initiative to publish a road map for the evaluation of the Urban Waste Water Treatment Directive. Since the UWWTD was issued, new agendas have occurred in the wastewater area. To address the challenges of the 21. century items like livable cities, sustainable development in Europa and globally, the climate and energy impact of the UWWTD now set the frame for the forthcoming development. Eventually it is relevant to explore if the UWWTD contributes sufficiently to the fulfillment of the UN SDGs. In Denmark waste water treatment and urban waste water treatment utilities have gone through a process that has bought the sector closer to address the above mentioned issues. The Water Framework directive sets the overall goals for the water environment performance of the wastewater sector. In this context it is important that the polluter pays principle and the principle of pricing of water from the WFD are integrated in the evaluation of the UWWTD. A correct pricing of water promotes economic efficiency and innovation of new solutions. As effectiveness and efficiency are key points in the evaluation, it is important to investigate the efficiency and effectivenes of the UWWTD in term of input and output of energy – energy consumed and energy produces from e.g. sludge, and resources such as recovery of nitrogen and phospor. According to World Energy Outlook 2016, 4% of energy consumption arise from the water sector. This figure is estimated to double on a global scale. Therefore, energy is an important part of development and operation of sustainable wastewater treatment. Is the UWWTD supportive to promote energy effective Waste Water treatment? It is also mentioned in the road map, that the relation between UWWTD and the Sewage Sludge Directive schould be discovered. Confederation of Danish Industry supports this approach. As questions have been raised concerning treatment of waste water from hospitals and WWT efficiency towards medicine residues in waste water from households and the use of sewage sludge in agriculture, the resource question schould be addressed in future actions. The resource issue should also be qualified in a perspective of the circular economy package. Techniques to extract phosphor are available. Use of such techniques can enhance recovery, distribution and trade of recycled fertilizers. Does the UWWTD promote the right techniques for recovery of resources? Therefor it is important to look at not only efficiency in wastewater treatment following parameters as concentrations in pollution per cubic meter and the amount of water (m3), but in the whole input/output-model. The EU is a very effective mechanism for the memberstates to develop and communicate, but in Confederation of Danish Industry we are convinced that at close collaboration with the OECD will make analysis of economic structures and government in the water sector available to the EU Commission. Changes in climate and rain pattern across Europe result in new challenges for the sewers and treatment plants. How the UWWTD can support the necessary changes of the system to adapt to the climate changes shall be evaluated carefully. To sum up, DI recommends to evaluate carefully if new areas like energy efficiency, nutrient recycling and climate adaptation needs to be addressed more specific in the UWWTD. The themes innovation and focus on new approaches as well as Stakeholder involvement from the overall EU policy catalogue are not addressed in the evaluation road map for UWWTD. The evaluation could benefit from connecting to these themes.
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Response to Commission Implementing Regulation pursuant Art 16(8) of NIS Directive

9 Oct 2017

The Danish ICT and Electronics Federation welcomes the possibility to comment on the Commission Implementing Regulation pursuant Art 16(8) of NIS Directive. Our general view on the implementing regulation is an appreciation of the focus on a high common level of security of network and information system and at the same time a stressing of the need for a pragmatic implementation of the NIS Directive, which will not pose unnecessary or disproportionate administrative burdens for the businesses. Regarding article 4, 1 (e) it is stated, that an incident, which affects the provision of the services in two or more Member States has to be reported no matter the impact of the incident regarding unavailability, integrity, public safety, material damage etc. The Danish ICT and Electronics Federation strongly recommends the withdrawal of article 4, 1 (e), since it very easily could lead to unnecessary or disproportionate administrative burdens for the businesses in reporting insignificant incidents just because the incidents affects the provision of the services in two or more Member States. Our recommendation is alone the four other (a to d) and professional situations as reporting criteria.
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Meeting with Margrethe Vestager (Commissioner)

23 Jun 2017 · EU Current Affairs

Meeting with Cecilia Malmström (Commissioner)

27 Apr 2017 · current trade agenda

Meeting with Margrethe Vestager (Commissioner)

31 Oct 2016 · EU Current Affairs

Meeting with Andrus Ansip (Vice-President) and

16 Sept 2016 · Telecom review, free flow of data, e-privacy

Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

13 Sept 2016 · Regulatory environment for probiotics

Meeting with Margrethe Vestager (Commissioner)

7 Sept 2016 · EU Current Affairs

Meeting with Margrethe Vestager (Commissioner)

31 May 2016 · EU Current Affairs

Meeting with Miguel Arias Cañete (Commissioner)

11 Mar 2016 · Follow up to Paris and legislative agenda 2016

Meeting with Margrethe Vestager (Commissioner) and

25 Jan 2016 · Current European Affairs

Meeting with Bernardus Smulders (Cabinet of First Vice-President Frans Timmermans) and DIGITALEUROPE and

14 Jan 2016 · AECA Round-Table on “Dealing with Regulatory Burden

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

12 May 2015 · European Fund for Strategic Investment, Commission economic agenda

Meeting with Margrethe Vestager (Commissioner)

12 May 2015 · European Business Affairs

Meeting with Christian Linder (Cabinet of Vice-President Maroš Šefčovič)

12 May 2015 · Presentation of Energy Union

Meeting with Ditte Juul Jørgensen (Cabinet of Commissioner Margrethe Vestager)

18 Mar 2015 · Discussion on European Issues

Meeting with Riccardo Maggi (Cabinet of First Vice-President Frans Timmermans)

5 Mar 2015 · Better Regulation

Meeting with Robert Madelin (Director-General Communications Networks, Content and Technology)

25 Feb 2015 · Digital Single Market

Meeting with Frans Timmermans (First Vice-President)

29 Jan 2015 · Better regulation

Meeting with Christina Holm Eiberg (Cabinet of Commissioner Margrethe Vestager)

14 Jan 2015 · Introduction to Confederation of Danish Industry

Meeting with Fabrice Comptour (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and

1 Dec 2014 · Functioning of the internal market and the key role of intellectual property in fostering innovation, creation and growth.