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Confederation of Swedish Enterprise

The Confederation of Swedish Enterprise is Sweden's largest business federation representing 60,000 member companies.

Lobbying Activity

Meeting with Jörgen Warborn (Member of the European Parliament)

27 Jan 2026 · Trade

Meeting with Adnan Dibrani (Member of the European Parliament)

10 Dec 2025 · Digitala frågor, Digital Omnibus

Meeting with Arba Kokalari (Member of the European Parliament)

10 Dec 2025 · Digital omnibus

Meeting with Francesco Corti (Cabinet of Executive Vice-President Roxana Mînzatu)

9 Dec 2025 · Discussion on subcontracting

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur) and ArcelorMittal and METINVEST

2 Dec 2025 · Stålmarknaden

Meeting with Tomas Tobé (Member of the European Parliament) and Teknikföretagen

28 Nov 2025 · Research Policy

Meeting with Arba Kokalari (Member of the European Parliament)

28 Nov 2025 · Employment policy

Response to EU Design Delegated Regulation

26 Nov 2025

The Confederation of Swedish Enterprise (Svenskt Näringsliv) supports the aim to streamline procedures to apply and register and EU design at EUIPO. The Confederation of Swedish Enterprise also supports the aim to enhance the level of transparency, effectiveness and efficiency in proceedings before EUIPO. The Confederation of Swedish Enterprise is Swedens largest and most influential business federation representing 60 000 member companies. Among the member companies most are Small and Medium-Sized Enterprises (SMEs). Efficient systems for registering designs are important to these companies. Our only concern when it comes to the proposal is some uncertainties regarding the relation to grounds for invalidity, looking at the wording in Article 7. The concern is if this aims to only cover invalidity due to invalidity grounds based on lack of novelty or lack of individual character. It this is the intention, we doubt if this is fit for purpose and we also think that it then should be stated in a clearer way.
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Meeting with Arba Kokalari (Member of the European Parliament) and Teknikföretagen and Swedish Institute for Standards

21 Nov 2025 · Standardisation

Meeting with Adnan Dibrani (Member of the European Parliament) and Teknikföretagen

20 Nov 2025 · Inre marknad och standardiseringsfrågor

Meeting with Sofie Eriksson (Member of the European Parliament, Rapporteur for opinion) and Teknikföretagen

5 Nov 2025 · Synpunkter på Kommissionens förslag om ståltullsmekanism

Meeting with Arba Kokalari (Member of the European Parliament)

29 Oct 2025 · Employment policy

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

27 Oct 2025 · Green files

Swedish Business Urges Major Cut to EU Foreign Subsidy Rules

24 Oct 2025
Topic — Review of 2022 regulation on foreign subsidies distorting the internal market.
Message — The organization requests fundamental changes to reduce reporting requirements, including removing mandatory notifications for mergers and procurement, raising turnover thresholds by 20%, and allowing companies to use annual accounts instead of real-time data. They argue the Commission underestimated both affected companies and administrative burden.1234
Why — This would massively reduce their compliance costs and reporting workload across thousands of transactions.567
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Meeting with Yvo Volman (Director Communications Networks, Content and Technology) and Confederation of Finnish Industries EK and Confederation of Danish Industry

24 Oct 2025 · Data Union Strategy – Digital Omnibus

Swedish Business Urges Stronger Enforcement Over New Digital Fairness Rules

21 Oct 2025
Topic — EU proposal to strengthen consumer protection against dark patterns and unfair digital practices.
Message — The organization requests the Commission prioritize reviewing the Consumer Protection Cooperation Regulation to strengthen cross-border enforcement and create a cross-functional task force for coordination. They argue existing laws are sufficient and new legislation should only be considered after improving enforcement mechanisms.123
Why — This would avoid new compliance requirements while maintaining current business models and legal certainty.456
Impact — Consumers lose potential protections against new digital exploitation techniques not covered by existing enforcement.78
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Swedish Business Groups Oppose Steel Industry Rescue Aid Expansion

16 Oct 2025
Topic — EU review of state aid guidelines for rescuing struggling companies.
Message — The confederation opposes including steel companies in rescue aid guidelines and requests updating the definition of 'undertaking in difficulty' to better accommodate innovative startups. They recommend extending the period for classifying newly established companies or adjusting exemption criteria.123
Why — This would prevent public bailouts from undermining market competition and protecting efficient Swedish firms.45
Impact — Struggling steel companies and workers lose potential state rescue support during crises.67
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Swedish Enterprise urges major simplification of EU digital rules

14 Oct 2025
Topic — The consultation focuses on reducing administrative burdens through a new digital simplification agenda.
Message — The organization calls to identify inconsistencies and overlaps in the digital rulebook to ensure removal. They propose a single-entry point for cybersecurity reporting and deleting far-reaching non-personal data requirements. They request no application of AI rules until harmonised standards are implemented for twenty-four months.123
Why — This would reduce administrative and cost burdens that currently affect the competitiveness of businesses.45
Impact — Data protection authorities lose the documentation needed for auditing purposes when companies reduce their paperwork.6
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Swedish Enterprise urges technology neutrality for EU electrification

9 Oct 2025
Topic — This consultation seeks to identify barriers to accelerating demand-side electrification across the European Union.
Message — The organization requests a technology-neutral framework that supports nuclear and other low-carbon power sources. They argue against mandatory efficiency regulations and additional sub-targets that create cost-efficiency risks. They also seek more flexible state aid rules for purchasing heavy-duty electric trucks.12
Why — These proposals would lower electricity costs and protect energy-intensive industries from burdensome regulations.34
Impact — Renewable energy providers would face new financial burdens from mandatory storage and balancing obligations.56
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Swedish Enterprise urges expanded state aid exemptions for green transition

6 Oct 2025
Topic — EU review of rules exempting certain state aid from prior Commission approval.
Message — The organization requests updated rules with better structure, expanded aid for fossil-free energy technologies beyond renewables, revised vehicle and charging infrastructure provisions with higher aid limits, and increased operational aid limits for regional airports up to 700,000 passengers.1234
Why — This would reduce legal risks for aid-receiving companies and enable more state support for Swedish businesses' green transition investments.567
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Meeting with Jessika Roswall (Commissioner) and

3 Oct 2025 · Current political priorities

Meeting with Sofie Eriksson (Member of the European Parliament)

2 Oct 2025 · Internationella handelsfrågor och tullar

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 Roxana Mînzatu (Executive Vice-President) and

1 Oct 2025 · Meeting to discuss the Swedish labour market model and the transition agreement negotiated between trade unions and employers in the private sector

Swedish Business Group Backs Voluntary EU Company Form with Narrow Scope

30 Sept 2025
Topic — New optional EU-wide corporate legal framework to help innovative companies scale up.
Message — The organization requests that any 28th regime be voluntary, focus on solving concrete problems, and exclude tax and labor law. They emphasize the initiative must avoid disrupting national corporate governance models and should remain open to all company types.1234
Why — This would allow Swedish companies flexibility while protecting their existing corporate governance framework.56
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Meeting with Tomas Tobé (Member of the European Parliament)

25 Sept 2025 · Simplification

Meeting with Johan Danielsson (Member of the European Parliament)

24 Sept 2025 · Railway capacity Regulation, roadworthiness package, CEF, military mobility

Meeting with Stéphane Séjourné (Executive Vice-President) and

24 Sept 2025 · Single Market

Meeting with Jörgen Warborn (Member of the European Parliament)

22 Sept 2025 · Digital simplification

Meeting with Pär Holmgren (Member of the European Parliament)

16 Sept 2025 · Klimat och energifrågor

Meeting with Joan Canton (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

15 Sept 2025 · Exchange of views on the Industrial Accelerator Act

Swedish Industry Demands Uniform EU Carbon Cost Compensation Rules

5 Sept 2025
Topic — The consultation reviews State aid rules for compensating indirect carbon costs in electricity.
Message — The group calls for a harmonized EU-wide system to ensure fair competition. They argue current rules create distortions because many countries do not offer compensation.12
Why — Swedish companies would achieve financial parity with competitors in countries currently providing subsidies.3
Impact — Member states with fossil-fuel-reliant power grids would lose their current competitive funding advantage.4
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Response to Revision of the 'New Legislative Framework'

1 Sept 2025

The Confederation of Swedish Enterprise welcomes the Commissions ambition to futureproof the New Legislative Framework (NLF). A modernised, streamlined, and better-aligned NLF is essential for European competitiveness. By reducing regulatory complexity, embracing digital solutions, and strengthening standardisation and market surveillance, the EU can ensure a robust single market that supports innovation, sustainability, and global trade. Please find our suggestions attached.
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Swedish Enterprise urges enforcement focus for new Consumer Agenda

29 Aug 2025
Topic — The EU is setting its consumer policy strategy and priorities for 2025-2030.
Message — The Confederation advocates for enforcing existing rules and simplifying consumer law rather than introducing new regulations. They suggest removing unnecessary requirements to reduce administrative burdens and creating a task force to coordinate enforcement.12
Why — Removing overlapping requirements would reduce administrative burdens and compliance costs for businesses.3
Impact — Consumer groups may face delays in receiving new protections due to the focus on enforcement.4
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Swedish Enterprise backs digital product info but opposes common specifications

29 Aug 2025
Topic — This consultation concerns updating EU product legislation for the digital age and simplification.
Message — The group supports digitalising product declarations and instructions to simplify business processes. They suggest replacing physical addresses with digital contacts and removing "Common Specifications" proposals.123
Why — Replacing physical addresses with digital info reduces labeling costs and saves packaging space.45
Impact — Non-digital consumers may lose access to manufacturer details if physical addresses are removed.67
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Swedish Enterprise urges EU to simplify data laws

18 Jul 2025
Topic — The consultation seeks to streamline data rules to facilitate seamless cross-border sharing.
Message — The organization calls for a stop to new legislation, favoring the simplification of existing rules to reduce paperwork. They want clearer guidelines on how various data laws work together with privacy regulations.12
Why — Businesses would benefit from lower operational costs and improved protection for their commercial secrets.34
Impact — EU authorities would lose the power to restrict industrial data transfers to foreign governments.5
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Response to Revision of the Standardisation Regulation

15 Jul 2025

The Confederation of Swedish Enterprise supports revising the Standardisation Regulation alongside the New Legislative Framework (NLF) to ensure a cohesive approach to placing safe, compliant products on the EU single market. While we recognize that standard setting is often lengthy and complex, we urge the Commission to streamline both its own and the European Standardisation Organisations' administrative procedures for developing and publishing standards, without compromising their quality. Standards are created through an open, consensus-based process involving experts from across Europe. Although administrative steps should be simplified, it is important not to rush consensus efforts, as this could reduce the quality of the standards. The revision seeks to address the underrepresentation of SMEs, startups, civil society, and other groups in standardisation. While greater inclusion is possible, the current system lets all stakeholders take part via National Standardisation Bodies (NSB), enabling local language contributions with minimal travel. Centralising standardisation could hinder local participation and make it even more difficult for underrepresented stakeholders to participate. Therefor we do not support allowing the Commission to send standardisation requests to organisations other than ESOs, unless they have a robust system ensuring input from all member states and stakeholders. In addition their standards should meet WTO requirements and be developed in openness and consensus. We support the proposed revision's aims to boost competitiveness, growth, and innovation, and stress the need for strengthening the EUs role in international standardisation. Strengthening cooperation between international and European standardisation bodies is essential. The current regulations international first principle should be upheld. Copyright issues highlighted by recent court cases must be resolved to enable continued publication of European harmonised standards (hEN) that match global ones. Departure from the global standardisation system risks harming the competitiveness of European business. We stand at your disposal and look forward to contributing to a future proof Standardisation Regulation.
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Swedish Enterprise supports Digital Networks Act and regulatory simplification

11 Jul 2025
Topic — The European Commission's initiative aims to boost secure, high-speed broadband and digital infrastructure investment.
Message — SN supports the Act provided it follows the simplification agenda and reduces reporting obligations by half. They advocate for better spectrum coordination and the phase-out of market power regulations.123
Why — Reducing reporting obligations and harmonising rules would lower costs and administrative burdens.4
Impact — National authorities would lose the power to impose unique local regulations and security standards.5
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Meeting with Anna Vernet (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

8 Jul 2025 · Revision of the State aid rules and concerns regarding other competition policy instruments

Confederation of Swedish Enterprise urges predictable ETS and export support

7 Jul 2025
Topic — Consultation on reviewing the EU Emissions Trading System and market stability for climate targets.
Message — Establish the annual emission reduction rate for 2031-2040 to ensure business investment certainty. The market stability system should be repurposed to maintain liquidity and limit volatility. Create export support schemes for companies competing in markets without carbon pricing.123
Why — This would reduce financial pressure on operations and maintain global competitiveness for Swedish exporters.45
Impact — Global trading partners risk facing protectionist fees that exceed actual carbon costs.6
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Response to Quality Jobs Roadmap

3 Jul 2025

We welcome the roadmaps emphasis on job creation, incentives to work, and labour market dynamism. But for the initiative to deliver real impact, it must also address Europes structural weaknesses in particular, low productivity, persistent skills shortages, and declining competitiveness. These factors are critical to reversing stagnation and enabling long-term, sustainable job creation. At the same time, we are concerned that the role of employers is largely absent from the roadmaps background note. The term employer does not appear once, despite the fact that jobs quality or otherwise cannot exist without them. The roadmap should better reflect the diversity of business models, sectoral conditions, and the importance of a healthy investment climate. Clearer links should also be made to the EUs Competitiveness Compass, the Union of Skills, and industrial strategies. Defining what makes a job quality must also be done with care. Peoples expectations and needs vary throughout life from students entering the workforce to parents balancing work and family, or older workers preparing for retirement. For many, flexible forms of work such as part-time or remote arrangements are not problems to be solved but valuable solutions. Attempting to define job quality too narrowly risks excluding important and legitimate employment models. From our perspective, all productive jobs offered in compliance with national labour law and collective agreements, and adaptable to changing needs, are quality jobs. Skills provision must be at the heart of the roadmap. Addressing mismatches between labour market needs and available competences is central to both quality employment and business performance. Swedens model of social partner-led transition systems shows how individuals can be supported through change, with strong outcomes for workers and companies alike. EU action should help unlock further investment in training. In a similar vein, digitalisation and the use of AI in the workplace should be approached constructively. Many of the challenges related to new technologies are already covered by existing EU legislation and collective agreements. Additional regulation risks overlapping with these frameworks and undermining innovation. What is needed is effective implementation of current rules and continued social dialogue not duplication. Respect for social partner autonomy must also be preserved. While collective bargaining can contribute to job quality, it is not a prerequisite. Many quality jobs are created outside collective agreements, and different models exist across the EU. The Commission should refrain from intervening in national labour relations systems or promoting top-down solutions. Ultimately, the success of the roadmap will depend on whether it strengthens Europes capacity to grow, innovate, and adapt. That means putting skills, competitiveness, and employer perspectives at the centre of policy. Without the right conditions for companies to thrive, quality jobs cannot be sustained no matter how well-intentioned the strategy may be. Read our full written input in the document below.
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Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur)

30 Jun 2025 · Green Claims Directive

Swedish Enterprise urges EU to model savings accounts on Sweden

26 Jun 2025
Topic — Creating a European blueprint for savings and investment products to support retail participation.
Message — The group advocates for a voluntary blueprint based on the Swedish Investment Savings Account model. It emphasizes simplicity, avoiding lock-in periods, and allowing a wide range of assets.12
Why — Swedish businesses would benefit from increased access to equity markets and diverse financing options.34
Impact — Professional investment managers may lose business if accounts remove the need for mandatory advisory services.5
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Meeting with Wopke Hoekstra (Commissioner) and

12 Jun 2025 · Roundtable meeting on clean industrial deal

Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

5 Jun 2025

The Confederation of Swedish Enterprise supports the Commissions goal to strengthen the capital markets within the EU under the frameworks of an effective Savings and Investments Union. We share the ambition to improve how capital is mobilised and allocated across the EU. In our view, this must go hand in hand with preserving the integrity of well-functioning national frameworks. To achieve this, we advocate the following approach: 1. Bottom-up innovation - EU policy should enable, not prescribe, nationally anchored reforms that lower barriers for retail investors and expand access to capital. Swedens ISK model is one example of how simple, well-designed rules can successfully boost household participation. 2. Improved collaboration among supervisors - While closer coordination between supervisors can support mutual understanding and exchange of good practices, broad transfers of supervisory powers risk weakening national frameworks that are trusted, well understood, and closely connected to the market. Any shift to joint supervisory arrangements should be limited to narrowly defined cases. 3. Removing technical cross-border frictions - We support EU-level action where it addresses specific technical barriers to cross-border activity - such as in post-trade processes - provided that measures are proportionate, market-driven and focused on removing clearly identified frictions.
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Meeting with Pierre Schellekens (Director Energy)

3 Jun 2025 · Exchange on Svenskt Näringsliv’s scenario analysis

Meeting with Anna Vernet (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Ericsson and

3 Jun 2025 · Strengthening the Swedish voice in EU policymaking processes

Response to International Digital Strategy

21 May 2025

Please see attached file. Best regards Ingrid Serup (Berglund), Confederation of Swedish Enterprise
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Meeting with Tomas Tobé (Member of the European Parliament)

15 May 2025 · Energy Policy

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and Confederation of Finnish Industries EK

14 May 2025 · Omnibus

Meeting with Maria Zafra Saura (Cabinet of Commissioner Michael McGrath), Maria Zafra Saura (Cabinet of Commissioner Michael McGrath)

14 May 2025 · Data protection, simplification

Meeting with Olivier Micol (Head of Unit Justice and Consumers)

13 May 2025 · Simplification of the GDPR

Meeting with Jessica Polfjärd (Member of the European Parliament, Rapporteur for opinion)

12 May 2025 · Omnibus

Meeting with Johan Danielsson (Member of the European Parliament, Rapporteur)

9 May 2025 · Kommissionens förslag till gemensamt utstationeringsregister

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

28 Apr 2025 · Single market strategy

Meeting with Johan Danielsson (Member of the European Parliament)

14 Apr 2025 · Kampen mot arbetslivskriminalitet

Meeting with Jörgen Warborn (Member of the European Parliament)

10 Apr 2025 · International trade

Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur)

7 Apr 2025 · Digital infrastructure

Meeting with Jörgen Warborn (Member of the European Parliament)

4 Apr 2025 · EMPL

Meeting with Maria Luís Albuquerque (Commissioner) and

3 Apr 2025 · Exchange on the Savings and Investments Union

Response to Foreign Subsidies Guidelines

2 Apr 2025

We welcome the upcoming guidelines, as business are in need of further clarity on these and other key concepts within the FSR, in particular the concept of foreign financial contributions. Please read our thoughts on for instance distortions of competition and the balancing test in the attached document.
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Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Exchange on Savings and Investments Union and capital markets in Sweden

Meeting with Maria Luís Albuquerque (Commissioner) and

2 Apr 2025 · Savings and Investments Union – dialogue with social partners

Meeting with Tomas Tobé (Member of the European Parliament, Shadow rapporteur for opinion) and Jernkontoret

27 Mar 2025 · Industrial Policy

Swedish industry urges more radical EU taxonomy reporting relief

26 Mar 2025
Topic — The consultation proposes amendments to the EU Taxonomy Delegated Acts to simplify corporate sustainability reporting.
Message — The organization calls for a significant reduction in disclosure requirements and a more flexible approach to materiality assessments. They also recommend completely removing the burdensome requirement to report on operating expenditure KPIs.12
Why — This would significantly lower the administrative costs and technical complexity associated with taxonomy compliance.3
Impact — Financial analysts lose access to specific data points regarding how companies manage green operational costs.4
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Meeting with Emma Wiesner (Member of the European Parliament)

26 Mar 2025 · Föredrag för Svenskt Näringslivs utvecklingsprogram

Meeting with Johan Danielsson (Member of the European Parliament)

25 Mar 2025 · Kampen mot arbetslivskriminalitet

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and EUROCHAMBRES – Association of European Chambers of Commerce and Industry and Finance Sweden

25 Mar 2025 · Omnibus

Meeting with Hanna Gedin (Member of the European Parliament)

24 Mar 2025 · Equality

Meeting with Heléne Fritzon (Member of the European Parliament)

24 Mar 2025 · Arbetsmarknadspolitik

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

20 Mar 2025 · EU digital policy

Response to EU Start-up and Scale-up Strategy

14 Mar 2025

The Confederation of Swedish Enterprise supports the Commissions ambition to improve the business environment for innovative companies in the EU. Start-ups and scale-ups play a crucial role in economic growth by developing and applying new technologies and innovations, thereby challenging incumbents, driving change in mature companies and increasing the overall efficiency of the economy. The EU has clearly fallen behind in this area, and related challenges need to be addressed in order to achieve the EUs long-term goals such as prosperity, security and succeeding in the twin transitions. The focus on improving the environment for start-ups and scale-ups is welcome. However, it should be recognized that these companies exist within a broader economic context, where they form dependencies on other businesses. Large- and smaller companies/start-ups/scale-ups complement each other with large companies engaging smaller businesses as suppliers, allowing knowledge and ideas to cross-fertilise. Many new innovations and business concepts born from start-ups and scale-ups therefore often benefit larger firms as well. Furthermore, large firms can provide an attractive exit option for smaller companies, thus increasing the incentives to engage in entrepreneurial and innovational activity. Hence, the starting point for policy development should be to create framework conditions that favour businesses of all sizes and types, and not specifically start-ups and scale-ups. Where such focused actions are taken, they must be clearly justified and pass a rigorous cost/benefit analysis. Given the strategic importance of start-ups and scale ups, it is crucial that the underlying problems are correctly understood. When comparing funding levels between different countries, it is important to keep in mind that financial market outcomes are greatly driven by the real economy. The lower funding levels of EU start-ups and scale-ups is not necessarily a reflection of lack of access to capital, but rather the lack of viable investment opportunities. While it is important that much needed competitiveness reforms are implemented both at the national and EU level, it should be recognized that innovative business ecosystems can take a long time to mature. Success (and failure) beget success. Investors and advisors have often previously founded a company themselves, and their experience contributes to strengthening the ecosystem. Older, larger companies can also directly and indirectly contribute, as investors and sources of relevant knowledge. They also provide a potential exit opportunity for founders and investors. A dynamic capital market provides funding possibilities, and active stock exchanges provide listings and yet another attractive exit opportunity. Ecosystems such as these are not quickly or easily built, but a sound business environment is necessary. While the EU can take action to remove barriers and make investing in the EU more attractive, experience suggests that many of the important policy areas, are under the exclusive control of Member States. Therefore, any meaningful improvement in the EU start-up and scale-up ecosystems will have to involve reforms at the national level. The primary challenges for the EU to address in this context is developing the single market, encouraging structural reform at the Member State level and using EU funds efficiently.
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Meeting with Alice Teodorescu Måwe (Member of the European Parliament) and Swedish Forest Industries Federation and Byggföretagen

7 Mar 2025 · Vatten

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall)

5 Mar 2025 · Water Resilience

Response to Savings and Investments Union

21 Feb 2025

The Confederation of Swedish Enterprise supports the aim of the Capital Markets Union (also referenced as the Savings and Investment Union) (in the following the CMU) to create a single market for capital. Strong, well-functioning capital markets are critical for businesses and are key to achieving the EUs long-term goals, such as the twin transition and increased competitiveness. As shown in the Draghi-report, the EU has the foundations in place for a highly competitive economy but must urgently focus on increasing productivity growth. Therefore, investment levels need to increase across the EU in the coming years. The following paper details our views on how the CMU can best support the goal of meeting businesses investment needs. If the CMU is to aid in raising investment levels, any actions to reinforce and implement the CMU should be designed to strengthen EU companies access to finance by identifying their unmet needs, areas of potential improvement and by facilitating financial market innovation. This is especially important when it comes to complex, transformative and technology intensive investments where banks, which dominate corporate lending in the EU, are less suited to provide financing. The long-term goal should be to make the EU more attractive both to foreign and domestic investors, in order to increase investment in the areas that will drive future productivity growth. Our key messages regarding the CMU are the following: Any actions taken to reinforce and implement the CMU should strengthen EU companies access to finance by identifying their unmet needs, areas of potential improvement and by facilitating financial market innovation, thereby supporting the aim of increasing investment in the EU. Focus on competitiveness and improving business conditions to attract and increase investment. Financial market outcomes are greatly driven by the real economy. Do not overestimate the role of financial regulation. Increase the size and liquidity of EU capital markets by encouraging a shift of household savings to the capital markets. This can be done via attractive savings accounts and reformed pension systems at the member state level. Analyze why households in some member states have low capital market engagement, and then aim to remove barriers and lower costs. The Swedish experience indicates that taxation and pensions are two key policy areas for improving capital markets. These policy areas are under the exclusive control of member states. This in turn means that meaningful improvements to capital markets in the EU will require member states taking responsibility of their own reforms at the national level. Leverage the diversity in the EU by improving each individual market through a structured process. Be careful when attempting to harmonize financial market rules across the EU. Many issues are more effectively resolved by an inter-governmental approach, where the EU has an important leadership role. Focus on enhancing the coordination and exchange of information between ESMA and national authorities. Centralized supervision would be difficult to implement effectively and would bring limited benefits, if any. For further reading and more detailed proposals, please see the attached position paper, which can also be found here: https://www.svensktnaringsliv.se/english/capital-markets-for-a-more-competitive-europe_1224606.html
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Meeting with Jessika Roswall (Commissioner) and

14 Feb 2025 · Political priorities of the Commission

Meeting with Nils Behrndt (Deputy Director-General Justice and Consumers)

11 Feb 2025 · Discussion on the future initiative on a 28th company law regime and the High Level Group Justice for Growth

Meeting with Jessica Polfjärd (Member of the European Parliament)

10 Feb 2025 · Forestry policy

Meeting with Pierre Schellekens (Director Energy)

5 Feb 2025 · Exchange on the Commission’s upcoming initiative

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

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

Response to Single Market Strategy 2025

31 Jan 2025

In a competitive world, the EU must enhance its competitiveness. The Single Market is Europes key asset and driver of prosperity, but it needs improvement. Long-known shortcomings require decisive political action now to boost the internal market. The focus needs to be on core issues of removing trade barriers, making use of the better regulation toolbox, better enforcement and more uniform implementation and application of EU-legislation as well as reducing the regulatory burdens to business, including overly prescriptive legislation, micro-management of standards, over-use of delegated acts, and insufficient market surveillance. Governance should include a regular dialogue with stakeholders and high quality impact assessments. Provide understandable guidelines of the regulations and how they interact with each other, especially tailored to SMEs. The NLF is a great system for harmonising product requirements and the EU need to safeguard it and make sure that it´s fundamental principles are working well. Use standards correctly, as voluntary, market driven, tools to show compliance to essential requirements clearly stated in legislation. Use global standards as often as possible to promote scale up and foster global competitiveness. A restored NLF could be further developed to support the green and digital transformation. Initiate work to explore further alignment with legislations such as REACH, ESPR and Due Diligence requirements. Assess new legislative proposals to make sure they are NLF compatible. Harmonise mandatory labelling requirements and systems for Extended Producer Responcibility (EPR) to avoid technical barriers to trade within the internal market. Allow for fulfilment of labelling requirements and compliance documentation through digital means. Reinforce market surveillance through cooperation between industry and authorities and sufficient resources. For non-harmonised products, mutual recognition is an important but underutilised tool for companies to grow on the internal market. Companies rather adapt to national legislation than push for mutual recognition, either because they do not know that the opportunity exists, or they consider invoking the mutual recognition principle too slow and uncertain. Make sure that the tools provided, such as TRIS, SOLVIT and the Single Digital Gateway are known and used diligently. The Single Market for services remains fragmented. It works only because companies find their way around the barriers, often through freedom of establishment. The current legislation is sufficient but need to be better enforced. Assign SMET to review whether the Services Directive has been implemented with a focus on mobility within the Single Market, with a view to removing remaining barriers under the Services Directive. Launch a thorough screening of permitting, licencing and authorisation schemes, starting with the services that are key to manufacturing industry (engineering, industrial installation and maintenance, logistics) Free movement of labour is essential for free movement of goods and services. Burdensome administration pre-empts companies from sending their experts abroad to other Member States. Member States installing identity controls at the border also create barriers for a common labour market, especially for cross border commuters passing the border on a daily basis. Labour mobility requires mutual recognition of diplomas and regulated professions due to the many persisting differences in national rules and requirements. Member states need to review and reduce the number of nationally regulated professions and ensure a more uniform application of the Professional Qualifications Directive. Introduce an exemption for business trips in Regulation 883/2004 on the coordination of social security systems as a matter of priority
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Meeting with Johan Danielsson (Member of the European Parliament)

29 Jan 2025 · Aktuella arbetsmarknadsfrågor

Meeting with Andrea Beltramello (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

29 Jan 2025 · Capital Market Union

Meeting with Adnan Dibrani (Member of the European Parliament, Committee chair)

28 Jan 2025 · Kapitalmarknadsunionen

Meeting with Emma Wiesner (Member of the European Parliament)

28 Jan 2025 · Svenskt Näringsliv jubileum 50 år i Bryssel

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

28 Jan 2025 · CORPORATE GOVERNANCE

Meeting with Heléne Fritzon (Member of the European Parliament)

28 Jan 2025 · Svenskt Näringsliv 50-årsjubileum

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

28 Jan 2025 · Svenskt Näringsliv 50 år i Bryssel

Meeting with Tomas Tobé (Member of the European Parliament) and Teknikföretagen

27 Jan 2025 · Research Policy

Meeting with Jörgen Warborn (Member of the European Parliament, Shadow rapporteur)

24 Jan 2025 · Digital Infrastructure

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 Jörgen Warborn (Member of the European Parliament)

10 Dec 2024 · EMPL

Meeting with Tomas Tobé (Member of the European Parliament)

10 Dec 2024 · Energy Policy

Meeting with Sofie Eriksson (Member of the European Parliament)

9 Dec 2024 · Forskning och innovation i nästa ramprogram

Meeting with Pär Holmgren (Member of the European Parliament) and Swedish Forest Industries Federation

27 Nov 2024 · Climate and Environmental policies

Meeting with Karin Karlsbro (Member of the European Parliament) and Swedish Forest Industries Federation

22 Nov 2024 · Aktuella frågor inom miljöutskottet

Meeting with Adnan Dibrani (Member of the European Parliament)

22 Nov 2024 · Finansmarknadsfrågor

Meeting with Tomas Tobé (Member of the European Parliament)

21 Nov 2024 · Industrial Policy

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

20 Nov 2024 · Informative session

Meeting with Jonas Sjöstedt (Member of the European Parliament) and Teknikföretagen

13 Nov 2024 · Business

Meeting with Johan Danielsson (Member of the European Parliament)

8 Nov 2024 · Aktuella transportfrågor i Europaparlamentet

Meeting with Johan Danielsson (Member of the European Parliament) and The Swedish Trade Union Confederation

5 Nov 2024 · Industrivarsel och omställningsfrågor

Meeting with Adnan Dibrani (Member of the European Parliament)

26 Sept 2024 · Presentation av Svenskt Näringslivs medlemsförbund

Meeting with Sofie Eriksson (Member of the European Parliament)

26 Sept 2024 · Presentation av Svenskt Näringslivs medlemsförbund

Meeting with Johan Danielsson (Member of the European Parliament)

26 Sept 2024 · Presentation av Svenskt Näringslivs medlemsförbund

Swedish industry urges higher state aid limits for regional airports

25 Sept 2024
Topic — The European Commission is revising state aid guidelines for the aviation and airport sectors.
Message — The group requests raising the passenger limit for operational aid to cover larger regional airports. They also propose transitional support for airports serving up to one million passengers.12
Why — Higher aid limits would ensure long-term stability and investment capacity for regional hubs.3
Impact — Nearby competing airports might suffer if aid leads to the duplication of infrastructure.4
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Meeting with Karin Karlsbro (Member of the European Parliament)

25 Sept 2024 · Prioriteringar inför ny mandatperiod

Meeting with Li Andersson (Member of the European Parliament, Committee chair) and Confederation of Finnish Industries EK and Tehy ry

24 Sept 2024 · Labour market politics

Meeting with Beatrice Timgren (Member of the European Parliament)

24 Sept 2024 · EU - labor market policy

Meeting with Tomas Tobé (Member of the European Parliament) and Orgalim – Europe's Technology Industries and Alfa Laval Corporate AB

24 Sept 2024 · Industrial and Transport Policy

Meeting with Johan Danielsson (Member of the European Parliament)

24 Sept 2024 · Arbetsmarknadspolitik under mandatperioden

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

18 Sept 2024 · Miljö- och klimat-prioriteringar under mandatperioden

Swedish Enterprise urges EU to prioritize digital frontrunners and deregulation

28 Jun 2024
Topic — European Commission consultation on scenarios to address digital infrastructure and connectivity needs.
Message — The organization calls for more ambitious connectivity goals and urgent deregulation. They advocate for supporting frontrunner nations and phasing out legacy technologies.123
Why — This would foster competition and reduce costs for Swedish businesses.45
Impact — Lagging nations may lose attention as policy shifts toward supporting digital leaders.6
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Response to Update of State aid procedural rules, considering the EU’s international commitments, recent practice and case law

24 Jun 2024

The Confederation of Swedish Enterprise has previously provided a detailed account of our views on this issue in a letter to the European Commission, dated 20 September 2022. Our assessment is that no major changes have occurred on this matter that would motivate a revision of our overall stance and the proposals we previously made. The following summarises and supplements that letter. When assessing whether the public has sufficient opportunity to access information and seek judicial review in state aid cases related to EU environmental legislation, we believe that the assessment should not be limited solely to the state aid case itself. The state aid, i.e., the selective advantage, does not in itself have an environmental impact, but the economic activity it supports does. That activity, in turn, is subject to extensive permitting processes of various kinds, provided the activity has potential consequences for the environment and health. An additional review of the aid itself would lead to double scrutiny, which is not appropriate or consistent with good regulation. Please find our additional comments in the attached file.
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Response to Directive of the European Parliament and of the Council on a Quality Framework for Traineeships

28 May 2024

Attached are initial comments from the Confederation of Swedish Enterprise on the proposals for traineeships. Best regards, Naiti del Sante Senior Legal Advisor Confederation of Swedish Enterprise
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Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

17 May 2024 · Global Gateway

Response to Evaluation and review of the Regulation concerning the screening of foreign direct investments

29 Apr 2024

Please find enclosed the comments of the Confederation of Swedish Enterprise.
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Meeting with Ilan De Basso (Member of the European Parliament)

12 Apr 2024 · Möte

Meeting with Karin Karlsbro (Member of the European Parliament)

12 Apr 2024 · Deltagare på Svenskt Näringslivs styrelsemöte

Meeting with Ivan Štefanec (Member of the European Parliament) and Republiková únia zamestnávateľov

9 Apr 2024 · Europe Unlocked

Response to Initiative on the European Works Council Directive

25 Mar 2024

Enclosed are the Comments from the Confederation of Swedish Enterprise on the European Commission's proposal for a revised European Works Council Directive. Best Regards, Naiti del Sante, Senior Legal Advisor on behalf of the Confederation of Swedish Enterprise ( Svenskt Näringsliv).
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Meeting with Tomas Tobé (Member of the European Parliament)

15 Mar 2024 · Research Policy

Meeting with Tomas Tobé (Member of the European Parliament)

4 Mar 2024 · Industry Policy

Meeting with Jörgen Warborn (Member of the European Parliament)

1 Mar 2024 · EU-India Relations

Meeting with Ilan De Basso (Member of the European Parliament)

21 Feb 2024 · Paneldeltagande

Meeting with Ilan De Basso (Member of the European Parliament)

19 Feb 2024 · Möte om europeiska företagsråd

Meeting with Jörgen Warborn (Member of the European Parliament)

19 Feb 2024 · Företagarfrågor

Meeting with Tomas Tobé (Member of the European Parliament) and Swedish Forest Industries Federation

16 Feb 2024 · Industry policy

Meeting with Ilan De Basso (Member of the European Parliament)

14 Feb 2024 · Möte om aktuella EU-frågor

Meeting with Abir Al-Sahlani (Member of the European Parliament, Rapporteur) and Bundesvereinigung der Deutschen Arbeitgeberverbände e.V.

14 Feb 2024 · EU Talent Pool

Meeting with Jörgen Warborn (Member of the European Parliament)

14 Feb 2024 · Swedish business

Meeting with Ilan De Basso (Member of the European Parliament)

13 Feb 2024 · Möte om europeiska företagsråd

Meeting with Jörgen Warborn (Member of the European Parliament) and Byggföretagen and Industriarbetsgivarna

13 Feb 2024 · Företagarfrågor

Swedish Enterprise urges GDPR competitiveness check and reform

8 Feb 2024
Topic — Review of the General Data Protection Regulation's application six years after its launch.
Message — The group seeks measures to counter unnecessary bureaucracy and unjustified restrictions on business activities. They recommend updating definitions of personal data and anonymisation to support AI-driven innovation. Additionally, they propose limiting data access rights to prevent strategic misuse in legal disputes.123
Why — Clarified rules would reduce resource-intensive compliance work and lower high administrative costs.456
Impact — Individuals would lose their ability to use data requests for gathering evidence in disputes.7
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Meeting with Jörgen Warborn (Member of the European Parliament)

2 Feb 2024 · Företagarfrågor

Meeting with Ilan De Basso (Member of the European Parliament)

1 Feb 2024 · Möte om aktuella EU-frågor

Meeting with Jessica Polfjärd (Member of the European Parliament)

1 Feb 2024 · Soil health

Meeting with Abir Al-Sahlani (Member of the European Parliament, Rapporteur)

1 Feb 2024 · EU Talent Pool

Meeting with Nils Torvalds (Member of the European Parliament)

31 Jan 2024 · Soil Monitoring Law

Meeting with Jörgen Warborn (Member of the European Parliament)

24 Jan 2024 · Transportfrågor

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 Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Swedish Forest Industries Federation and Svensk Handel

18 Sept 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Lucrezia Busa (Cabinet of Commissioner Didier Reynders)

12 Sept 2023 · CSDDD

Meeting with Kurt Vandenberghe (Director-General Climate Action)

12 Sept 2023 · give an overview of the EU policy landscape

Meeting with Jakop G. Dalunde (Member of the European Parliament)

7 Sept 2023 · Discussion about Competitiveness of the private business world

Swedish Business Urges EU Strategy for Carbon Capture Infrastructure

31 Aug 2023
Topic — EU strategy for carbon capture, utilisation and storage deployment by 2050.
Message — The organisation requests a comprehensive EU strategy to develop carbon capture technologies and CO2 transport infrastructure. They want the EU to coordinate projects, ensure knowledge sharing, and clarify quality standards for hard-to-abate sectors like cement.1234
Why — This would enable cost-efficient decarbonization of hard-to-abate industrial sectors like cement.56
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Swedish Business Groups Urge Simplified CBAM Reporting to Reduce Administrative Burden

10 Jul 2023
Topic — EU regulation requiring companies to report carbon emissions from imported goods starting October 2023.
Message — The organization requests company group-level reporting instead of per EORI number, combined notification reports across entities, and fewer mandatory reporting fields during the transition period. They argue the current system creates substantial administrative burden with multiple EORI numbers and VAT entities.123
Why — This would significantly reduce their internal administrative costs and complexity of compliance.45
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Meeting with Andrus Ansip (Member of the European Parliament, Rapporteur) and Deutsche Telekom

6 Jul 2023 · Green Claims

Meeting with Abir Al-Sahlani (Member of the European Parliament) and Svensk Handel and

29 Jun 2023 · Samtal om viktiga EU-frågor för näringslivet

Meeting with Ilan De Basso (Member of the European Parliament)

6 Jun 2023 · Mingel

Swedish industry group urges broader scope for EU green law

15 May 2023
Topic — The European Commission's plan to boost manufacturing capacity for net-zero energy technologies.
Message — The organization advocates for general rules over picking specific technologies to promote green transitions. They oppose production targets and want all climate projects to receive faster permits.123
Why — Removing extra assessment layers would give companies faster permit approvals and reduce administrative costs.4
Impact — Smaller firms and non-prioritized sectors face disadvantages if specific strategic projects receive special treatment.56
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Meeting with Emma Wiesner (Member of the European Parliament)

4 May 2023 · EU ETS

Meeting with Nicolas Schmit (Commissioner) and

4 May 2023 · Discussion on employment and social policies

Response to European Critical Raw Materials Act

3 May 2023

The Confederation of Swedish Enterprise welcomes the European Commission's initiative to improve access to critical and strategic raw materials for business in the EU. It notes that this is both through the intention to promote opportunities for exploration, mining, processing and recycling as well as the ambition to strengthen trade relations with like-minded countries. This will provide companies with the opportunity to secure their value chains through business-driven diversification. However, the European Commission's initiative is too narrow in its design. The Confederation of Swedish Enterprise advocates broader measures, which remove obstacles to the development of the entire value chain. It is important that the European Commission's proposal takes into account the fact that critical and strategic raw materials are often derived as a by-product of the extraction of other raw materials. The main obstacle that both the European Commission and the Member States should focus on is the long and unpredictable permit processes, which often constitute crucial barriers to the development of new mining activities. The proposal to introduce fixed time limits for strategic projects may be welcomed by those affected. However, from a market perspective this is problematic, as other activities may be disadvantaged when selected projects are prioritised. More fundamental measures are required to bring about genuine change and accelerate the transition. In addition, a new organisation of the licensing process may risk undermining the possibility of an effective review. The European Commission's focus on strategic projects also risks leading to a high administrative burden, without necessarily benefiting those companies most in need of support and guidance.
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Meeting with Emma Wiesner (Member of the European Parliament)

27 Apr 2023 · Aktuellt i energi och klimatpolitiken

Meeting with Emma Wiesner (Member of the European Parliament)

21 Apr 2023 · Svenskt konkurrenskraft i EU

Meeting with Arba Kokalari (Member of the European Parliament)

21 Apr 2023 · Europe's competitiveness

Swedish Enterprise Urges Gradual Phase-In for Lead Safety Rules

17 Apr 2023
Topic — Revision of EU directives establishing exposure limits for lead and diisocyanates.
Message — The organization requests a step-by-step reduction of lead exposure limits over eight years. They support the diisocyanate proposal but advocate for higher lead limit values.12
Why — Longer transition periods would reduce immediate compliance costs and prevent the relocation of production.34
Impact — Industrial workers will face higher health risks due to delayed enforcement of stricter lead limits.5
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Response to VAT in the Digital Age

4 Apr 2023

Please find comments by the Confederation of Swedish Enterprise and the Swedish Business and Industry Tax Delegation in the attached file.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion) and BUSINESSEUROPE

22 Mar 2023 · Follow up on the skills seminar held on 16 February, Council recommendations on strengthening the social dialogue in the EU and European Works Council

Meeting with Valdis Dombrovskis (Executive Vice-President) and Teknikföretagen and

10 Mar 2023 · Social dialogue, EU policies in the employment and social area

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

2 Mar 2023 · European competitiveness strategy and Inflation Reduction Act

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

2 Mar 2023 · long term competitivness, TTC

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

2 Mar 2023 · Industry competitiveness and the single market

Meeting with Jakop G. Dalunde (Member of the European Parliament)

1 Mar 2023 · Energy Market Design

Meeting with Emma Wiesner (Member of the European Parliament)

1 Mar 2023 · Diskussion om nya regler för EUs elmarknadsdesign

Meeting with Jessica Polfjärd (Member of the European Parliament, Shadow rapporteur)

1 Mar 2023 · Circular Economy

Meeting with Tomas Tobé (Member of the European Parliament, Committee chair)

28 Feb 2023 · Development policy and energy policy

Swedish Enterprise warns of 'unacceptable' complexity in subsidy rules

21 Feb 2023
Topic — Detailed procedural rules for investigating and reporting distortive foreign subsidies.
Message — Swedish Enterprise calls for a clearer definition of financial contributions to enable legally secure reporting. They propose ten amendments to simplify data collection and allow for aggregating transactions.123
Why — Reducing administrative burdens would lower business costs and prevent firms from over-implementing rules.456
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Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

16 Feb 2023 · Critical Raw Materials package

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

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 Danish Industry

14 Feb 2023 · Corporate Sustainability Due Diligence

Confederation of Swedish Enterprise urges guidelines over mental health laws

13 Feb 2023
Topic — This consultation addresses a comprehensive EU-wide approach to promoting and preventing mental health issues.
Message — Employers argue it is highly inappropriate to legislate further on psychosocial risks at the European level. They recommend distinguishing between workplace risks and other life challenges. Instead of new laws, they suggest providing guidelines and information for smaller companies.123
Why — This position helps companies avoid new regulatory burdens while maintaining control over national labor arrangements.45
Impact — Workers may lose support for individual health issues as employers focus solely on organizational risks.6
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Response to New Agenda for Latin America and the Caribbean

8 Feb 2023

The Swedish Confederation of Enterprise supports the position of Business Europe when it comes to relations with Latin America. In general, we can not only trade with friends, and the idea of friendshoring is naive, but we do need to trade more with our friends. And the countries in Latin America are mostly are friends politically. Economically, our relationship is underutilized and has many opportunities to expand, both when it comes to exports and imports as well as FDI. The EU should seek to build a much closer economic relation with Latin America and deploy various tools to acheive this objective. Needless to say, economic relations must be based on a foundation of sustainability and contribute to the green transiation
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Swedish Enterprise warns against mandatory EU asbestos screening rules

7 Feb 2023
Topic — EU initiative to address asbestos risks through mandatory building screening and registries.
Message — The organization opposes a new legislative framework, arguing that asbestos should only be removed during planned renovations. They prefer guidance that helps owners comply with existing regulations rather than mandatory mandates.123
Why — This avoids the high economic costs of mandatory screening and removal mandates.4
Impact — Building occupants risk increased exposure if asbestos is disturbed unnecessarily.5
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Response to Community Design registration

31 Jan 2023

A design proposal based on out-of-date assumptions The review of the EUs rules on industrial design was widely welcomed when it was first announced in the Intellectual Property Action Plan. However, now that the proposals have been presented, they seem to be based on old, out-of-date assumptions. The impact assessment covers the same topics and arguments that were discussed when the current rules came about, more than 20 years ago. Yet so much has changed since then. A proposal on updated rules should be based on an analysis of the competitiveness of European industry, it should consider what is needed from a sustainability perspective and it should explore the much-needed modernisation of the legislation created by increasing digitalisation. The details of the comments from the Confederation of Swedish Enterprise can be found in the attached file.
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Response to Review of the Designs Directive

31 Jan 2023

A design proposal based on out-of-date assumptions The review of the EUs rules on industrial design was widely welcomed when it was first announced in the Intellectual Property Action Plan. However, now that the proposals have been presented, they seem to be based on old, out-of-date assumptions. The impact assessment covers the same topics and arguments that were discussed when the current rules came about, more than 20 years ago. Yet so much has changed since then. A proposal on updated rules should be based on an analysis of the competitiveness of European industry, it should consider what is needed from a sustainability perspective and it should explore the much-needed modernisation of the legislation created by increasing digitalisation. The details of the comments from the Confederation of Swedish Enterprise can be found in the attached file.
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Response to Review of the Community Designs Regulation

31 Jan 2023

A design proposal based on out-of-date assumptions The review of the EUs rules on industrial design was widely welcomed when it was first announced in the Intellectual Property Action Plan. However, now that the proposals have been presented, they seem to be based on old, out-of-date assumptions. The impact assessment covers the same topics and arguments that were discussed when the current rules came about, more than 20 years ago. Yet so much has changed since then. A proposal on updated rules should be based on an analysis of the competitiveness of European industry, it should consider what is needed from a sustainability perspective and it should explore the much-needed modernisation of the legislation created by increasing digitalisation. The details of our comments are to be found in the attached document.
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Meeting with Radan Kanev (Member of the European Parliament, Rapporteur)

13 Dec 2022 · Industrial emissions directive

Meeting with Jessica Polfjärd (Member of the European Parliament)

8 Dec 2022 · European policy

Meeting with Nicolas Schmit (Commissioner) and

5 Dec 2022 · General discussion on the employment and social agenda and preparation of the Swedish Presidency of the EU. State of play of the negotiations between the European Parliament and the Council on the Platform workers directive.

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

5 Dec 2022 · Single market, industrial policy.

Swedish industry urges clarity on EU forced labour ban

30 Nov 2022
Topic — This consultation concerns a proposed EU ban on products made using forced labour.
Message — The group demands a full impact assessment and insists that authorities carry the burden of proof. They also request detailed guidelines at least one year before the ban begins.123
Why — It ensures companies avoid massive administrative burdens and preserves the presumption of innocence.4
Impact — Developing nations risk being cut off from trade due to high compliance costs.5
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Meeting with Pär Holmgren (Member of the European Parliament)

17 Nov 2022 · Industrial emissions (staff level)

Meeting with Tomas Tobé (Member of the European Parliament, Rapporteur for opinion)

16 Nov 2022 · Industrial Emissions Directive

Meeting with Ursula von der Leyen (President)

10 Nov 2022 · Meeting with the Chairman and representatives of the Confederation of Swedish Enterprises (topic: economic situation)

Meeting with Arba Kokalari (Member of the European Parliament)

29 Sept 2022 · Digital policy

Meeting with Pär Holmgren (Member of the European Parliament)

28 Sept 2022 · Discussion with expert group for Environmental Policy

Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur for opinion)

28 Sept 2022 · Ecodesign

Meeting with Jessica Polfjärd (Member of the European Parliament, Shadow rapporteur) and H M Hennes Mauritz AB and Classifieds Marketplaces Europe

28 Sept 2022 · Circular economy

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit) and The Swedish Trade Union Confederation and Tjänstemännens centralorganisation

21 Sept 2022 · forthcoming proposal on strengthening social dialogue in the Member States

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

16 Sept 2022 · - State of play regarding the New Pact on Migration and Asylum - Temporary Protection Directive Ukraine - Upcoming Swedish Presidency

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and Telefonica, S.A. and

31 Aug 2022 · AI Act

Response to Review of the de minimis aid Regulation

1 Jul 2022

Summary: The Confederation of Swedish Enterprise suggest that the de minimis threshold is raised to no more than 250 000 Euro. The inflation in the Eurozone has amounted to around 35 percent since 2006 when the threshold was set. Our view is that also small aid amounts can raise concerns of competition distortions, in particular considering that the economy is even more integrated now than in 2006, especially thanks to the large expansion of online markets. In addition, we welcome the suggestion to make it mandatory to set up a national de minimis registry, to increase transparency and lower administrative burden and legal uncertainty for business. Our full response is attached (in Swedish).
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Swedish Enterprise urges higher aid thresholds for regional airports

1 Jul 2022
Topic — This consultation concerns a proposed extension of state aid rules for regional airports.
Message — The Confederation of Swedish Enterprise supports the suggested prolongation of the transitional period for airport operating aid. They also point out the need to permanently increase the current passenger threshold to 500,000 passengers.12
Why — A higher threshold allows more regional airports to secure funding and avoid closure.3
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Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová)

1 Jul 2022 · Corporate Sustainable Due Diligence

Response to Sustainable Products Initiative

22 Jun 2022

This document contains Swedish Enterprise’s initial comments on the Sustainable Product Initiative and the Ecodesign requirements for sustainable products regulation (ESPR) presented on March 30 by the European Commission. Confederation of Swedish Enterprise is Sweden’s largest business federation, representing 60 000 member companies in all sectors with almost 2 million employees. We bring together 49 industry and employer organisations, and this position has been produced in close cooperation with our members. Swedish Enterprise welcomes the European Commission’s work on the Sustainable Product Initiative and sees the Ecodesign requirements for sustainable products regulation (ESPR) as a key step towards a more circular economy in Europe. As a more circular economy – where materials and products are managed more resource-efficiently – is a core aspect of achieving the climate goals, the Regulation is also an important contribution to the work of achieving these goals. Swedish Enterprise welcomes that the Commission’s legislative proposal is in the form of a regula-tion, as this provides increased harmonisation in the EU single market. The efficient functioning of the single market is vital to business and the development of the circular economy. It is therefore impor-tant that product requirements are set at EU level and that specific national rules are avoided. Swedish Enterprise is in general positive to the Regulation , but also sees a number of challenges that needs to be addressed in the legislation and future product regulations. It is crucial that the Regulation strengthens the competitiveness of European business.
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Swedish Enterprise urges risk-based bans on all forced labour products

20 Jun 2022
Topic — EU initiative to ban products made with forced labour from the internal market.
Message — The organization calls for a product withdrawal mechanism covering all goods rather than just an import ban. They insist that public authorities, not companies, must prove forced labour has occurred before withdrawing products.12
Why — Shifting the burden of proof to authorities avoids huge costs for legitimate businesses.34
Impact — Public authorities face high costs as they must find and prove forced labour.56
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Meeting with Jakop G. Dalunde (Member of the European Parliament, Shadow rapporteur)

16 Jun 2022 · ESPR (Staff Level)

Meeting with Karin Karlsbro (Member of the European Parliament)

15 Jun 2022 · Reception Swedish Enteprise

Swedish Enterprise urges narrower scope for corporate sustainability rules

23 May 2022
Topic — The European Commission is proposing mandatory sustainability due diligence for large companies.
Message — The group demands the rules apply only to supply chains rather than entire value chains. They also insist that legal liability must be restricted to direct contractual partners to remain manageable.12
Why — Restricting the rules' scope would lower operational costs and reduce litigation risks.34
Impact — Communities downstream lose protections against corporate environmental damage and human rights violations.5
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Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

19 May 2022 · General introduction to the work of the Commission as an institution

Meeting with Heléne Fritzon (Member of the European Parliament)

17 May 2022 · Möte med Svenskt Näringsliv

Swedish business group warns Data Act risks European competitiveness

13 May 2022
Topic — The consultation gathers views on harmonized rules for fair data access and use.
Message — The organization requests limiting mandatory sharing to sectors with clear market failures and strengthening trade secret protections. They also call for the removal of restrictions on international transfers of non-personal data.123
Why — This would protect companies' competitive advantages and prevent the undermining of investment incentives.45
Impact — Third-party maintenance providers and consumers lose access to cheaper aftermarket repair and data services.67
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Response to A New European Innovation Agenda

10 May 2022

The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). The Confederation of Swedish Enterprise (Svenskt Näringsliv) is working on policy issues linked to innovation and knowledge-based assets. The comments are based on that work, with a starting point that knowledge-based assets are crucial in the knowledge economy. There is a need for a New European Innovation Agenda. Europe is losing competitiveness when it comes to innovation in may fields. EFPIA has shown that only 22 % of global new treatments originate in Europe, while 48 % come from the US. This represents a complete reversal of the situation just 25 years ago. Other regions of the world have also gone from producing to innovating themselves. In 2021, it became evident that Chinese operations are moving forward in applications for the European market. Patents applicants to the EPO went up by 24 %. The country that handed in most trademarks applications to the EUIPO was China. This calls for action. However, action taken must be relevant. An Innovation Agenda must be up to date with the innovations of today. Innovation is not just technical solutions. Innovation is also service innovation or even innovation when it comes to the building of a new kind of business model. Research in humanities may also lead to innovation, not just research in the traditional STEM sectors. Another thing for an Innovation Agenda to tackle is the effects that other legislative processes may have on the innovative competitiveness of Europe. There are several issues that may hinder companies in Sweden and the rest of the Union from innovating. This includes the GDPR, the Data Act, and the Digital Product Passport. For digital innovation copyright is crucial. The partial harmonisation of copyright within the EU is a direct hindrance for start ups in Europe. Handling of knowledge-based assets is crucial to attract investments. The lack of knowledge on how to use the different intellectual property rights leads to problems in access to finance. This also has to be addressed. A part of this is that any research funded by public means should include strategies on knowledge-based assets and also should be linked to how patent information has been used. Christina Wainikka Policy Expert Intellectual Property
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Meeting with Christel Schaldemose (Member of the European Parliament) and Confederation of Finnish Industries EK and

2 May 2022 · industri- og konkurrencepolitik

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 Tomas Tobé (Member of the European Parliament) and Confederation of Norwegian Enterprise

2 May 2022 · Labor market policy, European competitiveness, Nordic cooperation

Swedish Business Lobby Rejects EU Compulsory Patent Licensing Rules

29 Apr 2022
Topic — The Commission is exploring harmonized EU rules for compulsory patent licensing.
Message — The organization argues there is no evidence for a new legislative initiative. They insist that current international and national frameworks already provide sufficient regulation.12
Why — The group avoids regulatory changes that might weaken their members' intellectual property rights.3
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Meeting with Pär Holmgren (Member of the European Parliament)

21 Apr 2022 · War in Ukraine impact on Swedish Businesses

Meeting with Arba Kokalari (Member of the European Parliament)

21 Apr 2022 · War in Ukraine and its consequences

Meeting with Malin Björk (Member of the European Parliament)

21 Apr 2022 · Consequences of the war in Ukraine

Response to European chips act package – Regulation

8 Apr 2022

Regarding the European Chips Act, Swedish Enterprise would like to make the following general points: • Reforms to promote business and trade in semiconductors are fundamentally positive. Semiconductors are a key input for many Swedish companies, and many Swedish companies and universities are at the forefront of this area. Increased R&D&I in the value chain in the EU is to be welcomed, assuming it does not take place at the expense of other important R&D&I activity. • However, the European Chips Act is generally more problematic. It contains proposals that are in themselves negative: substantial state aid that risks distorting competition; regulations that restrict the business freedoms; and the risk of an increased administrative burden. • There is also a key issue of principle: if public intervention and control to the extent that is now being proposed is accepted, there is a risk that additional inputs/production types are considered so important that the same approach can also be justified for them. Free, well-functioning, and dynamic markets risk becoming more limited and rigid. Increased support for and restrictions on production could also contribute to a “state aid race” and to increased barriers to trade. • We do not share the view that increased production within the EU is of such considerable value that it justifies the proposed interventions. The planned measures will not address the supply constraints experienced since the outbreak of the pandemic. In the long run, considerable investment will be made globally, using private and public funds, which makes it likely that the degree of diversification could be increased, thereby building resilience to future crises. Further reasoning can be found attached, in swedish.
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Response to Instrument to deter and counteract coercive actions by third countries

25 Mar 2022

In our view, it might be necessary to develop an instrument like this one. However, we do see several risks associated with it. The instrument gives the Commission vast powers to use in a discretionary way with an almost unlimited arsenal of trade policy tools. Some of these tools are inappropriate and should not be used. It is very unclear to us what this new instrument will lead to, when and how it will be used. Our attached comments does not take ithe sanctions against Russia into account. These sanctions, which we support fully, are outside the scope of the instrument as it is a trade policy instrument and not a security policy instrument.
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Meeting with Margrethe Vestager (Executive Vice-President) and

18 Mar 2022 · competitiveness and competition policy.

Response to Fight against counterfeiting

3 Mar 2022

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the initiative to create an EU toolbox against counterfeiting. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). Counterfeiting is a problem for companies in all sectors. It is also a problem for consumers. The Confederation of Swedish Enterprise can confirm the description of the problems. Numerous studies have been done on the impact of counterfeiting on the economy. Lack of awareness is a problem when it comes to consumer behavior. The Swedish Intellectual Property Office has target that in a good way, through for example information on-line. They were also a partner in creating an exhibition that has been placed in various places from time to time. Among other places it has been in airports to be seen by people on the way to travel to locations where counterfeited goods often is sold. It would be important to collect such “best practices” from the member states to see what actions have the most effect. The Confederation of Swedish Enterprise shares the view that action needs to be taken and that collaboration is a key factor. However, there is a concern that the creation of a specific instrument could counterproductive. The worst-case scenario is that it would create an administrative burden without tackling the problem.
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Response to Alignment EU rules on capital requirements to international standards (prudential requirements and market discipline)

21 Feb 2022

The Confederation of Swedish Enterprise welcome this opportunity to give feedback regarding the proposed amendment to Regulation (EU) No 575/2013 (the Capital Requirements Regulation or CRR) and the wider legislative package of which it is a part, known as Banking Package 2021. Please see the attached document for our views, which are very briefly summarised below. The Confederation of Swedish Enterprise recognises the importance of the financial stability objectives underlying the Commission’s proposal. We also recognize the value of international cooperation and harmonisation regarding financial regulation. However, global standards must take local circumstances into account when implemented at the EU and national level. It is important that the amendments to the capital requirements Directive and Regulation strengthen the resilience of the banking sector without resulting in significant and unjustified increases in capital requirements and subsequent harm to competitiveness. In the case of Sweden, the Commission’s proposal would lead to an increased cost of capital for corporates, due to an increase in the capital requirements for lending to unrated corporates caused by the implementation of the output floor. The resilience of the Swedish banking sector indicates that these capital increases are not justified. We also comment on the increased capital requirements for trade finance and the management of ESG-related risks.
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Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

17 Nov 2021 · Sustainable Corporate Governance, internal market, free trade, state aid regulations

Meeting with Pär Holmgren (Member of the European Parliament)

13 Oct 2021 · Fit for 55, Taxonomy, Circular Economy

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

12 Oct 2021 · Discussions on Schengen, freedom of movement and other topical matters in the context of home affairs

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager), Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

12 Oct 2021 · Issues within the competition portfolio

Meeting with Henrik Hololei (Director-General Mobility and Transport)

12 Oct 2021 · EU Transport Agenda

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

27 Sept 2021 · Industrial ecosystems

Meeting with Agnieszka Skonieczna (Cabinet of Commissioner Thierry Breton)

20 Sept 2021 · Sustainable Corporate Governance

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

10 Jun 2021 · Listen to their views on Sustainable Corporate Governance Initiative

Meeting with Simona Constantin (Cabinet of Vice-President Věra Jourová)

7 Jun 2021 · Sustainable Corporate Governance

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The Confederation of Swedish Enterprise would like to give the attached feedback (please see the seprate file) on the Commission’s draft delegated act, specifying the reporting requirements under the Taxonomy regulation. Our comments concern the requirements for non-financial reporting entities, i.e. the Commission’s proposed specifications of the KPI’s and disclosures under Article 8 of the Taxonomy Regulation. Summary of our main concerns: Given the great uncertainty regarding the delayed technical screening criteria we believe the reporting requirements need to be pushed back entirely by one year in order to provide adequate time for reporting entities to prepare. If the Commission chooses to keep the current partial postponement, the 2022 disclosures need to be further specified. The current wording does not make it adequately clear what constitutes eligible economic activities and does not explain how the share of eligible activities should be measured. The massive amount of additonal disclosures goes far beyond the requirements in the level one legislation. The additional disclosures have not been subject to an adequate impact assesment. Among the proposed disclosure requirements, we are particularly concerned with the contextual information and the five-year historical information. The Commission proposes a granular definition of CapEx plans that will have an impact on internal management decisions that may not be in line with the overall purpose of the Taxonomy. We are particularly concerned with the time frame of five years and the requirement that the plan should be disclosed and approved by the Management Board.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The Confederation of Swedish Enterprise welcomes the European Commission's Chemical strategy for sustainability and a revision of REACH that makes the legislation simpler and more efficient. This combined with a strong and coordinated enforcement across the union will protect consumers, environment and ensure a level playing field and competitiveness for business. Our input is further developed in the attached file.
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

12 Apr 2021 · DGA

Meeting with Asa Webber (Cabinet of Commissioner Ylva Johansson)

25 Mar 2021 · Meeting about new rules on corporate governance and due diligence with focus on sustainability. The representative of the organization raised concerns about the consequences for both Swedish and other European companies.

Response to Instrument to deter and counteract coercive actions by third countries

9 Mar 2021

We see an increasingly geopolitical trade policy being developed and this initiative is very much a part of that new philosophy/strategy. This is regrettable as the aim of trade policy should be to open up markets and establish market access. It should not be to introduce measures to close markets or even threat to close them. At the same time, we can see that the world is changing rapidly and that other countries use trade policy tools to coerce the EU and its member states to act in certain ways. It might well be that a new instrument to counter this is needed, but we note a number of new initiatives which might also be relevant (not only the blocking statute) and want to ensure that the initiatives are not overlapping and that the cumulative effect does not become too administratively burdensome for European companies. We would like to refer specifically to the updated enforcement regulation as well as IPI. We want to ensure that any new initiative is WTO-compliant and we want the assessment to analyse how businesses could be affected. In general, businesses strongly dislike uncertainty. It would therefore be negative if this instrument gave the EU a blank check to impose any kind of sanction against third countries, that could well be negative for our own firms. Therefore, the issues related to the specifics of the counter measures and the forms of the stakeholder consultations are vital. Also, it is of great importance to find the right triggers for this instrument to be used. The triggers should be high so that the instrument is only used when vital interests are at stake and the coercion has a significant impact on the EU or its member states. Finally, we would ask the assessment to include the topic of cooperation with other countries when it comes to anti-coercion. It might well be the case that the most pursuasive and effective anti-coercion mechanism is a transatlantic one, or one which is co-ordinated with like-minded countries globally, which does hopefully not have to be used often because of its deterring effect.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

The Confederation of Swedish Enterprise supports the Commission's work on sustainable products, in accordance with the Circular Economy Action Plan. The Swedish business community is already at the forefront of this work, and wishes to play a leading role in developing and contributing constructively to the European Commission's work on the topic. The action plan contains a range of initiatives that the Confederation sees – if designed appropriately – can become valuable tools in enabling a transition into a circular economy. It is important that the work remains oriented towards securing the EU's long-term competitiveness. Electrification will be a vital tool in achieving the EU’s climate goals, and batteries will play an important role in the transition process. The Confederation of Swedish Enterprise is grateful for the opportunity to provide its inputs on the proposed battery regulation. Our comments address the proposal on a general level. The Confederation finds both positive parts and some more troublesome suggestions in the Commission´s proposal. For instance, it is for positive that the Commission has selected a specific range of batteries to be covered by the product passport requirements, and that such requirements do not automatically apply to all types of batteries. It is also positive that the Commission suggests establishing a database where companies can retrieve secondary data for carbon footprint calculations. On the other hand, The Confederation finds it problematic that the legislation is extensive and that a large number of issues will be dealt with through so-called delegated acts. The proposal also contains a range of new initiatives that will entail increased reporting requirements for companies, and it is important that the demands for providing information always is proportionate to the benefit that such information ultimately provides. Within certain areas, the Confederation also sees a risk of double regulation.
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Meeting with Arba Kokalari (Member of the European Parliament, Shadow rapporteur)

27 Jan 2021 · Digital Services Act

Response to Geographical indication protection at EU level for non-agricultural products

15 Jan 2021

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the Commission’s IP Action Plan Roadmap. It is an important initiative, as a strong IP framework is key to sustainable innovation. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). From our perspective, a new sui generis geographical indication right does not solve any problem that cannot be solved, or is already solved, by other means. Free movement and freedom of competition are two cornerstones for the European Union. All intellectual property rights must balance protection with freedom. Limiting free movement and freedom of competition is beneficial in certain situations, as for example patent rights are important as an incentive for innovation. However, that should only be done when other solutions are not already in hand. There are already rules applicable if someone would give misleading information regarding where a product comes from. All European countries in EU already have existing and established protection against unfair business practices relating to non-agri GIs. The protections against unfair competition has developed differently in different countries. However, there are at least a couple of points that are common to all different approaches – it is a provision for actors in trade with an existing effective remedy against unlawful and dishonest business of their competitors. In some countries, specific statutes providing for the repression of unfair competition also fulfil the function of consumer protection. In Article 6.1 b Unfair Commercial Practices Directive it is stated that it is considered as a misleading action when a commercial practice contains false information on not only commercial but also geographical origin. This is well in line with jurisprudence in the Member States even before the directive was implemented. Trade mark protection does to a large extent cover the same interests as a protection for geographical indications. Trade marks helps customers identify the commercial origin of a product. In order to help producers to market their products as guaranteeing a certain quality linked to their geographical origin a reform of the trade mark system may have to be done. That would serve the purpose better than to create a unitarian protection for non-agri GIs. The differences between agri and non-agri GIs are bigger than what has been argued for in surveys made by EU-Commission. The need and use of agri GI protection cannot and shall not be used analogously – since the very core of the instruments for protection differ from agri GIs. Employment, free movement and the equality of the Member States chances to let companies and people to have prospoerous expansions through existing and new businesses are risking to be hampered. Last spring, the Confederation of Swedish Enterprise published a memorandum on non-agri GI. This memorandum is enclosed.
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Meeting with Thierry Breton (Commissioner) and

13 Jan 2021 · The pandemic recovery and forthcoming Industrial Strategy

Response to Review of the Community Designs Regulation

12 Jan 2021

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the Commission’s IP Action Plan Roadmap. It is an important initiative, as a strong IP framework is key to sustainable innovation. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). The Confederation of Swedish Enterprise shares the view that it is important to modernize and further harmonize the EU legislation on design protection. The creation of a design protection for the EU took several important steps, not the least in creating a protection with a design approach. This approach is the foundation of a protection that is still largely fit for purpose. However, there are some concerns. In a world where design is becoming of greater and greater importance design protection is underused, not only by SMEs but by all types of actors. This underuse must be addressed in a clearer way. As is pointed out, this may be caused by too complex procedures and a structure of fees that is not optimal. The strength of the protection, the likelihood that a registration will hold in court, is another important factor. This means that it is not enough to only improve accessibility and affordability of design protection in the EU. The certainty of the protection must also be improved. Here, digital solutions may be used. The modernization of the trademark protection that was recently done may serve as a benchmark for modernizing also the design protection. This concerns both the changes when it comes to what can be covered by design protection and the procedures regarding registration. The complexity of design protection is even greater for companies operating also outside the EU. There are still many differences between not only the legal foundations in different parts of the world but also the procedures for registration. It would therefore be beneficial if the EU took lead in harmonizing design protection internationally. Another problem is however the lack of knowledge. EUIPO has done tremendous work in sharing knowledge on intellectual property. This work must continue. Unfortunately, the lack of knowledge may lead to that many do not even know what to look for. New measures must be taken to reach those who do not realize that they lack knowledge. When it comes to protection of spare parts harmonization is important. The aim should be that spare parts are protected under design protection. The protection of spare parts was one of the most difficult question in creating the design protection that we have today. Many things have however changed since then. Today, all types of operations have to aim to be a part of a circular economy. One important part of the circular economy is the life length of different products. In order to improve the life length of their products, companies have to invest also in developing spare parts. Those investments strive for making repairs easy but at the same time preserve the safety of the product. Competition today is global. Companies in the Member States have to compete on the ability to make their products fit for a circular economy with companies from for example the US, Japan, China, South Korea and Brazil. In all these countries, there is no equivalent to the limitations in protecting spare parts as we have in the EU. This is a clear disadvantage for companies here. A harmonization of the protection of spare parts should therefore be to of a kind that creates an incentive for investing in developing spare parts. All other options create a disadvantage for Europe in the circular economy.
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Swedish Enterprise calls for cost-effective national climate targets

26 Nov 2020
Topic — The European Commission is reviewing national emission reduction targets for 2030.
Message — The organization advocates for national targets based on cost-effectiveness rather than GDP per capita and proposes a minimum carbon tax across all member states. They also stress avoiding double regulation and double pricing of emissions.123
Why — Swedish companies would benefit from a more level playing field where other member states carry a fairer share.45
Impact — Lower-income member states would lose the preferential target treatment they currently receive based on their GDP.67
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Swedish Enterprise urges ETS focus on carbon leakage protection

26 Nov 2020
Topic — Updating the EU Emissions Trading System to meet higher 2030 climate targets.
Message — The organization opposes including more sectors in the ETS and demands a harmonized system for indirect cost compensation. They argue that stopping carbon leakage must remain the central focus of climate policy.123
Why — These changes would protect their export competitiveness and provide funds for members already using clean power.45
Impact — Member states with coal-dependent power sectors would lose their current advantage in receiving compensation funds.67
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Response to Sustainable Products Initiative

16 Nov 2020

Se attached file
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Swedish Enterprise urges cost-effective energy efficiency and growth

21 Sept 2020
Topic — The European Commission is reviewing energy efficiency rules to meet 2030 targets.
Message — The group argues that increased energy consumption should not automatically require more savings efforts. They stress that energy efficiency must remain cost-effective and support electrification even if demand increases.123
Why — Companies would avoid additional compliance costs during periods of economic expansion or electrification.4
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Response to Intellectual Property Action Plan

13 Aug 2020

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the Commission’s IP Action Plan Roadmap. It is an important initiative, as a strong IP framework is key to sustainable innovation. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). As intangible, knowledge-based, assets are cornerstone of today’s economy, The Confederation of Swedish Enterprise has adopted an IP Strategy which is being launched 2019-2020. The strategy is focused on five identified challenges. The challenges are: 1. Lack of knowledge 2. Not making the most of existing assets 3. New technical reality 4. Globalization 5. Rules in need of change The Confederation of Swedish Enterprise is happy to contribute to the debate on knowledge-based assets. Regarding this Roadmap, we will limit ourselves to a few targeted comments. Upgrade of the IP framework The Confederation of Swedish Enterprise supports upgrading the existing system for IP protection. The entry into operation of the Unitary Patent system (including the Unitary Patent and the Unified Patent Court) remains the highest of our priorities. Those of our members that are affected, would also welcome the introduction of a fair and balanced unitary supplementary protection certificate (SPC). Regarding copyright, the legal situation today is most unfortunate. It is almost impossible to comprehend. More than a dozen EU-directives, jurisprudence from ECJ alongside national legislation and jurisprudence makes it difficult even for lawyers. There is a need of a copyright regulation, harmonizing copyright. The modernisation of the EU legislation on design protection is another priority. Promote a better uptake and deployment of IP There is much to be done to ensure that SMEs use IP in the best possible way. The main problem is lack of knowledge. It is however not enough to just raise awareness. To achieve concrete results, there is a need to strengthen interaction between EU institutions, IP national offices, local, regional and national authorities, business associations and SMEs. Promote better licensing and sharing of IP-protected assets Promoting better licensing in the copyright market would be welcomed. However, the major obstacle to license copyright within EU is still the legal differences. A copyright regulation is necessary. Today, the transaction costs for licensing copyrighted works to other countries within EU can be substantial due to the need to investigate whether specific clauses are allowed also in those countries. When it comes to registered rights we are not certain that there is a real problem to reach licenses. There are also several initiatives taken in the current situation, such as https://opencovidpledge.org/ Regarding data, it is important that the desire to promote sharing of data is balanced with the interest to protect data as an intangible asset. Fight IP theft – enforcement It is fundamental that the EU upholds and strengthens its commitment to fighting counterfeiting, unlawful transfer of technology and other illegal practices which ultimately deprive IP right holders of their legitimate rights. The legal protection for trade secrets also has to be strengthened in EU, the current directive leaves out important parts. Promote a global fair play The Confederation of Swedish Enterprise supports a robust global level playing field for IP protection and enforcement, consistent with the EU trade strategy. This fosters innovation and expands economic opportunities. It is important that strong and harmonised IP standards are guaranteed in any attempts to reform bilateral and multilateral trade agreements. However, it is equally important that trade agreements can be updated when IP rules must be updated due to new technical possibilities such as AI.
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Response to Chemicals strategy for sustainability

17 Jun 2020

The Confederation of Swedish Enterprise welcomes the Chemicals Strategy for Sustainability as part of the zero-pollution ambition for a toxic-free environment, announced in the European Green Deal in December 2019. It is positive that the EU-commission emphasizes the importance of chemicals to our society. Chemicals are essential to society and play an important role to deliver climate ambitions and are used in almost all our products to deliver specific functions and features. The chemical industry produces the building blocks and materials on which a modern, climate-neutral and resource-efficient society will be built. A safe handling of chemicals to ensure a high level of protection to the environment and to human health is a prerequisite. Although agreeing on the main objective of the strategy we would like to give the following input that we believe are essential to reach the objective and also to ensure the synchronization of the strategy to other policy areas in the Green Deal. The following aspects are important in the continued development of the strategy: • Ensuring a high level of protection to human health and the environment while encouraging innovation and development of safe and sustainable chemicals. • Simplifying the legal framework and improving coherence between existing legislations, for example the chemical-, product and waste legislations, by filling the existing gaps and clarifying the interfaces. • The ‘’one substance-one assessment’’ approach should be a key element to reduce the number of chemical related legislations, increase coherence and clarify the interface between different regulatory processes. • Continue to build on the already solid legislative framework with improvements, better implementation and stronger enforcement. The regulatory framework will need to proportionately and robustly manage risks posed by endocrine disruptors, hazardous chemicals in products including imports, combination effects of different chemicals and very persistent chemicals. Science needs to remain at the heart of decision-making. • Support EU’s strategic autonomy in the production of essential chemicals across key sectors and promote research, innovation and development for the sustainable transformation of the chemical industry and the creation of green and sustainable manufacturing capacity in Europe. • The chemicals strategy is linked to The Circular Economy Action Plan as chemical content is essential in product design, primary production, recycling and the market for secondary materials. It is therefore vital that actions in the Chemical strategy for sustainability and the Circular economy action plan are synchronized to a great extent. • Chemical content in recycled material is an important issue that needs to be handled carefully and in a balanced way to facilitate and not hinder recycling and use of recycled material. Information about chemical content is important but to phase out certain substances may be is a challenge in the short term, since recycling will continue and increase. Some substances also occur naturally in some materials and others contribute with a specific function and alternatives may take time to develop. A risk-based approach is therefore crucial where the risk to the environment and to health with a substance in a specific application is evaluated. Clear considerations and methods are needed to deal with this matter. We find it worrying that no impact assessment is foreseen for the Strategy as a whole. We hope that the upcoming Chemicals Strategy for Sustainability represents a key opportunity to achieve the objectives of a zero-pollution ambition in the framework of the Green Deal, and that the strategy facilitates the circular transition in the society. (The Confederation of Swedish Enterprise (Svenskt Näringsliv) is Sweden’s largest business federation representing 50 member organizations and 60 000 member companies.)
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Swedish industry demands growth focus and delayed climate targets

30 Apr 2020
Topic — Legislative proposal to enshrine the 2050 climate neutrality objective into law.
Message — The organization insists that all Member States individually achieve climate neutrality by 2050. They argue discussions regarding 2030 targets must be delayed until businesses recover from the pandemic. They also oppose using delegated acts to modify the climate neutrality trajectory.123
Why — This would preserve business competitiveness and provide investment predictability during economic uncertainty.45
Impact — Less ambitious nations lose the opportunity to rely on collective progress.6
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Swedish Enterprise urges delay of EU 2030 climate target discussion

15 Apr 2020
Topic — The European Commission proposes increasing the EU's 2030 greenhouse gas emission reduction targets.
Message — The group urges delaying 2030 target talks until post-pandemic economic impacts are assessed. They suggest non-ETS sectors should bear the main part of any increased ambition. Strengthened safeguards are requested to protect industrial competitiveness and prevent carbon leakage.123
Why — Delaying targets avoids imposing additional costs on industry during a global economic recession.45
Impact — Non-industrial sectors would face tougher regulations if they must absorb the increased climate burden.6
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Swedish Industry Urges WTO-Compatible Carbon Border Price

1 Apr 2020
Topic — The EU is consulting on a carbon price for imported goods.
Message — The Confederation supports a well-designed mechanism that is WTO-compatible and avoids trade friction. They argue it must address export competitiveness and include direct and indirect emissions. The initial scope should be limited to sectors with easily estimated carbon content.123
Why — This would protect Swedish export competitiveness while mitigating rising production costs.45
Impact — Non-EU trading partners and exporters face higher costs and new trade barriers.67
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Confederation of Swedish Enterprise urges growth-focused climate law

6 Feb 2020
Topic — EU legislation aimed at making the 2050 climate neutrality target legally binding.
Message — They demand predictable rules that protect competitiveness and prevent industries from relocating. The group requests streamlined policy reviews and regulations that avoid mandating specific technologies. Flexible implementation is needed for cost-efficient innovation and growth.123
Why — This approach protects existing investments and reduces the risk of industrial relocation.4
Impact — Laggard member states would face stricter enforcement and lose their current advantages.5
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Response to Strengthening the principle of equal pay between men and women through pay transparency

31 Jan 2020

The Confederation of Swedish Enterprise are staunch advocates for greater work life equality, see reports in attached file. It is our firm conviction that achieving greater gender equality is essential for the realization of the full potential of all individuals and undertakings. Research shows that workplaces where both men and women work achieve better business results and build better workplace communities. It is thus well established that striving for diversity in staffing and recruitment leads to positive business results. Having experience from binding pay transparency measures in the form of pay surveys, we are equally convinced that the latter is not the way to close the gender pay gap. On the contrary, as shown by the recent evaluation undertaken by the Swedish National Audit Office, such legislation is a blunt instrument for reducing the gender pay gap (RiR 2019:16, summary available in English). Regarding our experience see further Comments on pay surveys – the Swedish case in attached file. As the situation differs greatly between the member states of the EU, there are no one-size-fits all solutions. Priorities and measures have to be set according to the specific needs, conditions and prevailing culture and attitudes in the different national labour markets. There are also no quick fixes. Sweden has the highest female labour market participation rate in the EU, resulting from decades of active policy and individual preferences. Measures that have promoted gender equality in Sweden include the following: • The scrapping of family taxation and the introduction of individualized taxation. • The expansion of care services for children and the elderly. • The expansion of public sector services, creating employment opportunities for women. • Increased participation of women in higher education (currently, Swedish women have higher levels of education than Swedish men). • Legislation introducing compensation for parental leave which is the same for both parents (including when caring for sick children). • Changes in values and perceptions with respect to the roles of women and men. The principal reasons for current differences in pay between men and women in the Swedish labour market are: • Differences in pay between profession and sectors, resulting from the gender segregation of the Swedish labour market. • Differences in working time between women and men, as women work part-time to a much greater extent than men, taking overall responsibility for family and children (e.g. parental leave and care leave), impacting negatively on career and wage developments. • The fact that women to a greater extent than men choose time off instead of pecuniary compensation (e.g. shorter working hours and less over time work). Measures that would contribute to further gender equality in the Swedish labour market include: • A more even distribution of girls and boys on educational programs and courses, in particular STEM and care-related profession respectively. • A more even distribution of women and men in the different sectors of the labour market, including at the level of specific professions. • A more even distribution of parenting responsibilities and domestic work between men and women. • Active gender and diversity measures at company level in the areas of recruitment, skills development, corporate culture, work organisation and management as well as gender-neutral wage setting. • Continuous efforts to change attitudes and views with respect to the roles of women and men in their professional and private lives. • Information about the consequences of different life choices with respect to professional careers and pensions. • Special information targeted at recent immigrants. Regarding the Confederation of Swedish Enterprise's positions with respect to greater work life equality, see also Platform for competencies and gender equality in attached file.
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Meeting with Nele Eichhorn (Cabinet of Executive Vice-President Margrethe Vestager)

22 Jan 2020 · Industrial policy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Phil Hogan)

21 Jan 2020 · Digital trade and Industrial policy

Response to A new Circular Economy Action Plan

20 Jan 2020

It is positive that the Commission will present a Circular Economy Action plan and that the plan will be adopted together with the EU Industrial Strategy since they need to be synchronized. Our input to the consultation is a report on circular economy that we produced in 2019 where we highlight important principles and the needs of the Swedish business sector to be able to become more circular and implement circular business models.
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

8 Oct 2019 · Future of Europe

Response to More efficient law-making in social policy: identification of areas for an enhanced move to qualified majority voting

18 Jan 2019

The Confederation of Swedish Enterprise strongly opposes the European Commission’s proposal to introduce more qualified majority voting in the area of social policy. • The Commission wrongly asserts that this is a response to citizens’ expectations, and not identified problems, while that which has been expressed are their concerns. Such common interests do not automatically translate into a need for common measures, in particular with respect to topics the standards of which the social scoreboard has shown differ greatly between member states (MS). • The social dimension of Europe must be rooted in employment creation and active participation in society, focusing on e.g. the tackling of youth and long-term unemployment. For this Europe needs more jobs, the connection between people working and social welfare cannot be stressed enough. A social Europe is a Europe where people work. Conversely, there will be no social Europe without jobs. • Furthermore, things must be done in the right order, namely: companies must be ensured the right preconditions for job creation. This is how we create a social Europe. The path towards fairer jobs and markets runs through economic development. In this globalized world, amid fierce international competition, the EU needs to provide the best possible conditions for its MS, citizens and companies to succeed. It is only by removing barriers for enterprising people and competitive companies that the EU can become a real driver for continued and sustainable prosperity for all. • Current differences in work and living outcomes between MS mainly stem from differences in economic development and employment – not from differences in national labour market regulations or other social rights. Labour market reforms can only be determined at national level, while forced harmonization creates harmful divisive debates on the role of the EU and those of the MS and, in the end, turns people against Europe. National competences must be respected. • The areas under unanimity voting rules are core pillars of national socio-economic systems, issues that are of primary importance in national democratic political debates and elections as well as for national social partners. We believe that the EU institutions must respect the highly varied social policy traditions and the country-specific structures of labour relations and social protection systems. • Recent proposals in the social area already go too far, constituting a direct threat to our labour market model where the social partners have a high degree of freedom to regulate working and employment conditions. Our collective agreement model has many advantages. It creates conditions conducive to long term stability in the labour market that can be adjusted to different sectors, making the regulation flexible. Consequently, this model lays the foundation for strong competitive capabilities. • We are convinced that the conditions, traditions and positions of each MS must be the point of departure. The diversity of Europe is a competitive advantage that must be put to better use. Recent pledges to take into account the diversity of national systems and the key role of social partners are but acknowledgements of such efficiency and legitimacy. • The European Commission needs to take initiatives in a targeted and balanced way on topics where there is a clear role and added value for the EU to act, building on the existing processes such as the EU semester and focusing on delivering mutually beneficial outcomes for companies, workers and citizens. This is how Europe will move forward in unity. • If efficiency in the legislative process is really desired then focus should turn to practices such as trialogues, a black box phenomenon which by lacking in transparency, and, hence, accountability and eventually legitimacy, produces legislation of extremely poor quality which is both difficult to implement and to enforce.
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Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

19 Nov 2018 · General presentation of DSM

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker)

19 Nov 2018 · Working dinner on the Future of Europe

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

6 Nov 2018 · Digital trade

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

7 Sept 2018 · Artificial Intelligence

Response to Detailed measures for the Definitive VAT System

24 Aug 2018

The Confederation of Swedish Enterprise have been given the opportunity to comment on the EC-proposal for a directive which contains the technical details of the definitive VAT system for intra-Union trade (COM (2018) 329 final). We provide a summary enclosed which states the core of our concerns and views of the proposal. Summary • We support the EU Commissions efforts to modernize the EU VAT-system, reduce the compliance burden and reduce levy losses. • We support the proposed destination principle. • We oppose the proposed model where the supplier is liable for charging VAT on cross border B2B EU trade. • The proposal is opposed due to its harmful effects on the Swedish business community. The proposed system of taxation causes a cost of capital, according to an analysis of the VAT reporting at twelve large industrial companies, that can range from 84 million to over 1 billion SEK (depending on repayment and capital interest rates) per annum. • The proposals negative capital cost effects occur since several Swedish companies are net re-payers of VAT (entitled to a VAT refund) regarding cross border trade and that Sweden have a shorter repayment time, 11 days compared to the EU average of 60 days. • Companies have stated that the cost of capital could exceed the transportation cost. In combination with higher business risk due to flaws in the OSS system, business may change their supply chains with the risk of hampering intra union trade. This will also cause negative environmental effects due to increased and longer transports. • We believe that the VAT system regarding cross-border EU-trade would be improved through an equal treatment of goods and services. This could be achieved with an improved reverse charge mechanism when it comes to cross-border trade. • We believe that the proposed OSS system is insufficient, uncertain and contains flaws that cannot be ignored. • We strongly oppose the introduction of the “certified taxable person” (CTP). • We state that the proposal will result in higher amounts of VAT in the system. Implying larger risks for other forms of fraudulent behavior and levy losses. • We consider that uncertainties exist regarding the information exchange between Member States with consideration to GDPR. • We question if the reason for some proposed provisions (e.g. article 12 and 19) is stated in a sufficient way, fulfilling the Commissions obligation laid down in article 296 FEUF. More details in Swedish regarding the above is found in our answer to the Swedish Ministry of Finance, please see the following link. https://www.svensktnaringsliv.se/material/remissvar/remissvar-100-2018pdf_716160.html/BINARY/Remissvar%20100-2018.pdf
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Response to Targeted revision of EU consumer law directives

14 Jun 2018

The Confederation of Swedish Enterprise ("Svenskt Näringsliv") is Sweden's largest and most influential business federation representing 49 member organizations and over 60.000 member companies with over 1.6 million employees. It represents almost all sectors of business with the exception of the banking industry. The Confederation of Swedish Enterprise was founded in 2001 through the merger between the Federation of Swedish Industries (founded in 1910) and the Swedish Employers' Confederation (founded in 1902). The Confederation of Swedish Enterprise opposes the Commission's proposal for a directive. We see no need for any EU-wide collective redress measures. The proposal lacks several of the principles for safeguards that the Commission itself has put forward [see Recommendation 2013/396/EU of 11 June 2013] as necessary to guarantee that fundamental procedural rights of the parties are preserved and to prevent abuse. Those safeguards - such as articles on opt-in, on the loser pays-principle, on prohibition of punitive damages, on restricted use of contingency fees and on conditions that must be met to initiate a collective redress case - are in our view essential to prevent unmeritorious claims and to discourage speculative litigations. A directive without all the safeguards of the Recommendation increases the risk for abuse and leeds straight to the type of litigation culture that surrounds Americain class actions. In addition to this, we have objections to several of the proposed articles, for example regarding third party funding. The introduction of fines for non-compliance with a final decision issued in a collective redress case conflicts the principles of proportionality and subsidiarity and also Swedish legal principles. The proposals that the redress (compensation) and fines shall be directed to a public purpose serving the collective interests of consumers will encourage speculative litigations and should therefore be rejected. Please find attached our comments (in Swedish) regarding COM (2018) 184.
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Response to Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

7 May 2018

Please, find the comments by the Confederation of Swedish Enterprise in the attached file.
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16 Mar 2016 · Seminar on Circular economy

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22 Jan 2015 · TTIP

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