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DigitalTrade4.EU

DigitalTrade4.EU is a collaborative platform advancing digital trade, interoperability, and regulatory alignment in the European Union.

Lobbying Activity

Response to Digital package – digital omnibus

7 Oct 2025

Our feedback outlines how the European Trade Indexes Registry (EUTIR) can strengthen the EUs Digital Omnibus initiative by providing a unified, cross-sector trust infrastructure that ensures interoperability, reduces administrative burdensespecially for SMEsand enhances legal certainty across digital trade, sustainability, customs, and financial frameworks.
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Response to Formats of advanced electronic signatures and seals to be recognised by public sector bodies

26 Sept 2025

Our feedback supports the European Commission in refining the draft Implementing Regulation on advanced electronic signatures and seals, with a focus on ensuring interoperability, SME accessibility, and international alignment. Drawing on UNCITRAL and World Bank principles, we propose targeted amendments and advocate for the integration of trusted digital infrastructuresparticularly the European Trade Indexes Registry (EUTIR)to strengthen legal certainty, reduce administrative burdens, and position the EU as a global leader in secure, sustainable, and digitally enabled trade.
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Response to Acceptance of supply contracts as proof of origin for certain tariff rate quotas

25 Sept 2025

Our feedback on the European Commissions draft Implementing Regulation highlights targeted improvements to the proof of origin requirements for poultry tariff rate quotas, while advocating for the integration of the European Trade Indexes Registry (EUTIR) as a Union-wide trusted digital layer to ensure authenticity, traceability, and legal certainty across Member States.
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Response to Revision of EU antitrust procedural rules

25 Sept 2025

Our feedback to the European Commission highlights the strategic role of the European Trade Indexes Registry (EUTIR) in modernising EU antitrust procedural rules. As digital markets generate vast, complex evidence, traditional enforcement tools are no longer sufficient. EUTIR offers a trusted, immutable, and machine-readable digital infrastructure that enhances transparency, accelerates interim measures, reduces administrative burdensespecially for SMEsand ensures coherent, cross-border competition enforcement. By integrating EUTIR into the revision of antitrust procedures, the EU can strengthen legal certainty, digital sovereignty, and its global leadership in trusted digital trade.
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Response to Roadmap towards Nature Credits

24 Sept 2025

Our feedback outlines a strategic proposal to integrate Nature Credits into the European Trade Indexes Registry (EUTIR), establishing a unified digital trust infrastructure for environmental, trade, and sustainability data. By anchoring Nature Credits within EUTIRs accredited certification framework and immutable metadata lifecycle, the EU can ensure high-integrity, legally enforceable, and interoperable credits that align with key instruments like the Digital Product Passport (DPP), Carbon Border Adjustment Mechanism (CBAM), and electronic Freight Transport Information (eFTI). This approach prevents greenwashing, reduces administrative burdensespecially for SMEsand positions Europe as a global leader in trusted, green-digital trade.
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Response to 28th regime – a single harmonized set of rules for innovative companies throughout the EU

23 Sept 2025

Our feedback to the EU Commission on the proposed 28th regime for an EU corporate legal framework highlights its potential to significantly strengthen Europes business environment by reducing legal fragmentation and lowering administrative burdens. We emphasize that while the 28th regime establishes a unified legal company form, its full potential can only be realized by integrating it with the European Trade Indexes Registry (EUTIR). EUTIR serves as the essential digital trust infrastructure, ensuring the authenticity, interoperability, and real-time verifiability of corporate data across borders. Together, they create a trusted EU company brand that is both legally recognized and digitally verifiable, enhancing Europes attractiveness for investment and providing SMEs and startups with easier access to financing. This document combines a simplified impact assessment of the 28th regime with a detailed analysis of EUTIRs role, aiming to guide the Commission in aligning corporate law with Europes broader digital transformation goals.
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Response to Evaluation of the Defence Transfers Directive

22 Sept 2025

Our feedback proposes integrating the European Trade Indexes Registry (EUTIR), a decentralised digital trust infrastructure based on Distributed Ledger Technology, into Directive 2009/43/EC on intra-EU transfers of defence-related products. This integration aims to address the Directives longstanding implementation challengessuch as fragmentation, administrative burden, and low SME uptakeby providing a secure, interoperable, and legally reliable system for registering licences and certificates. EUTIRs dual-use design not only revitalises the defence transfers framework but also aligns it with broader EU digital, green, and security priorities, enhancing supply chain resilience and Europes strategic autonomy.
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Response to Sequential recording of data into qualified electronic ledgers

22 Sept 2025

Our feedback on the draft Implementing Regulation for Qualified Electronic Ledgers aims to future-proof the legal framework by embedding essential functionalitiessuch as metadata lifecycle management, exclusive control, and harmonised certificationthat ensure interoperability and legal validity across all electronic documents. We advocate for these amendments to lay the groundwork for a Digital Business Wallet and to align seamlessly with upcoming Union-wide digital registries like EUTIR, thereby supporting the Single Markets green and digital transition while safeguarding Europes digital sovereignty.
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Response to General requirements for qualified trust service providers

22 Sept 2025

Our feedback presents targeted proposals to strengthen the draft Implementing Regulation for Qualified Trust Service Providers (QTSPs) under eIDAS 2.0. We advocate for enhanced legal certainty, global interoperability, and robust cybersecurity by embedding core principles like exclusive control over digital records, immutable metadata audit trails, and the mandatory use of globally recognised identifiers (e.g., LEI/vLEI alongside EORI). Drawing on the complementary European Trade Indexes Registry (EUTIR) framework, we outline how QTSPs can serve as the foundational trust layer for the EUs digital economy, enabling secure cross-border trade, SME finance, and seamless integration with initiatives like the Digital Product Passport and CBAM.
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Response to EU Drugs Strategy and European Action Plan Against Drug Trafficking

22 Sept 2025

Our feedback to the European Commission proposes leveraging the European Trade Indexes Registry (EUTIR) as a critical digital trust infrastructure to enhance the upcoming EU Drugs Strategy (2026-2030). In response to the increasingly complex threats posed by drug trafficking, synthetic opioids like nitazenes, and AI-powered organized crime, we argue that EUTIRs capabilities in ensuring document immutability, supply chain transparency, and cross-border data interoperability can act as a force multiplier. By providing a secure, auditable layer for customs, financial, and logistics data, EUTIR directly supports the strategys core pillars: disrupting trafficking routes, combating money laundering, reducing corruption, and strengthening international cooperation. This document details how EUTIRs technical framework aligns with and amplifies the EUs goals for preparedness, security, and harm reduction in the fight against illicit drugs.
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Response to Review of the Digital Markets Act

21 Sept 2025

Our feedback proposes the European Trade Indexes Registry (EUTIR) as a foundational, cross-sectoral trust layer to empower the enforcement of the Digital Markets Act (DMA) and accelerate the EUs digital and green transitions. Designed as a decentralized, blockchain-based infrastructure, EUTIR ensures the authenticity, traceability, and interoperability of electronic trade documents and data, transforming how gatekeeper compliance is monitored and verified. Beyond simplifying reporting for designated gatekeepers under Articles 511, EUTIR serves as a proactive early-warning system, enabling regulators to detect emerging market dominance by analyzing metadata patterns across domains like Digital Product Passports, freight information, and sustainability reporting. This positions EUTIR not merely as a compliance tool, but as a strategic enabler for contestable, transparent, and resilient digital markets, reducing regulatory burdens for SMEs while strengthening consumer trust and legal certainty across the Single Market.
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Response to Adjustment of the obligation to surrender CBAM certificates to take account of ETS free allowances phase-out

12 Sept 2025

Our feedback proposes integrating the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to strengthen the implementation of the Carbon Border Adjustment Mechanism (CBAM). By anchoring emissions data, EU ETS free allocation benchmarks, and foreign carbon price payments through cryptographic hashes, unique identifiers, and Mutual Recognition Agreements, EUTIR enhances verification, reduces administrative burdensespecially for SMEsand ensures global interoperability. This alignment supports the Commissions objectives with greater accuracy, transparency, and efficiency, positioning CBAM not just as a climate tool, but as a model for secure, interoperable green-digital trade.
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Response to Carbon border adjustment mechanism (CBAM) methodology for the definitive period

12 Sept 2025

Our feedback proposes integrating the CBAM implementing acts with the European Trade Indexes Registry (EUTIR) and eIDAS 2.0 to transform CBAM from a compliance mechanism into a trusted digital trade infrastructure. By leveraging secure identifiers, machine-readable metadata, and digital trust services, this alignment reduces administrative burdensespecially for SMEsenhances transparency, ensures legal certainty, and strengthens the EUs global leadership in climate and digital standards.
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Response to Carbon price paid in a third country under the carbon border adjustment mechanism (CBAM)

12 Sept 2025

Our feedback proposes integrating the Carbon Border Adjustment Mechanism (CBAM) with the European Trade Indexes Registry (EUTIR) to create a trusted, interoperable digital foundation for carbon price deduction and compliance. This linkage ensures authentic, machine-readable verification of third-country carbon payments, reduces administrative burdensespecially for SMEsand strengthens legal certainty, global interoperability, and the EUs leadership in green-digital trade standards.
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Response to Legislative initiative on CO2 transportation infrastructure and markets

10 Sept 2025

Our feedback to the European Commission links the development of a CO Market and Infrastructure with the EU Trade Framework 2025 (EUTIR), advocating for a unified digital trust backbone. We demonstrate how EUTIRs secure, interoperable registry can provide legal certainty, reduce risks, and enable SME access for cross-border carbon transport and storage. By integrating with key initiatives like CBAM, eFTI, and the Digital Product Passport, EUTIR ensures traceability and authenticity of CO data, reinforcing Europes global leadership in the green-digital transition.
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Response to Amendment to Appendix A of Annex II to Directive 2009/48/EC on the safety of toys as regards cobalt

8 Sept 2025

Our feedback proposes integrating the EUs cobalt-in-toys safety regulation into the broader EU Trusted Digital Trade Frameworkspecifically through the European Trade Indexes Registry (EUTIR), Digital Product Passport (DPP), and eIDAS 2.0. This strategic alignment transforms toy safety compliance from a fragmented, paper-based process into a seamless, real-time, and globally interoperable digital system. By anchoring safety data in trusted digital infrastructure, we enhance child protection, reduce administrative burdens for SMEs, empower consumers with transparency via QR codes, and position the EU as a global leader in digital product governance. The document includes concrete legal amendment proposals to embed cobalt compliance into the DPP, secure it with qualified digital signatures, link it to LEI/vLEI identifiers, and verify it instantly through EUTIR.
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Response to Organic Production : amended list of products and substances authorised for use in organic productions

8 Sept 2025

Our feedback to the European Commission proposes a strategic alignment between the evolving rules for organic production and the emerging European Trade Indexes Registry (EUTIR) digital infrastructure. We argue that integrating amendmentssuch as the authorization of new processing aids and transitional cleaning agent provisionswith EUTIRs capabilities for metadata management, immutable audit trails, and digital trust (via eIDAS 2.0, LEI/vLEI, and Digital Product Passports) will significantly enhance regulatory transparency, reduce administrative burdens for operators, and strengthen cross-border market surveillance. This integration positions the organic sector as a pioneering use case for Europes broader green and digital transition, ensuring that sustainability and technological innovation advance in tandem.
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Response to EU vision for enhancing global climate and energy transition

7 Sept 2025

This document presents a detailed proposal for the European Trade Indexes Registry (EUTIR), envisioned as a foundational digital trust layer for the EUs carbon market, trade infrastructure, and broader green transition. Submitted as feedback to the European Commission, it argues that EUTIR is a critical, cross-cutting digital infrastructure designed to ensure the interoperability, traceability, and verification of product, trade, financial, and sustainability data (including CBAM, DPP, and ESG metrics). By anchoring data in a secure, blockchain-based registry using global identifiers (LEI/vLEI), EUTIR aims to reduce administrative burdens (especially for SMEs), enhance market surveillance, and solidify the EUs global leadership in trusted, digital, and sustainable trade.
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Response to Delegated Act on RCB, determination of liquid markets for equity instruments, and PTRR services

3 Sept 2025

Our feedback outlines a strategic vision for strengthening the EUs New Legislative Framework (NLF) and broader trade governance through the proposed European Trade Indexes Registry (EUTIR). This comprehensive contribution supports the ongoing NLF revision and aligns with key EU initiatives such as the Digital Product Passport (DPP), electronic Freight Transport Information (eFTI), and the Carbon Border Adjustment Mechanism (CBAM). EUTIR is designed as a horizontal, digital trust infrastructure that anchors metadatasuch as cryptographic hashes, timestamps, and globally unique identifiersof trade-related documents, ensuring authenticity, traceability, and machine readability without storing full document content. By leveraging decentralized ledger technology (DLT), eIDAS 2.0 qualified trust services, and the integration of Legal Entity Identifiers (LEI/vLEI) with the EUs EORI system, EUTIR enhances regulatory coherence, reduces administrative burdensparticularly for SMEsand strengthens market surveillance and consumer trust. The proposal calls for coordinated governance across DG FISMA, DG TRADE, and DG TAXUD, and advocates for synergy with the MiFIR reforms and the future Customs Data Hub to ensure interoperability across financial, trade, and sustainability domains. Notably, Annex I, which provides a detailed visual and procedural model of the data set lifecycle and the accreditationcertification flow, has been developed separately and is intended to inform the drafting of future legislative acts, ensuring a clear, implementable framework for EUTIRs rollout.
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Response to Sustainable transport investment plan

3 Sept 2025

The document presents a comprehensive proposal for the European Union Trade Index Registry (EUTIR), a digital infrastructure designed to enhance the authenticity, traceability, and legal validity of electronic trade, transport, customs, and compliance documents across the EU. Developed by the DigitalTrade4.EU consortium, it outlines a metadata-based registry system that anchors cryptographic hashes, timestamps, and standardized identifiers (such as LEI, vLEI, and EORI) without storing full document content. EUTIR leverages technologies like Digital Ledger Technology (DLT), eIDAS 2.0, JSON-LD, and XBRL to support secure, interoperable, and auditable data exchange across key EU frameworksincluding CBAM, Digital Product Passport (DPP), eFTI, and the Customs Single Window. It introduces critical functionalities such as document versioning, parent-child relationships, flagging/locking by authorities, and two-layer verification for public and restricted access. Targeted at the European Commission, the document serves as input for the Sustainable Transport Investment Plan (STIP) and broader regulatory reforms, advocating EUTIR as a foundational element for reducing administrative burdens, preventing fraud, enabling green-digital trade, and positioning the EU as a global leader in trusted, sustainable digital trade.
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Response to Review of the Merger Guidelines

3 Sept 2025

The document is a comprehensive feedback to the European Commissions Call for Evidence on the Review of the Merger Guidelines. It advocates for modernizing the EUs merger control framework to align with the green and digital transitions, emphasizing the integration of data-driven competition, sustainability, and resilience into merger assessments. Central to the proposal is the European Trade Indexes Registry (EUTIR), a digital trust infrastructure designed to enhance legal certainty, interoperability, and real-time market surveillance across the Single Market. The document outlines how EUTIR can support merger control through standardized data exchange, AI/ML-enabled risk monitoring, and transparent compliance tracking, while ensuring alignment with key EU regulations such as the Digital Product Passport (DPP), eIDAS 2.0, NIS2, and the AI Act. It also provides detailed use cases, governance models, and policy recommendations to strengthen competitiveness, SME inclusion, and global interoperability.
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Response to Omnibus Regulation Aligning product legislation with the digital age

3 Sept 2025

Our feedback addresses the European Commissions proposal COM(2025) 504 and its annexes, focusing on the integration of the European Trade Indexes Registry (EUTIR) into the New Legislative Framework (NLF). We propose EUTIR as a foundational digital infrastructure that ensures legal validity, traceability, security, and interoperability of electronic trade documents across the EU. Built on Distributed Ledger Technology (DLT) via the European Blockchain Services Infrastructure (EBSI), EUTIR registers metadata recordsincluding cryptographic hashes, timestamps, status indicators, and identifierswithout storing full document content, thus ensuring privacy, immutability, and long-term auditability. The framework supports machine-readable formats such as JSON-LD, XBRL, ISO 20022, and alignment with UN/CEFACT CCL and WCO Data Model to enable cross-sector interoperability between customs (eFTI), sustainability (CBAM, DPP), finance, and logistics systems. We define key concepts including versioning, parent-child relationships, and lifecycle statuses (e.g., active, superseded, flagged, locked, cancelled, terminated), ensuring legal certainty and automated compliance. Our submission includes 14 detailed use cases demonstrating EUTIRs application in real-world scenarios: contract versioning, insurance policy linkage, customs declaration amendments with validity inheritance, AML monitoring by financial institutions, CBAM verification, Digital Product Passport registration, and authority-led flagging or locking of suspicious records. These illustrate how EUTIR enhances transparency, reduces fraud, and streamlines regulatory oversight. We advocate for the mandatory use of verifiable identifiersEORI, LEI, and vLEIand qualified electronic seals (QSeal) under eIDAS 2.0 to ensure trusted identities and secure submissions. Governance is distributed among Certified Service Providers (CSPs), Competent Authorities, Financial Institutions, and Economic Operators, with clear r
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Response to Revision of the 'New Legislative Framework'

1 Sept 2025

The document outlines the proposed European Trade Indexes Registry (EUTIR), a strategic digital infrastructure designed to support the European Unions digital and green transition. EUTIR aims to serve as a horizontal trust layer for secure, interoperable, and legally valid exchange of trade-related metadata across EU policy areas, including digital trade, sustainability, customs, finance, and climate. By leveraging technologies such as distributed ledger technology (DLT), cryptographic hashing, verifiable credentials (e.g., vLEI, eIDAS 2.0), and international data standards (e.g., UN/CEFACT, ISO 20022, XBRL), EUTIR enables traceability, reduces administrative burdens, enhances regulatory compliance, and strengthens cross-border trust. The framework supports key initiatives like the New Legislative Framework (NLF), Digital Product Passport (DPP), Carbon Border Adjustment Mechanism (CBAM), and electronic Freight Transport Information (eFTI), positioning the EU as a global leader in trusted, resilient, and interoperable digital trade ecosystems.
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Response to European Climate Law amendment

29 Aug 2025

The document titled Climate-Digital Synergies for a Trusted Trade Framework presents a strategic policy proposal to the European Commission, advocating for the integration of digital and climate objectives through the establishment of the European Trade Indexes Registry (EUTIR). It argues that achieving the EUs climate neutrality goals by 2050 and its 2040 greenhouse gas reduction target requires a trusted, interoperable digital infrastructure for trade. EUTIR is proposed as a decentralized, secure, and EU-wide verification layer that ensures the authenticity, traceability, and integrity of trade-related datasuch as carbon footprints, ESG performance, and product lifecycleswithout storing sensitive content. The document highlights how EUTIR can interoperate with key EU systems like the Digital Product Passport (DPP), Carbon Border Adjustment Mechanism (CBAM), electronic Freight Transport Information (eFTI), and the EU Customs Single Window. By leveraging global identifiers such as LEI/vLEI and technologies like Distributed Ledger Technology (DLT) and AI/ML analytics, EUTIR aims to prevent greenwashing, reduce administrative burdens, enhance regulatory compliance, and support SMEs in the green transition. The proposal includes concrete legislative amendments to strengthen digital trust, ensure GDPR compliance, and align climate action with digital innovation, positioning the EU as a global leader in sustainable and digitally enabled trade.
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Response to Consumer Agenda 2025-2030 and Action Plan on Consumers in the Single Market

29 Aug 2025

The document titled Strengthening Consumer Protection and Market Fairness through the European Trade Indexes Registry (EUTIR) provides strategic input to the European Commission in support of the upcoming Consumer Agenda 20252030. It introduces the proposed European Trade Indexes Registry (EUTIR) as a decentralised, interoperable digital infrastructure designed to enhance trust, transparency, and efficiency in cross-border trade within the EU Single Market. By integrating trusted data systems such as LEI/vLEI, electronic Freight Transport Information (eFTI), Digital Product Passports (DPP), and the CBAM registry, EUTIR aims to strengthen consumer protection, reduce administrative burdensespecially for SMEsand support the green and digital transitions. The document outlines how EUTIR addresses key challenges such as unsafe products, manipulative digital practices, fragmented enforcement, and lack of supply chain transparency, positioning EUTIR as a foundational trust layer for the future of EU digital trade.
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Response to European climate resilience and risk management law

29 Aug 2025

The document is a comprehensive policy feedback submission by the DigitalTrade4.EU consortium to the European Commission, focusing on the revision of the New Legislative Framework (NLF) and its integration with the European Climate Resilience Framework. It proposes the European Trade Indexes Registry (EUTIR) as a strategic, digital trust infrastructure designed to enhance transparency, traceability, and compliance across EU trade, sustainability, and product regulations. EUTIR aims to unify data from key initiatives like the Digital Product Passport (DPP), electronic Freight Transport Information (eFTI), and the Carbon Border Adjustment Mechanism (CBAM) through a secure, decentralized system based on Distributed Ledger Technology (DLT) and eIDAS 2.0 standards. The framework supports interoperability, real-time market surveillance, SME competitiveness, and global digital trade alignment, positioning the EU as a leader in trustworthy, green, and digitally integrated trade ecosystems.
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Response to Peer review of National Cybersecurity Certification Authorities (NCCAs)

26 Aug 2025

The document is a comprehensive policy and technical submission by the DigitalTrade4.EU consortium to the European Commission, originally prepared as feedback on the revision of the EUs New Legislative Framework (NLF). It proposes the establishment of the European Union Trade Indexes Registry (EUTIR)a digital trust infrastructure designed to enhance transparency, traceability, and interoperability across EU trade, sustainability, and compliance systems. EUTIR is presented as a strategic "trust anchor" that leverages distributed ledger technology (DLT), qualified trust services under eIDAS 2.0, and globally unique identifiers (LEI/vLEI) to ensure the authenticity, immutability, and verifiability of digital trade data. The framework integrates with key EU initiatives such as the Digital Product Passport (DPP), electronic Freight Transport Information (eFTI), and the Carbon Border Adjustment Mechanism (CBAM), supporting objectives like SME proportionality, green transition, cybersecurity, and global interoperability through Mutual Recognition Agreements (MRAs). While focused on the NLF, the document highlights strong synergies with the peer review process for National Cybersecurity Certification Authorities (NCCAs), advocating for shared principles such as digital trust, liability allocation, machine-readability, and governance resilience. It includes detailed recommendations, use cases, and proposed amendments to regulatory frameworks to ensure coherence, legal certainty, and future-proofing of the EUs digital single market.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

25 Aug 2025

This document, prepared by the DigitalTrade4.EU consortium, provides strategic input for the revision of the EUs Carbon Border Adjustment Mechanism (CBAM) and the New Legislative Framework (NLF). It proposes the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to support secure, transparent, and efficient cross-border trade. EUTIR is designed as a decentralised, machine-readable registry that anchors metadatasuch as cryptographic hashes, timestamps, and entity identifiers (LEI/vLEI, EORI)from key trade documents and compliance data (e.g., CBAM declarations, Digital Product Passports, eFTI). By ensuring data authenticity, traceability, and interoperability, EUTIR reduces administrative burdens, strengthens market surveillance, and enables seamless integration across EU regulatory systems. Built on trusted technologies like Distributed Ledger Technology (DLT) and eIDAS 2.0, and aligned with global standards, EUTIR supports AI-driven supervision, combats fraud, and positions the EU as a leader in digital trade governance. The document outlines EUTIRs governance, technical architecture, use cases, and policy recommendations, emphasizing its role in advancing the EUs green and digital transitions.
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Response to Import of third countries’ organic products compliant with EU rules: list of recognised control authorities and bodies

21 Aug 2025

The document outlines a strategic proposal for integrating recognised organic control bodies with the European Trade Indexes Registry (EUTIR) to enhance trust, transparency, and efficiency in organic trade. It advocates for EUTIR as a decentralised, interoperable digital infrastructure that verifies the authenticity, integrity, and traceability of trade-related data through metadata registration, leveraging technologies like Distributed Ledger Technology (DLT) and global identifiers such as LEI/vLEI. The integration aims to align organic certification with digital verification, prevent fraud, ensure regulatory compliance, and support the EUs green and digital transition. The proposal includes legislative amendments, a framework for accreditation and certification, GDPR compliance, and a broader vision for a unified, AI-ready, and sustainable digital trade ecosystem across the EU and globally.
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Response to Amendment to the list of the state-of-the-art documents supporting the EUCC scheme

21 Aug 2025

The document presents a strategic proposal to strengthen the EU's digital trade and cybersecurity infrastructure by integrating two key frameworks: the European Common Criteria-based cybersecurity certification scheme (EUCC) and the proposed European Trade Indexes Registry (EUTIR). It emphasizes the need for a unified, secure, and interoperable digital ecosystem that ensures trust in both ICT products and cross-border trade data. By aligning cybersecurity certification with verifiable trade data registries, the document advocates for enhanced transparency, continuity of assurance, and global interoperabilitysupporting the EUs goals for digital sovereignty, sustainable trade, and competitiveness. The proposal includes concrete legislative amendments and outlines how EUTIR can serve as a trust anchor for digital trade, leveraging technologies like blockchain (via EBSI) and global identifiers (LEI/vLEI, EORI) to enable secure, efficient, and fraud-resistant data exchange across customs, logistics, finance, and environmental compliance systems.
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Response to Farm Sustainability Data Network (FSDN) – compiling data on farm sustainability

20 Aug 2025

This document provides strategic feedback to the European Commission on enhancing the Farm Sustainability Data Network (FSDN) by integrating it with the proposed European Trade Indexes Registry (EUTIR). It outlines how linking agricultural sustainability datasuch as soil health, plant protection product use, and antimicrobial reportingwith a secure, decentralised, and interoperable digital infrastructure can improve data authenticity, traceability, and compliance across the EU. The proposal emphasizes alignment with key frameworks like the Digital Product Passport (DPP), LEI/vLEI identifiers, eIDAS 2.0, and EBSI-based blockchain technology, while supporting GDPR compliance, AI/ML analytics, green-digital finance, and SME-friendly reporting. Ultimately, the document advocates for EUTIR as a trust anchor that unifies trade, sustainability, and customs data to advance the EUs green and digital transition.
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Response to Measures related to specific plant pests

20 Aug 2025

The document is a feedback submission to the European Commission on the proposed Regulation concerning pest surveys and reporting. It welcomes the initiative to strengthen the EUs plant health framework in response to growing challenges such as climate change, global trade, and invasive species. The submission advocates for a modern, digital-by-design approach that integrates pest management into the broader EU digital trade ecosystem.
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Response to Implementing Act on the provision applying as from January 2026 of the amended Fisheries Control Regulation

19 Aug 2025

This document presents a set of targeted proposals from the DigitalTrade4.EU consortium for modernizing the EU's fisheries control system. It provides feedback on the draft Implementing Regulation under Regulation (EU) 1224/2009, advocating for a shift towards a digital, trust-based, and interoperable framework. The proposals aim to reduce administrative burdens, enhance transparency, and strengthen enforcement by integrating advanced digital tools like AI, blockchain, and electronic trust services (eIDAS 2.0), positioning EU fisheries as a global leader in sustainable and digitally-enabled governance.
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Response to EU’s next long-term budget (MFF) – EU funding for cross-border education, training and solidarity, youth, media, culture, and creative sectors, values, and civil society

19 Aug 2025

This document presents a proposal for a European Trade Indexes Registry (EUTIR) as a foundational trust layer for the EU's digital and green transition. It positions EUTIR as a decentralized, interoperable system to verify the authenticity and traceability of trade data, aiming to reduce administrative burdens, enhance competitiveness, and ensure seamless integration with global standards. The proposal is strategically designed to support and amplify the impact of EU funding for cross-border education, training and solidarity, young people, media, culture, and creative sectors, values, and civil society. It includes detailed legislative amendments to align the Erasmus+ programme and other initiatives with the European Green Deal and the Competitiveness Compass, creating a virtuous cycle where modern trade governance directly reinforces Europe's human capital and social foundations.
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Response to EU’s next long-term budget (MFF) – EU funding for competitiveness

19 Aug 2025

This document presents a proposal for a European Trade Indexes Registry (EUTIR), a foundational digital infrastructure designed to strengthen EU competitiveness. Acting as a trust anchor for trade data, EUTIR ensures authenticity, traceability, and machine-readability across the Single Market. It aims to reduce administrative burdens, enhance supply chain resilience, support ESG compliance (integrating with systems like the Digital Product Passport and CBAM), and foster innovation. The proposal outlines EUTIR's operational framework, its alignment with key EU priorities, and includes concrete draft amendments to relevant legislation to facilitate its adoption.
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Response to Amending standard forms for application for action for customs enforcement of intellectual property rights

19 Aug 2025

This document presents feedback from the DigitalTrade4.EU consortium on the European Commission's draft proposal to update application forms for the customs enforcement of Intellectual Property Rights (IPR). It outlines a series of targeted recommendations to modernize the process, emphasizing digitalization, interoperability with key EU systems, and improved accessibility for businesses, particularly SMEs. The proposals aim to create a more efficient, secure, and future-proof framework that aligns with the EU's broader digital and green transition goals.
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Response to EU’s next long-term budget (MFF) – EU funding for civil protection, preparedness and response to crises

19 Aug 2025

This document presents a strategic proposal for establishing the European Trade Indexes Registry (EUTIR) as a foundational trust infrastructure for EU digital trade. It outlines how EUTIR supports the EUs Multiannual Financial Framework (MFF) priorities by enhancing resilience, enabling the green and digital transitions, and improving crisis preparedness. EUTIR is proposed as a decentralised, interoperable registry based on blockchain technology (EBSI), designed to verify and trace trade-related data across systems such as the Digital Product Passport (DPP), Carbon Border Adjustment Mechanism (CBAM), and electronic Freight Transport Information (eFTI). The document details EUTIRs role in reducing administrative burdens, preventing fraud, enabling AI-driven analytics, and supporting SMEs, while also contributing to civil protection through real-time, trusted data sharing during crises. It includes legislative recommendations, implementation roadmaps, and governance frameworks to integrate EUTIR into EU policy and global trade ecosystems.
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Response to EU’s next long-term budget (MFF) – implementing EU funding with Member States and regions

19 Aug 2025

The document presents the European Trade Indexes Registry (EUTIR) as a strategic digital infrastructure to support the EUs Multiannual Financial Framework (MFF) 20282034. Proposed by the DigitalTrade4.EU consortium, EUTIR aims to enhance the digitalisation, transparency, and sustainability of cross-border trade by providing a decentralised, interoperable, and trusted verification layer for trade-related data. Aligned with key EU regulations such as eIDAS 2.0 and the UNCITRAL Model Law on Electronic Transferable Records (MLETR), EUTIR ensures authenticity, traceability, and integrity of data across customs, logistics, ESG compliance, and product lifecycle management. The document outlines EUTIRs role in strengthening competitiveness, SME participation, crisis resilience, and global digital trade governance, and includes draft legislative amendments to integrate EUTIR into EU funding, monitoring, and certification frameworks.
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Response to EU’s next long-term budget (MFF) – EU funding for external action

19 Aug 2025

The document provides strategic feedback to the European Commission on integrating the European Trade Indexes Registry (EUTIR) into the EUs long-term budget and digital trade framework. It positions EUTIR as a decentralised, interoperable trust infrastructure designed to enhance digital trade by ensuring authenticity, traceability, and machine-readability of trade-related data. Aligned with key EU objectives such as the green transition, competitiveness, regulatory coherence, and global trade leadership, EUTIR supports initiatives like the Digital Product Passport (DPP), CBAM, eFTI Regulation, and eIDAS 2.0. The document outlines how EUTIR can streamline customs, sustainability compliance, and cross-border data exchange while reinforcing EU strategic autonomy and facilitating integration for candidate and partner countries. It concludes with concrete legislative amendment proposals to institutionalise EUTIR as a cornerstone of Europes secure, transparent, and AI-ready digital trade ecosystem.
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Response to PNR Directive Evaluation

19 Aug 2025

The document provides strategic feedback to the European Commission on strengthening trust in data for security and trade, linking the evaluation of the Passenger Name Record (PNR) Directive with the proposed European Trade Indexes Registry (EUTIR). It highlights the PNR systems role in combating terrorism and serious crime while respecting fundamental rights, and draws parallels with the need for a secure, interoperable digital trade infrastructure. The EUTIR is presented as a decentralised, EU-level trust anchor designed to ensure authenticity, traceability, and verification of trade-related data across platforms such as eFTI, Digital Product Passport (DPP), CBAM, and EU Customs systems. The proposal emphasizes integration with global identifiers like LEI/vLEI, alignment with EBSI and DLT technologies, and harmonisation across Competent Authorities, Service Providers, and Economic Operators. The document calls for legislative enhancements to establish EUTIR as a cornerstone of the EUs digital, green, and competitive future.
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Response to European Innovation Act

19 Aug 2025

This document provides feedback to the European Commission on the proposed European Innovation Act, emphasizing the strategic role of the European Trade Indexes Registry (EUTIR) in advancing a digital, sustainable, and innovation-friendly Single Market. It outlines how EUTIR serves as a trusted, decentralized infrastructure for verifying and interoperating trade-related data across the EU, supporting objectives such as regulatory harmonization, access to finance, and intellectual property commercialisation. The paper details EUTIRs integration with key systems like electronic Freight Transport Information (eFTI), Digital Product Passport (DPP), and the Carbon Border Adjustment Mechanism (CBAM), and calls for legislative enhancements to establish EUTIR as a cornerstone of Europes digital trade ecosystem, fostering competitiveness, transparency, and global leadership in secure, AI-ready trade.
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Response to Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Regulation

19 Aug 2025

The document provides feedback to the European Commission on the 2025 Omnibus Package (COM(2025) 501), advocating for proportional regulation tailored to small mid-cap enterprises (SMCs). It highlights the need to extend SME-friendly simplificationssuch as reduced administrative burdens in GDPR, Prospectus Regulation, Batteries Regulation, and F-gas Regulationto SMCs, which face similar challenges but are often overlooked. Central to the proposal is the establishment of the European Trade Indexes Registry (EUTIR), a decentralised, interoperable digital infrastructure built on blockchain technology (EBSI), designed to serve as a trust anchor for trade-related data. EUTIR aims to streamline compliance, enhance transparency, and support sustainability and digital trade by integrating key identifiers (LEI/vLEI, EORI) and enabling machine-readable, verifiable data exchange across platforms like eFTI, DPP, and CBAM. The document positions EUTIR as a cornerstone for EU competitiveness, facilitating green transition, capital market access, and global trade digitalisation while ensuring legal certainty and regulatory coherence.
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Response to Commission Implementing Act establishing a Strategic Project application template under the Critical Raw Materials Act

19 Aug 2025

The document presents a strategic proposal for integrating the European Trade Indexes Registry (EUTIR) with the EUs framework for recognizing critical raw material projects under Regulation (EU) 2024/1252. It advocates for EUTIR as a decentralized, interoperable digital infrastructure that enhances trust, authenticity, and traceability in cross-border trade. By anchoring metadata from key documentssuch as permits, sustainability certifications, and off-take agreementsEUTIR ensures machine-readability, regulatory compliance, and real-time verification across systems like eFTI, Digital Product Passport (DPP), CBAM, and EU Customs Single Window. The proposal emphasizes reducing administrative burdens, preventing fraud, enabling AI/ML-driven oversight, and supporting the EUs green and digital transition. It calls for legislative updates to embed EUTIR as the central trust anchor in EU digital trade ecosystems, fostering competitiveness, sustainability, and global leadership.
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Response to Trade measure addressing the negative trade-related effects of global excess capacity on the EU steel sector

18 Aug 2025

The document outlines a strategic proposal to strengthen the European Union's steel sector through digital transformation by integrating the European Trade Indexes Registry (EUTIR) into the EUs regulatory and trade infrastructure. It emphasizes the need for digital trust, traceability, and interoperability in safeguarding the steel industry against global overcapacity and unfair trade practices. EUTIR is presented as a decentralized, blockchain-based (EBSI) registry that ensures authenticity, integrity, and machine-verifiability of trade-related data across supply chains. The document advocates for linking EUTIR with key systems such as electronic Freight Transport Information (eFTI), Digital Product Passports (DPP), the Carbon Border Adjustment Mechanism (CBAM), and EU Customs Single Window. It defines roles for economic operators, service providers, competent authorities, and certification bodies, and calls for legislative enhancements to support a unified, efficient, and secure digital trade ecosystem. The ultimate goal is to enhance regulatory efficiency, strategic autonomy, and sustainability while positioning the EU as a global leader in trusted, AI-ready digital trade.
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Response to European strategy for housing construction

15 Aug 2025

Our feedback to the European Commission highlights the strategic integration of the European Trade Indexes Registry (EUTIR) into the EU Housing Construction Strategy as a cornerstone for a competitive, digital, and sustainable built environment. By leveraging decentralised, interoperable digital infrastructure, EUTIR can transform the housing construction sector through enhanced trust, efficiency, and transparency across cross-border processes. The proposal outlines how EUTIR supports key priorities such as streamlining building permits, improving construction productivity, facilitating circular economy practices, and ensuring environmental compliance via linkages to systems like the Digital Product Passport (DPP) and CBAM. Anchored in global identifiers (LEI/vLEI) and built on the European Blockchain Services Infrastructure (EBSI), EUTIR enables machine-readable, tamper-proof verification of data sets, reducing administrative burdens, accelerating project delivery, and fostering mutual recognition of credentials across Member States. This integration not only aligns with the EUs green and digital transition goals but also strengthens the resilience and competitiveness of the European construction ecosystem.
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Response to Clean corporate vehicles

15 Aug 2025

Our feedback to the European Commission highlights the strategic role of the European Trade Indexes Registry (EUTIR) in enabling the successful implementation of the Clean Corporate Vehicles Regulation and advancing the EUs green-digital transition. EUTIR offers a decentralised, interoperable, and secure digital infrastructure that ensures authenticity, traceability, and trust in trade-related data across borders and sectors. By integrating vehicle compliance, carbon footprint declarations, financing references, and Digital Product Passports (DPP) into a unified verification framework, EUTIR can streamline regulatory reporting, prevent fraud, and reduce administrative burdens for businesses and authorities alike. This proposal underscores how EUTIRinteroperable with systems such as eFTI, CBAM, and the EU Customs Single Window, and anchored in global identifiers like LEI/vLEIcan serve as a foundational trust layer for sustainable corporate mobility and broader digital trade in the European Union.
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Response to European Border and Coast Guard – update of EU rules

15 Aug 2025

Our feedback to the European Commission highlights the strategic integration of the European Trade Indexes Registry (EUTIR) as a foundational element for strengthening the European Border and Coast Guards operational capabilities. Developed by the DigitalTrade4.EU consortium, this proposal supports the modernisation of EU border management through a secure, decentralised, and interoperable digital infrastructure. EUTIR acts as a trust anchor for trade-related data, enabling real-time verification of freight information, customs declarations, permits, and sustainability compliance across borders. By connecting with key EU systems such as ICS2, the EU Customs Single Window, electronic Freight Transport Information (eFTI), Digital Product Passport (DPP), and the Carbon Border Adjustment Mechanism (CBAM), EUTIR enhances situational awareness, reduces fraud, and streamlines cross-border operations. The integration of global standards like LEI/vLEI ensures seamless identification of economic operators, while alignment with EBSI-based blockchain technology guarantees data authenticity and traceability. This approach not only improves interoperability among Member States and with third countries but also reinforces fundamental rights, data protection, and AI-driven risk assessment. Ultimately, embedding EUTIR into the European Integrated Border Management framework supports the Commissions objectives of operational efficiency, regulatory harmonisation, and technological sovereignty, positioning the EU as a global leader in secure, sustainable, and digitally enabled trade and border governance.
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Response to Technical updates of the Emissions Trading Scheme (ETS) State aid guidelines

15 Aug 2025

Our feedback to the European Commission proposes the integration of the European Trade Indexes Registry (EUTIR) into the 2025 update of the EU Emissions Trading Scheme (ETS) State Aid Guidelines as a strategic enabler for competitive, low-carbon trade. Rising electricity prices and CO costs are increasingly affecting energy-intensive industries, heightening the risk of carbon leakage and undermining industrial competitiveness. To address these challenges, we advocate for a modernised, data-driven governance framework that leverages EUTIRs secure, decentralised, and interoperable infrastructure. By anchoring critical ETS-related datasuch as electricity consumption, CO intensity, and efficiency benchmarksin a trusted digital environment based on EBSI and Distributed Ledger Technology (DLT), EUTIR ensures that claims for indirect cost compensation are verifiable, up to date, and resistant to overcompensation. This integration would streamline cross-border verification, reduce administrative burdens, and enhance real-time risk assessment, aligning with the objectives of the EU Competitiveness Compass. Furthermore, by embedding global identifiers like LEI/vLEI and enabling machine-readable, AI-ready data exchange, EUTIR positions the EU as a global leader in green-digital trade governance, ensuring legal certainty, interoperability, and long-term resilience in the transition towards a sustainable and digitally integrated single market.
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Response to European Judicial Training Strategy 2025 - 2030

15 Aug 2025

The document outlines a strategic proposal for integrating the European Trade Indexes Registry (EUTIR) into the EUs digital justice and trade ecosystems. It emphasizes how EUTIRa decentralized, interoperable registry built on blockchain-based infrastructure (EBSI)can support the digital transformation of judicial systems by ensuring the authenticity, traceability, and integrity of trade-related data. By aligning with global standards such as LEI/vLEI, eIDAS 2.0, and MLETR, EUTIR enables secure cross-border data verification, enhances judicial cooperation, and facilitates compliance with EU regulations like eFTI, CBAM, and the Digital Product Passport (DPP). The document also calls for legislative enhancements to recognize EUTIR as a trusted verification layer, improve coordination among stakeholders (Economic Operators, Service Providers, Competent Authorities), and equip justice professionals with digital skills to handle AI-ready, machine-readable evidence. Ultimately, EUTIR is positioned as a cornerstone for legal certainty, efficient dispute resolution, and Europes leadership in sustainable, digital trade.
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Response to Circular Economy Act

15 Aug 2025

The document outlines the strategic synergy between the proposed Circular Economy Act (CEA) and the European Trade Indexes Registry (EUTIR) as a foundation for advancing the EUs green and digital transition. It advocates for EUTIR as a decentralized, interoperable digital infrastructure that ensures authenticity, traceability, and trust in cross-border trade data. By integrating systems like the Digital Product Passport (DPP), electronic Freight Transport Information (eFTI), and CBAM, EUTIR acts as a "trust anchor" to support regulatory compliance, reduce administrative burdens, prevent fraud, and enable AI-driven trade facilitation. The document calls for legislative enhancements to mandate EUTIRs role in verifying trade data, harmonizing standards, and ensuring global interoperability through identifiers like LEI/vLEI and EORI, ultimately positioning the EU as a leader in sustainable, digital trade.
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DigitalTrade4.EU Urges Digital Standards for Insurance Sector Review

7 Aug 2025
Topic — Technical rules supplementing the review of prudential standards for EU insurers.
Message — The group requests mandatory digital reporting standards and interoperability with EU platforms. They seek legal recognition for digital identities and electronic signatures. They also propose simplified compliance templates for small insurance companies.123
Why — Standardized digital reporting would reduce administrative costs and enable efficient oversight.4
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DigitalTrade4.EU advocates for digitalized recycled plastic reporting

7 Aug 2025
Topic — Common rules for reporting recycled content in single-use plastic beverage bottles.
Message — The organization recommends using a digital interoperability ecosystem to enhance reporting transparency. They suggest utilizing Digital Product Passports to track lifecycle data and ensure traceability across platforms.12
Why — This would establish the consortium’s digital standards as the primary framework for EU compliance.34
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DigitalTrade4.EU calls for digitalizing hazardous chemical trade documents

7 Aug 2025
Topic — EU consultation on rules governing the international trade of hazardous chemicals.
Message — The consortium envisions a seamlessly interconnected Europe powered by harmonized standards for digital trade documents. They propose linking permit registries with digital passports to ensure real-time verifiability of chemical data.12
Why — Standardized digital processes would reduce administrative costs and speed up cross-border chemical shipping.3
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Response to Gas SoS – risk groups amendment

7 Aug 2025

Read the attached document.
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Response to Amendment of protective measures against pests of plants

6 Aug 2025

The document presents proposed amendments to Commission Implementing Regulation (EU) 2019/2072, aimed at modernizing the EU's framework for regulating non-quarantine pests (RNQPs). Developed by the DigitalTrade4.EU consortium, it advocates for the integration of digital solutions such as Digital Product Passports (DPP), verifiable Legal Entity Identifiers (vLEI), and eIDAS 2.0-compliant cryptographic sealing to improve traceability, trust, and cross-border interoperability in plant health certifications. The recommendations align with broader EU digital, environmental, and trade policies, including the Green Deal, EU Digital Strategy, and Customs Single Window, promoting sustainable, efficient, and fraud-resistant agri-food trade.
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Response to EASA BoA Delegated Regulation

29 Jul 2025

The document is a proposal submitted by the DigitalTrade4.EU consortium to the European Commission, outlining comprehensive amendments to the Delegated Regulation on the Organisation and Composition of the Board of Appeal of the European Union Aviation Safety Agency (EASA). It advocates for the full digitalisation of the Boards procedures, aligning them with key EU initiatives such as eIDAS 2.0, the Digital Single Market, and the EU AI Act. The proposals focus on enabling secure digital identities, legal equivalence of electronic documents, remote proceedings, AI-assisted case management, and robust cybersecurity. The overarching goal is to enhance efficiency, transparency, legal certainty, and cross-border interoperability in aviation dispute resolution, while supporting the EUs broader green and digital transformation objectives.
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Response to EU Design Implementing Regulation

28 Jul 2025

Our feedback outlines the DigitalTrade4.EU consortium's recommendations to the European Commission on modernizing EU design protection for the digital age. The document emphasizes aligning design law with technological advancements, enhancing legal certainty, and supporting innovation through secure digital identity solutions (eIDAS 2.0), integration with Digital Product Passports (DPPs), and the application of Artificial Intelligence and Machine Learning. Special attention is given to improving accessibility for Small and Medium-sized Enterprises (SMEs) by reducing administrative burdens, offering user-friendly digital tools, and leveraging Legal Entity Identifiers (LEIs) and Verifiable LEIs (vLEIs). These proposals aim to strengthen the EUs intellectual property framework, support the green and digital transitions, and position Europe as a global leader in innovation-friendly regulation.
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Response to EU industrial maritime strategy

27 Jul 2025

Global trade is experiencing a major shift driven by the combined forces of environmental sustainability and digital innovation. The European Union is positioning itself as a leader in this transformation, particularly within the maritime industry, through strategic initiatives that integrate green goals with advanced digital solutions. At the heart of this effort is the DigitalTrade4.EU consortium, which advocates for a seamlessly interconnected Europe supported by standardized digital trade processes. This document provides feedback to the European Commission on how to strengthen the EU's leadership in green-digital trade and industrial maritime strategy. The EU is focusing on modernizing trade documentation through tools like Electronic Bills of Lading (eBLs) and Digital Product Passports (DPPs), while also reinforcing digital identity and trust services using Legal Entity Identifiers (LEI/vLEI) and eIDAS 2.0. Strategic investments in dual-use digital infrastructure, simplified maritime arbitration procedures, and the integration of Artificial Intelligence (AI) are also essential components of this vision. By aligning these efforts with global standards and deepening digital partnershipsespecially in Asiathe EU aims to build a resilient, interoperable, and future-ready trade ecosystem. This introduction sets the stage for a comprehensive roadmap that outlines how the EU can achieve its objectives in competitiveness, sustainability, and defence readiness through coordinated policy action and international cooperation.
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DigitalTrade4.EU Urges Unified Cybersecurity Standards for European Ports

18 Jul 2025
Topic — The EU strategy addresses security and competitiveness challenges across the maritime sector.
Message — They demand unified standards, dual-use by design technology, and simplified regulatory compliance.12
Why — This would reduce administrative costs and improve operational efficiency for port operators.3
Impact — Non-EU technology vendors may lose market share due to strategic autonomy goals.4
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DigitalTrade4.EU urges digital product passports for new EU vehicles

15 Jul 2025
Topic — This consultation covers the revision of CO2 emission standards for new passenger cars.
Message — The organization proposes mandating Digital Product Passports for all new vehicles starting in 2028. This digital infrastructure would track emissions and lifecycle data throughout the automotive value chain.12
Why — Digital tools would reduce administrative burdens and simplify regulatory compliance for the industry.34
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DigitalTrade4.EU pushes digital tracking for unsold clothing waste rules

15 Jul 2025
Topic — EU rules on derogations for the ban on destroying unsold apparel.
Message — The group calls for using Digital Product Passports to document why unsold products are destroyed. They also recommend using digital platforms to coordinate and track product donations to ensure destruction is a last resort.123
Why — Mandating digital verification would reduce manual audit efforts and lower compliance costs.45
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DigitalTrade4.EU Urges Linking Pesticide Residues With Digital Product Passports

14 Jul 2025
Topic — The consultation updates EU methods for sampling and analyzing pesticide residues in food.
Message — DigitalTrade4.EU requests integrating pesticide residue data into Digital Product Passports. They also recommend adopting standardized machine-readable formats and verifiable identifiers.12
Why — Digital alignment would reduce administrative burdens and streamline regulatory compliance for industry players.34
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Response to Commission Implementing Regulation for goods brought to the exclusive economic zone of Member States

14 Jul 2025

Our feedback proposes integrating Digital Product Passports (DPPs) into the Carbon Border Adjustment Mechanism (CBAM) to streamline carbon reporting for imported goods. Developed by the DigitalTrade4.EU consortium, this initiative aligns with the EUs Green Deal and Digital Europe goals, aiming to reduce administrative burdens, enhance data accuracy, and support SMEs. By leveraging DPPsa digital framework for tracking product sustainabilityCBAM compliance could become automated, ensuring seamless data exchange while meeting climate and transparency targets.
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DigitalTrade4.EU urges digital overhaul of EU emissions trading system

6 Jul 2025
Topic — The European Commission is reviewing the EU emissions trading system and market stability reserve.
Message — They propose integrating digital passports to track emissions for products like batteries. The group also calls for aligning reporting with global digital trade standards. They suggest simplified online tools to help small businesses comply with regulations.12
Why — Digitalizing the system would reduce paperwork and administrative costs for trading companies.3
Impact — Illicit traders lose their ability to exploit weak reporting through enhanced transparency.4
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DigitalTrade4.EU urges digital standards integration for EU securitisation rules

27 Jun 2025
Topic — This consultation reviews liquidity coverage requirements and the treatment of securitisation exposures for banks.
Message — The organization requests the integration of digital verification mechanisms to provide automated, real-time updates for credit assessments. They advocate for a digital-by-default approach to reporting and the reduction of haircuts for assets with verified sustainability metrics.123
Why — Digitalisation would reduce administrative burdens and lower issuance costs for sustainable financial instruments.45
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Response to Detailed specifications regarding functional requirements for eFTI platforms

27 Jun 2025

This updated feedback from DigitalTrade4.EU outlines strategic recommendations to strengthen the European Commissions digital trade agenda and implementation of the eFTI Regulation. It calls for aligning EU rules with global frameworks such as UNCITRALs MLETR and eIDAS 2.0, promoting decentralised and interoperable architectures, and integrating Digital Product Passports (DPPs) into both commercial and defence supply chains. These measures are essential to reduce administrative burdens, enhance cybersecurity, ensure regulatory coherence, and deliver a future-proof, competitive, and resilient Digital Single Market. To read more, download the full document
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Response to EU-Mauritania sustainable fisheries agreement and protocol – way forward

22 Jun 2025

Our feedback highlights how the EU can reinforce its leadership in green and digital trade through strategic partnerships, legal interoperability, and infrastructure investment. We recommend leveraging frameworks like DEPA, AfCFTA, MLETR, and eIDAS 2.0 to promote global standards, with Mauritania as a key partner in Africa. Accelerating Digital Product Passport (DPP) deployment, integrating ESG into trade finance, and supporting SMEs through upskilling and simplified regulation are essential. We also urge the EU to strengthen enforcement of Single Market rules and establish tools like a Trade Document Registry to ensure a resilient, inclusive, and sustainable digital trade ecosystem. To read more, download the full document
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DigitalTrade4.EU urges automated digital passports for unsold products

21 Jun 2025
Topic — EU rules requiring companies to disclose data on unsold consumer products they destroy.
Message — The organization requests that reporting on discarded goods use machine-readable formats and automated data submission. They propose integrating this information directly into Digital Product Passports to streamline the process. They also recommend using digital tools and verifiable credentials for the verification of discarded products.123
Why — Switching to automated digital systems would significantly lower administrative costs and simplify complex reporting.45
Impact — Large tech platforms would lose market dominance if forced to allow interoperability with third-party apps.67
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Response to Import into the Union of high-risk organic and in-conversion products

21 Jun 2025

Our feedback aims to support the European Commissions efforts to strengthen the EUs leadership in green and digital trade. We outline key developmentssuch as the EU-Singapore Digital Trade Agreement and the UNECE Recommendation No. 49and propose strategic actions to promote cross-border interoperability, accelerate the adoption of Digital Product Passports, and integrate environmental goals into trade policy. This input reflects the collective expertise of the DigitalTrade4.EU consortium and aligns with the EUs vision for a seamless, secure, and sustainable Single Market.
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DigitalTrade4.EU urges digital trade reform for capital markets

20 Jun 2025
Topic — A consultation on creating a European blueprint for savings and investment accounts.
Message — The consortium calls for a uniform legal framework for electronic documents. They also request a central trade data registry and mandatory digital product passports.12
Why — These reforms would significantly lower compliance costs and remove legal barriers for cross-border trade.3
Impact — Dominant digital platforms would lose the ability to lock businesses into proprietary software systems.4
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Response to Revised EU energy labelling for refrigerating appliances with a direct sales function

17 Jun 2025

Shared document represents the DigitalTrade4.EU consortiums contribution to the European Commissions strategy for a simpler, seamless, and stronger Single Market. It outlines practical recommendations to accelerate the EUs green and digital transition by embedding interoperable digital tools, global standards, and ESG-linked trade finance into the core of Single Market policy. With over 100 partners spanning 39 countries, DigitalTrade4.EU provides a cross-sectoral, globally aligned perspective to help operationalise the Commissions vision for a data-driven European home market. To read more download the full document
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DigitalTrade4.EU urges dual-use focus for European digital network strategy

16 Jun 2025
Topic — Consultation on enhancing EU digital connectivity for cloud and AI transition.
Message — The consortium calls for mandatory adoption of international standards for electronic trade. They suggest expanding product passports to secure defense supply chains and prevent counterfeits. The group also recommends creating shared data spaces for civilian and military purposes.123
Why — These measures would lower expenses by preventing the creation of redundant digital infrastructure.4
Impact — Member States would lose individual control over spectrum management as the EU moves toward harmonisation.5
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DigitalTrade4.EU urges digital solutions for faster industrial decarbonisation

16 Jun 2025
Topic — EU initiative to accelerate investment and permitting for decarbonising energy-intensive industrial sectors.
Message — DigitalTrade4.EU recommends integrating Digital Product Passports and automated platforms to expedite permitting and track environmental performance. They also call for the adoption of global digital standards to ensure cross-border legal recognition of electronic documents.12
Why — These measures would lower compliance costs and reduce administrative burdens for businesses in the consortium.3
Impact — Large online platforms lose market control as new rules force interoperability and prevent vendor lock-in.4
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DigitalTrade4.EU urges dual-use focus for European Data Union strategy

9 Jun 2025
Topic — The commission is seeking input on a new strategy to streamline European data sharing rules.
Message — The group calls for adopting digital standards and product passports for defense equipment. They also recommend investing in infrastructure that supports both trade and military logistics.12
Why — Harmonized standards would eliminate transaction delays and reduce administrative costs for member companies.34
Impact — Dominant digital platforms would lose market power as new rules prevent vendor lock-in.5
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Response to Mini omnibus for defence

8 Jun 2025

This document presents the DigitalTrade4.EU consortiums feedback to the European Commission on the European Defence Readiness 2030 strategy and related industrial initiatives. It highlights how digital transformation, based on interoperable and decentralized standards, can strengthen the EUs defence capabilities, enhance military mobility, secure supply chains, and foster innovation within the European Defence Technological and Industrial Base (EDTIB). The recommendations emphasize leveraging existing digital trade solutions with dual-use potential to support both economic competitiveness and defence readiness in a rapidly evolving geopolitical environment. To read more, download the full document
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Response to Fruit and vegetables – review of sectorial rules and modernising certain market monitoring provisions and mechanisms

5 Jun 2025

DigitalTrade4.EU aims to create a seamlessly interconnected Europe and neighboring regions by harmonizing standards for the digitalization of trade documents and processes. This initiative supports economic integration, cooperation, and trade facilitation across borders. The document provides feedback on the European Commissions draft Delegated Regulation amending rules for producer organisations in the fruit and vegetables sector. It highlights the importance of digital tools to simplify governance, improve transparency, and support sustainability in this critical agricultural sector. To read more, download the full document
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DigitalTrade4.EU urges digital standards to simplify agricultural policy

4 Jun 2025
Topic — The consultation addresses the simplification and digitalisation of Common Agricultural Policy Strategic Plans.
Message — They recommend integrating EU-wide digital standards like eIDAS 2.0 and MLETR into national roadmaps. The consortium also proposes the integration of sustainability data into Digital Product Passports.12
Why — Harmonized digital standards would reduce paperwork and operational costs for agricultural trade.3
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DigitalTrade4.EU calls for dual-use digital standards in defense

3 Jun 2025
Topic — This consultation covers the revision of the EU Cybersecurity Act's mandate.
Message — The consortium recommends aligning digital trade tools with defense initiatives through interoperability and decentralization. They suggest mandating standards like MLETR and eIDAS for secure military logistics. Additionally, they propose extending Digital Product Passports to track sensitive defense equipment.12
Why — Standardized digital processes would significantly lower administrative burdens and compliance costs for their member organizations.3
Impact — Operators of centralized digital systems face potential displacement by more resilient, decentralized network architectures.4
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DigitalTrade4.EU urges linking AI science with digital trade

3 Jun 2025
Topic — EU policy initiative to promote artificial intelligence adoption within scientific research.
Message — The consortium recommends linking scientific AI research with economic sectors like logistics. They suggest integrating AI tools with digital frameworks like eIDAS to ensure interoperability. Funding should be leveraged to help small businesses adopt these advancements.1234
Why — Interoperable AI models would streamline trade processes and reduce cross-border documentation costs.5
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Response to Wine package: Implementation of the recommendations of the High-Level Group on wine policy

2 Jun 2025

DigitalTrade4.EU supports the proposals goalsenhancing competitiveness, managing climate risks, and meeting consumer demandsand advocates for integrating digital tools and sustainability practices to achieve them. Key recommendations include adopting Digital Product Passports (DPPs) for supply-chain transparency, harmonizing e-labelling, promoting global digital trade standards (like MLETR), and supporting SMEs through dedicated funding and skills programs. The input aligns with the EUs broader vision for green-digital trade leadership and offers actionable solutions to strengthen the wine sectors resilience and global position. To read more, download the full document
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Response to Declaration of conformity and verification by independent auditor

2 Jun 2025

DigitalTrade4.EU advocates for integrating F-gas compliance data (Regulation EU 2024/573) into the Digital Product Passport (DPP) framework to enhance supply chain transparency and regulatory efficiency. This document outlines how mandatory inclusion of F-gas declarations (e.g., HFC type, GWP value, verification reports) in DPPs can streamline sustainability reporting, reduce SME burdens, and align with EU green finance incentives like CBAM. Key recommendations include adopting interoperable standards (eIDAS 2.0), linking compliance to trade benefits, and launching cross-border pilots with DEPA partners. To read more, download the full document
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Response to Proposal amending the Batteries Regulation (EU) 2023/1542 as regards battery due diligence obligations

2 Jun 2025

The DigitalTrade4.EU consortium welcomes the European Commissions proposal to postpone battery due diligence obligations to August 2027. This response advocates leveraging the delay to build a resilient digital framework centered on Digital Product Passports (DPPs), ensuring supply chain transparency and regulatory alignment with EU Green Deal goals. Key recommendations include adopting digital-by-default standards (eIDAS 2.0, MLETR), allocating 3.3 billion in EU funding for infrastructure and SME support, and fostering international cooperationespecially with Asian partnersto position the EU as a leader in sustainable digital trade. To read more, download the full document
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Response to Fruit and vegetables – review of sectorial rules and modernising certain market monitoring provisions and mechanisms

1 Jun 2025

The DigitalTrade4.EU consortium outlines a strategy to position the EU as a global leader in green-digital trade. Central to this vision is the adoption of Digital Product Passports (DPPs), enabling traceable sustainability data, streamlined compliance (e.g., CBAM), and access to green finance. To read more, download the full document
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Response to Apply AI Strategy

30 May 2025

The document by DigitalTrade4.EU outlines a strategic vision for integrating artificial intelligence (AI) into the European Unions trade, logistics, and capital markets to advance green and digital transitions. Key priorities include harmonizing AI adoption with foundational frameworks like Electronic Freight Transport Information (eFTI), eIDAS 2.0 for secure digital identities, and Digital Product Passports (DPPs) for sustainability tracking. It emphasizes leveraging the Multiannual Financial Framework (MFF) to fund AI solutions for SMEs, streamline cross-border innovation, and align AI with EU goals like the Carbon Border Adjustment Mechanism (CBAM) and Circular Economy. The proposal stresses ethical AI governance, cybersecurity, and global interoperability via agreement like DEPA and UNCITRAL MLETR model law to ensure trusted, transparent, and competitive trade ecosystems. Challenges such as data fragmentation and regulatory gaps are addressed through targeted investments, legal harmonization, and public-private partnerships. Case studies and roadmaps illustrate practical implementation steps. To explore detailed strategies and guidelines, download the full document
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Response to Proposal for an amendment to the InvestEU Regulation.

28 May 2025

Our consortium, representing over 100 trade and technology partners across Europe and globally, welcomes the European Commission's proposal to enhance the InvestEU Programme's efficiency. However, we express strong concern about the proposal's assessment that it has "no digital relevance." This overlooks a critical opportunity to align EU investments with the twin green and digital transitions. We argue that modern digital tools like Digital Product Passports are essential for enabling traceability, circularity, and automated compliance with EU regulations (e.g., CSRD, CBAM). Without prioritizing digital solutions, InvestEU risks funding projects that quickly become outdated. To know more, download and read the full document.
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Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

26 May 2025

Created document by DigitalTrade4.EU outlines a strategy to harmonize digital innovation and sustainability in EU trade. Central to this vision are the European Business Wallet (EBW) and Green Economy framework, which together aim to streamline cross-border business operations while advancing environmental accountability. The EBW leverages secure digital identities (e.g., verifiable Legal Entity Identifiers, eSeals) to reduce administrative burdens and fraud, while the Green Economy integrates tools like Digital Product Passports (DPPs) and Carbon Border Adjustment Mechanism (CBAM) to ensure transparent, low-carbon supply chains. Key challenges include workforce adaptation to digital tools, interoperability gaps, cybersecurity risks, and energy-efficient infrastructure. Recommendations focus on remunerated digital training for frontline workers, legal harmonization, and SME support through grants and simplified compliance. The framework aligns with EU policies like the Digital Decade, Green Deal, and Global Gateway Initiative, emphasizing international cooperation with DEPA partners and Central Asia to establish trusted digital trade corridors. To explore detailed guidelines, legislative frameworks, and possible case studies, download the full document
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DigitalTrade4.EU urges digital infrastructure for sustainable finance disclosures

24 May 2025
Topic — This consultation reviews EU rules to simplify sustainable finance disclosures and prevent greenwashing.
Message — The group advocates for integrating digital registries and product passports into the disclosure framework. They request faster adoption of digital signature laws to provide reliable, real-time data for investors.12
Why — These digital solutions would reduce administrative costs and improve capital allocation for sustainable businesses.34
Impact — Sectors unable to transition to digital data infrastructure risk being excluded from private investment.5
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Response to Savings and Investments Union: Directive fostering EU market integration and efficient supervision

20 May 2025

The Commissions impact assessment confirms that fragmentation remains one of the most persistent barriers to fully integrated EU capital markets. National regulatory and supervisory silos continue to drive up costs, limit investment opportunities, and hinder market-driven consolidationultimately preventing the single market from reaching its full potential. While legislative progress is being made in trade, finance, transport, and sustainability, achieving true harmonization demands more than parallel effortsit requires active coordination. Misaligned timelines and conflicting requirements risk creating a complex compliance landscape that stifles innovation. For example, businesses navigating overlapping obligations under the eFTI Regulation (transport data), ViDA (VAT digitalization), Digital Product Passport (sustainability and trade compliance), and the CBAM (Carbon Border Adjustment Mechanism) may face duplicate filings, increased costs, and legal uncertainty. This document reflects feedback from our members, whose message was clear: the initiative is ambitiousperhaps too ambitious. Yet ambition is not the problem. What matters is ensuring it is anchored by clear objectives and a phased, realistic implementation strategy. Success depends on concrete steps, not sweeping attempts to solve everything at once. Reducing fragmentation and achieving regulatory alignment is key to fostering a business environment that supports, rather than obstructs, entrepreneurial activity. True harmonization should empower businesses, not burden them. This requires close collaboration among EU institutions, Member States, and industry stakeholders to align priorities, eliminate redundancies, and build interoperability into the legislative framework. The cost of fragmentation is tangible. For example, a German exporter using a national e-invoicing platform may experience delays if a Belgian importers bank still requires paper-based verification. Such disconnects can increase transaction costs by 15 to 20%. Coordinated legislation will reduce administrative burdens, simplify compliance, and allow regulations to keep pace with technological developments. By aligning rules and reducing fragmentation, the EU can unlock innovation and reinforce the strength of its single market. Download the file to learn more!
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Response to International Digital Strategy

18 May 2025

The DigitalTrade4.EU consortium supports the EUs International Digital Strategy as a foundation for strengthening global digital partnerships and advancing interoperable trade systems. We believe this strategy provides the right framework to expand high-trust digital trade agreements, especially with Asia through DEPA, and to embed sustainability through tools like Digital Product Passports. The EUSingapore Digital Trade Agreement demonstrates how European digital standards can shape cross-border data flows and AI governance globally. We also highlight the alignment between EU initiatives and UNECEs Recommendation 49, which reinforces global sustainability traceability. To accelerate implementation, we recommend prioritizing legal harmonization via MLETR and eIDAS 2.0, launching practical capacity-building efforts like a Green-Digital Trade Academy, and supporting SMEs through targeted digital infrastructure and skills programmes. Interoperability, platform openness, and ESG-linked trade finance must remain central pillars. This strategy is essential for building resilient, rules-based trade corridors aligned with EU values. Download the file to learn more.
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