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FEDIL - The Voice of Luxembourg's Industry

FEDIL

FEDIL is a business federation representing Luxembourg's industry, construction, and services sectors.

Lobbying Activity

Meeting with Marc Angel (Member of the European Parliament) and Association des Banques et Banquiers, Luxembourg and

3 Dec 2025 · Competitiveness

Response to Revision of EU antitrust procedural rules

30 Sept 2025

Remarks against fragmentation of the Single Market by divergent national laws on abuse of dominance Ensuring the coherence and effectiveness of EU competition law requires avoiding the risks of fragmentation caused by divergent Member State rules on unilateral conduct. Fragmentation undermines the integrity of the Single Market, creates significant legal and economic uncertainty for companies operating across borders, exposes firms to conflicting remedies, and weakens the EUs ability to build strong, diversified and resilient supply chains. A coordinated and harmonised EU approach is therefore essential to protect cross-border competition and safeguard the resilience of the European economy. -Internal Market as the guiding principle EU competition policy must contribute to the deepening of the Internal Market. Allowing Member States to apply divergent unilateral conduct rules risks weakening this core objective and contradicts the aim of a more integrated, resilient and competitive Single Market. -Cross-border economic reality Many economies in Europe, such as Luxembourg, are inherently cross-border and integrated within regional and EU-wide supply chains. Companies and consumers operate seamlessly across borders. Fragmented enforcement frameworks would artificially segment these integrated markets and fail to reflect the economic reality of the Single Market. -Markets are no longer purely national Geographic markets are increasingly regional, European or even global in scope, depending on competitive conditions. Nationally divergent abuse-of-dominance regimes impose artificial boundaries that are disconnected from the actual functioning of markets, creating legal uncertainty and inconsistent obligations for businesses. -Risks of inconsistent or conflicting remedies If National Competition Authorities (NCAs) impose remedies under stricter national laws without a common EU reconciliation mechanism, divergent or even contradictory remedies may emerge. This undermines legal certainty and exposes firms to conflicting compliance obligations. A EU-level process would be necessary to safeguard convergence and preserve coherent enforcement across the Single Market. -Unrealistic enforcement timelines The current 30-day deadline leaves the European Commission with very limited time to reassess an NCAs analysis under Article 102 TFEU. This short timeframe makes it challenging to ensure consistent application when national laws go beyond EU rules, and may increase the risk of fragmented enforcement practices across Member States. -Barriers to competition and supply chains Fragmented national rules, including divergent licensing, permit, or administrative requirements, can prevent suppliers from entering or competing across borders. This reduces competitive pressure, hampers cross-border trade, and ultimately limits consumer choice. Such obstacles weaken the resilience of EU supply chains and the competitiveness of the Single Market. -Legal uncertainty and economic dependence Regulatory fragmentation creates uncertainty and risks of economic dependence for firms operating cross-border. Divergence in unilateral conduct rules not only weakens the predictability of competition law enforcement, but also undermines the EUs ability to strengthen resilience and coherence in the Single Market.
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Meeting with Christophe Hansen (Commissioner) and

25 Sept 2025 · - Industrial policy - Trade and international relations - Digital and innovation

Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen), Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen), Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

25 Sept 2025 · Digital and Telecom policy

Meeting with Pauline Weinzierl (Head of Unit Trade)

25 Sept 2025 · Meeting with Federation of Luxemburgish Industries

Meeting with Ioana-Maria Gligor (Head of Unit Secretariat-General)

25 Sept 2025 · Discussion on the Digital Omnibus and digital regulation compliance with focus on Luxembourg's businesses and the complexity surrounding cybersecurity reporting.

Meeting with Elisa Roller (Director Secretariat-General)

25 Sept 2025 · Balancing Europe’s competitiveness and its decarbonisation objectives

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič), Charlotte Merlier (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and

25 Sept 2025 · Trade policy, including trade defence instruments and trade agreements

Meeting with Marc Angel (Member of the European Parliament)

12 Sept 2025 · Industrial Policy

Meeting with Isabel Wiseler-Lima (Member of the European Parliament)

12 Sept 2025 · FEDIL MEP Visit Industry

Meeting with Charles Goerens (Member of the European Parliament)

12 Sept 2025 · FEDIL Industry Visit (Hydro Aluminium & Tarkett)

Meeting with Thomas Schmitz (Cabinet of Executive Vice-President Henna Virkkunen)

9 Sept 2025 · Coordination call to prepare the meeting to be held on 25/09/2025

Meeting with Marc Angel (Member of the European Parliament, Shadow rapporteur)

16 Jul 2025 · e-Declaration and other IMCO-related topics

Meeting with Martine Kemp (Member of the European Parliament) and Association des Banques et Banquiers, Luxembourg

20 Mar 2025 · general meeting

Meeting with Martine Kemp (Member of the European Parliament)

14 Mar 2025 · Exchange of views

Meeting with Charles Goerens (Member of the European Parliament)

6 Mar 2025 · Geopolitical situation, US tariffs, Omnibus

Meeting with Maive Rute (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Association des Banques et Banquiers, Luxembourg and

6 Feb 2025 · Stakeholders’ roundtable in Luxembourg – Single Market Strategy Consultation

FEDIL urges EU to eliminate Single Market barriers

31 Jan 2025
Topic — The European Commission is seeking evidence for its Single Market Strategy 2025.
Message — FEDIL requests full legal harmonisation and a mandatory Single Market test. They call for standardized digital declarations to reduce administrative fragmentation. This includes removing barriers to worker mobility across the Union.12
Why — Unified EU rules would reduce compliance costs and administrative complexity for companies.3
Impact — National governments lose the power to implement stricter local standards for industries.4
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Meeting with Isabel Wiseler-Lima (Member of the European Parliament)

16 Jan 2025 · Réception du Nouvel An

Meeting with Marc Angel (Member of the European Parliament) and Association des Banques et Banquiers, Luxembourg and

18 Dec 2024 · ECON and IMCO-related issues

Meeting with Martine Kemp (Member of the European Parliament)

11 Dec 2024 · Exchange of views and introductory meeting

Meeting with Marc Angel (Member of the European Parliament) and Goodyear Europe B.V

6 Sept 2024 · Industrial Policy

Meeting with Charles Goerens (Member of the European Parliament)

6 Sept 2024 · Industry Visit

Meeting with Christophe Hansen (Member of the European Parliament) and Goodyear Europe B.V

6 Sept 2024 · MEP visit Industry

Meeting with Isabel Wiseler-Lima (Member of the European Parliament)

15 Mar 2024 · Echange en vue des éléctions européennes

Meeting with Martine Kemp (Member of the European Parliament)

15 Mar 2024 · Perspectives for the European Union

Meeting with Nicolas Schmit (Commissioner) and Vereniging VNO-NCW and VERBOND VAN BELGISCHE ONDERNEMINGEN / FEDERATION DES ENTREPRISES DE BELGIQUE

6 Mar 2024 · Social dialogue, economic growth and job creation

Meeting with Charles Goerens (Member of the European Parliament)

28 Feb 2024 · EU campaign

Meeting with Isabel Wiseler-Lima (Member of the European Parliament)

23 Jan 2024 · Réception du Nouvel An des entreprises

Meeting with Martine Kemp (Member of the European Parliament)

8 Dec 2023 · Premier échange

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

6 Oct 2023

FEDIL The Voice of Luxembourgs Industry (FEDIL), is a multi-sector business federation, giving a voice to nearly 700 industrial members, service providers and construction companies and fostering economic activity in Luxembourg. FEDIL is a founding member of BusinessEurope and has a representative office in Brussels to ensure that its member companies voice is heard in European policymaking. FEDIL acknowledges and appreciates the European Commission's commitment to reducing regulatory burdens for SMEs and micro-companies. We endorse the adjustment of size criteria for financial statements, recognizing its potential to alleviate administrative burdens within these sectors. At present, SMEs and micro-companies experience accelerated mandatory financial statement audits, primarily due to inflation-distorted balance sheets and turnovers. These circumstances present substantial administrative challenges for these entities, given their smaller workforces and lack of internal audit readiness. However, it's worth noting that over the past decade, inflation has nearly reached 30% (data provided by the Commission indicates a cumulative increase of 24.3% in the euro area and 27.2% for the EU27 from January 1, 2013, to March 31, 2023). This raises concerns about the sufficiency of the proposed adjustments, especially considering the potential for further inflation over the next five years before the next revision. Therefore, we would recommend raising the threshold amounts by a more substantial margin, by at least 40%. Furthermore, regarding mid-cap companies, it remains unclear whether the current approach aims to extend the SME definition to include small mid-caps or establish a distinct classification for them. The proper reflection of this approach in relevant EU legislative acts holds equal importance and clarifications should be provided. In any case, we consider that it might be appropriate to develop a harmonised definition, strategy, and framework conditions should be developed specifically tailored for mid-cap companies. It is important to note that while mid-caps might often achieve significant revenue generation, they should not be classified as large companies due to their typically limited administrative capacities and less readiness to handle complex regulations compared to larger companies. Hence, such a definition, strategy, and framework should encompass aspects related to accessing finance and investments, as well as a comprehensive review of the current regulatory environment. This review should start by its definition and thresholds so to exclude them by the scope of the CSRD and other relevant EU legislations imposing disproportionate administrative burdens. Thresholds should be established as follows: employee count between 250 and 1500, balance sheet between 25 000 000 EUR and 75 000 000 EUR and net turnover between 50 000 000 EUR and 100 000 000 EUR. Finally, as we consider the implications of raising these thresholds, it is crucial to ensure that access to EU grants and financing opportunities for SMEs and micro-companies is not hindered. Special attention should be paid to safeguarding their ability to pursue such resources. As a final remark, FEDIL believes that, in addition to monetary thresholds, it is essential to engage stakeholders in a discussion regarding the adequacy of staff headcount criteria. We believe that solely adjusting figures based on inflation will not provide a comprehensive solution. Therefore, we recommend implementing a threshold of 500 employees, considering part-time equivalents based on hours worked.
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Meeting with Marc Angel (Member of the European Parliament)

8 Sept 2023 · Industrial, environmental, and energy policy

Meeting with Ruud Kempener (Cabinet of Commissioner Kadri Simson)

3 Jul 2023 · Commission proposals on the Net-zero Industry Act, Electricity Market Design and the European Hydrogen Bank

Response to VAT in the Digital Age

3 Apr 2023

Founded in 1918, FEDIL The Voice of Luxembourgs Industry (hereinafter FEDIL), is a multi-sector business federation, giving a voice to nearly 700 industrial members, service providers and construction companies and fostering economic activity in Luxembourg. Today, FEDIL represents 95% of Luxembourgs industrial production, 75% of Luxembourgs private research activity, 25% of national employment and 35% of national GDP. FEDIL welcomes the opportunity to provide its feedback on behalf of its members on the VAT in the Digital Age proposal of the European Commission. We fully support the European Commissions ambition to improve the VAT system through the use of digital tools, reducing VAT-related barriers for cross-border trade in the EU and making the VAT system better for businesses, while also more resilient to fraud. We believe the VAT in the Digital Age proposal is well placed to embrace digitalization, and effectively addresses the challenges faced by businesses (and in particular by SMEs) who trade, or have ambitions to trade, across EU borders. This is well reflected in the proposal through: The expansion of the Union One Stop Shop (UOSS) and the introduction of a transfer module allowing businesses to use one single VAT registration to report transfers of own inventory to locations across the EU, as well as the onward sales in those locations. We strongly encourage Member States to reach consensus on this pillar, as it would be a pivotal tool to reduce the need for costly, time-consuming, and often prohibitive need for businesses wanting to sell products across the EU to maintain multiple VAT registrations. Amendments to the text of the proposal should be in line with the north star goal of reducing the VAT administrative burden for businesses. To achieve this, it is key that there is no (or extremely limited) negative VAT cash flow impact when businesses opt to report through the UOSS and the transfer module. Any newly introduced obligations for businesses and for electronic interfaces facilitating the transfer and/or the sale of goods should be proportional and ensure a level playing field. A shift to real-time digital reporting based on e-invoicing for businesses that operate cross-border in the EU and a more harmonized framework for domestic transactions. We welcome the ambition to harmonize EU digital reporting requirements, as current fragmentation of digital reporting and e-invoicing standards around the EU is causing immense burden on businesses and is a threat to the Single Market. However, as the proposal focuses solely on creating a harmonised invoice format, it misses a key opportunity to harness the full business and economic benefits that could come from harmonization of transmission protocols and technical specifications for digital reporting. However, due to the ambition of the proposal, we opine that a more realistic timeframe must be considered. Some of the proposed rules are designed to take effect eight months after the finalisation of this public consultation (from 1 January 2024). Given the unanimous approval required from all Member States, we recommend a minimum of twenty-four months from the date ViDA is approved before the first measures start being implemented. Additional lead time will be needed for the introduction of the more complex proposals, such as the introduction of mandatory electronic invoicing (see below). It could also be worth examining the possibility of granting incentives to businesses, ensure their practical needs are considered and provide sufficient guidance and support. We attach a document developing and detailing these different elements.
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Meeting with Tilly Metz (Member of the European Parliament)

11 Nov 2022 · Due diligence directive

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Antoine Kasel (Cabinet of Commissioner Nicolas Schmit)

26 Sept 2022 · Inflationary pressure on households and businesses, energy prices and the situation in Luxembourg industry as well as the conclusions of the tripartite in this context.

Meeting with Tilly Metz (Member of the European Parliament)

2 Sept 2022 · Energy and Circular Economy

Meeting with Marc Angel (Member of the European Parliament, Shadow rapporteur for opinion)

1 Jul 2022 · EU Chips Act

Meeting with Marc Angel (Member of the European Parliament)

31 May 2022 · EU ETS and CBAM

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

2 Feb 2022 · Instrument on Foreign Subsidies

Meeting with Nicolas Schmit (Commissioner) and

28 Sept 2021 · Fit for 55 Package and the Revision of the EU Emissions Trading System (ETS)

Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Antoine Kasel (Cabinet of Commissioner Nicolas Schmit)

15 Jul 2021 · ETS & CBM

Meeting with Nicolas Schmit (Commissioner) and

30 Apr 2021 · Meeting on Minimum Wage, cross-border workers in the Benelux region and the European Pillar of Social Rights Action Plan.

Meeting with Nicolas Schmit (Commissioner) and

1 Mar 2021 · Participation at the “Industry Days 2021" event on “A New Industrial Strategy shaping Europe’s Digital Future: nourished by talents, driven by data, reinforced by trust ” organised by FEDIL.

Meeting with Didier Reynders (Commissioner) and

12 Jan 2021 · due diligence

Response to Voice call termination rates in the EU (Eurorates)

22 Sept 2020

The European Electronic Communications Code requires the Commission to adopt a delegated act setting maximum fixed (FVT) and mobile voice call termination (MVT) rates in the EU by 31 December 2020. For the final delegated act to be as efficient as possible and adapted to the realities of the telecom sector, FEDIL participates in the public consultation as follows: While we always strongly support the development of a fully functioning single market for electronic communications, which will strengthen de competitiveness of the EU, it is important to note the specific circumstances of the Luxembourg market being close to national borders, having a relatively small economy and therefore a higher demand for international calls than other Member States. The approach implemented, according to which we dispense with the national regulator to define a generic cost model is not suited to our situation because it does not take into account local specificities. We therefore regret the move towards a "one size fits all" system. The fact that FVT and MVT will also apply to calls originating in third countries and terminating in the Union where certain conditions are met will have for consequence that our companies will suffer from a significant competitive disadvantage compared to third country operators. FEDIL welcomes that the draft act recognises that the difference between mobile voice termination (MVT) a fixed voice termination (FVT) is a factual element that influences the structure of the costs and proposes different glide paths and price objectives for both. Nevertheless, the introduction of termination prices has a high impact on the productivity and profitability of our telecom member companies. Especially the gradual decline towards EUR 0.2 cent per minute for MVTs by 2024 represents a major challenge for our member companies. Indeed, the risk of sales at lost is becoming a reality and the projections are negative since there is a substantial loss in gains in growth. The target planned for 2024 in the MVT does not take into account specific costs, for example invoicing, and it thus becomes impossible to cover the wholesale price. We therefore have formal reservations as to whether this target is a good approach, especially in times of crisis. Likewise, our companies will have to face non negligible challenge in meeting national and European ambitions in terms of investments in the 5G network. The “glidepath” of lower international tariffs, spread over several years, has been welcomed by our members. We believe that international and domestic tariffs should only equalize over the long term, instead of immediate alignment. Concerning the implementation period of 2 months for the yearly updated maximum MVT rates, we urge the Commission to recognise serious strains it brings about. Considering that telecommunication companies have to notify all operators of their new rates, we have major concerns regarding the application of this rules on international level. A period of 6 months would be necessary to notify all international operators. The European Commission’s delegated act on these issues is of key importance to the European telecommunication community. In these extremely turbulent times, Europe cannot afford any policy choices or legislation that could undermine our competitiveness. We trust the Commission will continue safeguarding our competitive edge and give our companies the legal certainty that they need for the implementation of new tariffs.
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Meeting with Nicolas Schmit (Commissioner), Thierry Breton (Commissioner) and

6 Jul 2020 · Entrevue sur les investissements dans les compétences et la transition numérique pour accélérer la reprise, les stratégies numériques et industrielles, les PME.

Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

4 Mar 2020 · Digital Services Act and digital package

Meeting with Nicolas Schmit (Commissioner) and

14 Feb 2020 · Skills, Industrial Strategy and SMEs

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

12 Jan 2016 · Ongoing projects

Meeting with Léon Delvaux (Cabinet of President Jean-Claude Juncker)

12 Jan 2016 · Discuss Commission Work Programme

Meeting with Jean-Claude Juncker (President)

19 Nov 2015 · Gala dinner