IDA, The Danish Society of Engineers
IDA
Fagforening og interesseorganisation for folk der studerer og arbejder indenfor STEM-fagene.
ID: 067595045565-63
Lobbying Activity
Response to Digital package – digital omnibus
13 Oct 2025
The Danish Society of Engineers (IDA) welcomes the consultation and supports the Commissions ambition to strengthen regulatory coherence across the EUs digital framework. In relation to the part of the Digital Omnibus that concerns the smooth application of the recently adopted AI Act, IDA wishes to emphasize the importance of establishing a clear and operational definition of what constitutes high-risk AI systems. It is essential that the Commission not only defines who is covered by the regulation, but also explicitly clarifies who is not. This delineation is necessary to ensure legal certainty and consistent implementation across Member States. Without such clarity, both authorities and businesses may lack sufficient guidance, leading to uncertainty and potentially hindering innovation. Once the definition of high-risk is in place, IDA recommends the rapid development of concrete, sector-specific guidelines to support effective and accurate implementation of the AI Act as we have already seen with article 4 as an example. These guidelines should be made available without delay to ensure clarity and consistency in how the regulation is applied. We recommend prioritizing the healthcare sector, where AI poses both significant risks and transformative potential. In this regard, it is essential that the Commission continues to drive progress and prioritizes the timely implementation of the AI Act, ensuring that safeguards for the responsible development and deployment of AI in the EU are implemented without delay. Regarding cookies and tracking technologies, IDA welcomes updates, provided they maintain the same level of protection for consumers as currently in place. Transparency and user control over personal data are cornerstones of digital trust, and any changes must not undermine this foundation. Consumers must continue to have the ability to make informed choices about data sharing. IDA notes with concern the broader trend of digital rights being challenged in the pursuit of competitiveness and alignment with global market pressures. While it is important that the EU continues to strengthen its competitiveness, this must not come at the expense of fundamental rights. Maintaining high standards for data protection and digital responsibilitythrough regulations such as the GDPR and the Digital Services Act (DSA)is essential. These frameworks are key to safeguarding citizens and must remain robust. A balanced approach, where technological advancement goes hand in hand with strong rights protections, is crucial to sustaining trust and ensuring a responsible digital transition.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
18 Feb 2022
Overall, we are looking very much forward to a revision of the Waste Framework Directive. Among other initiatives, we are especially hoping for a new recycling hierarchy.
We naturally support that prevention of waste generation and reuse have priority over recycling. Concerning this matter, we’ve found that designs promoting circularity is a key action area. That said, more should be done to promote prevention of waste generation.
In addition to that, we have in the Danish Society of Engineers (IDA), developed a concrete proposal for how a recycling hierarchy could look in the future. You can read further on the proposal in the report “Cirkulær genanvendelse” (it only exists in Danish, but you can read it by following this link: https://ida.dk/media/9661/idas-strategi-for-cirkulaer-oekonomi-2021-14-enkelt-sidet-til-net.pdf ) I’ve attached a short summary of the report in English.
In the existing waste hierarchy recycling is interpreted as a single concept and is therefore not differentiated. In IDA’s proposal, the concept of recycling is broadened and differentiated into four different kinds of recycling.
It is crucial that we promote high-quality recycling, where the material is kept a close to its original form as possible.
Recycling one product to a completely different one might be the best solution right now, containing many environmental upsides, alongside the opportunity for the market to learn how to deal with recycled materials. But the hierarchy of recycling is necessary to secure the further development in the long term.
From our point of view, it’s very problematic that the current understanding of recycling does not differentiate between different qualities of recycling, mainly because this implies that all kinds of recycling are the same. A recycling hierarchy would be a part of the solution to this problem.
The hierarchy developed by IDA draws attention to the fact that not all kinds of recycling contribute to a circular economy, and in many cases recycling might just be a short-sighted solution right now. This is also why recycling is understood more like a “recycling economy” instead of a circular economy.
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