Japan Business Council in Europe
JBCE
The Japan Business Council in Europe represents Japanese companies operating in Europe and advocates for open trade, common regulatory frameworks, and responsible business practices.
Lobbying Activity
Japan Business Council seeks chemical limit exemptions for articles
19 Dec 2025
Message — JBCE requests extending trace contaminant limits to finished articles to ensure regulatory consistency across different EU laws. They also urge a longer transition period because necessary testing standards for certain chemicals are currently unavailable.123
Why — The amendment avoids impossible technical requirements at the manufacturing stage and facilitates global trade.45
Impact — Environmental groups lose momentum toward clean goals as technical barriers prevent immediate chemical removal.6
Japanese Business Council Urges Delays for Chemical Restrictions
19 Dec 2025
Topic — The EU is restricting medium-chain chlorinated paraffins under persistent organic pollutant rules.
Message — JBCE requests longer transition periods and specific derogations for specialized equipment like medical devices. They stress that finding alternatives and re-certifying products requires extensive time and personnel.12
Why — The extension would help firms avoid production delays and preserve limited human resources.34
Impact — Citizens could lose access to medical diagnostics and environmental monitoring during equipment shortages.5
Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné)
15 Dec 2025 · EU’s industrial policy
Meeting with Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and Fujitsu Technology Solutions B.V. and
11 Dec 2025 · Discussion on EU-Japan trade, competitiveness, and industrial policy.
JBCE Urges EU Taxonomy Alignment With Industrial Policy
5 Dec 2025
Message — JBCE requests full recognition of net-zero technologies and coherence with the Net Zero Industry Act. They seek the clarification or deletion of unclear requirements regarding suitable alternative substances. They also urge alignment between the Taxonomy and REACH standards for hazardous substances.123
Why — These changes would lower administrative costs and prevent companies from losing access to sustainable investment.45
Impact — Environmental groups lose if the Taxonomy allows substances currently restricted beyond basic REACH requirements.6
Meeting with Olivier Bringer (Head of Unit Communications Networks, Content and Technology)
18 Nov 2025 · EU-Japan Digital Partnership and potential areas for further collaboration with JBCE
Japan Business Council urges EU to accept non-EU recycled materials
6 Nov 2025
Message — The organization requests that the EU recognize secondary materials from partner countries with established economic security agreements, rather than mandating EU-origin materials exclusively. They argue that limiting circulation to EU-produced materials would disrupt global supply chains and hinder optimal circular economy systems.123
Why — This would preserve their existing supply chain partnerships and investments in quality assurance and cost efficiency.4
Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)
28 Oct 2025 · DG Kerstin Jorna Meeting - Speaking engagement with JP companies
Japan Business Council in Europe Urges Bold Digital-First Product Rules
3 Sept 2025
Message — The organization advocates for a digital-first approach to labels, marking, and documentation. They request replacing physical postal addresses with digital contact points and prioritizing international standards.123
Why — This would lower logistical expenses and reduce complexity across their global supply chains.45
Impact — EU citizens may face higher prices if new testing requirements increase manufacturing costs.6
Japan Business Council urges digital-first EU product rules
3 Sept 2025
Message — JBCE urges the EU to require digital formats as the default for formal requirements. They recommend prioritising international standards over EU-specific ones to avoid trade barriers.12
Why — Moving to digital documentation reduces compliance costs and logistical burdens like packaging clutter.34
Impact — EU citizens face higher prices if the regulations introduce unnecessary financial and administrative burdens.5
Japan Business Council Urges Simplified CBAM Compliance for Downstream Goods
25 Aug 2025
Message — The organization requests simplified compliance methods for downstream goods importers, clearer threshold rules based only on CBAM-covered materials' weight, and harmonization with other EU carbon calculation methodologies. They argue the current approach creates disproportionate administrative burdens compared to minimal emission reductions.123
JBCE urges further postponement of battery due diligence rules
30 Jul 2025
Message — The council requests delaying obligations until August 2028 and aligning them with other EU sustainability laws. They also seek early publication of guidelines and recognition of industry schemes to simplify compliance.123
Why — This delay avoids high costs and penalties before a proper verification system exists.4
Impact — Sustainability goals and compliant companies suffer if oversight is delayed or capacity is lacking.5
Japanese business council seeks flexible EU unsold product rules
9 Jul 2025
Message — They argue only goods primarily intended for consumers should be subject to reporting. They also state the limited assurance requirement must be removed to avoid burdens.12
Why — This would reduce the complexity of compliance and remove disproportionate burdens for operators.3
Impact — Public transparency loses out if regulators accept aggregated data or best estimates instead.4
Japan Business Council urges simpler maritime carbon market rules
7 Jul 2025
Topic — The Commission is reviewing the EU emissions trading system for maritime and aviation sectors.
Message — JBCE argues regulatory simplification is essential to reduce administrative burdens. They request that Ocean Carbon Capture and carbon removal credits be formally recognised as emission reduction solutions.123
Why — Streamlined rules would reduce high entry barriers and compliance risks for international businesses.45
Impact — European maritime companies lose competitive standing if regional rules overlap with global standards.6
Meeting with Mika Aaltola (Member of the European Parliament, Rapporteur for opinion) and Bureau du Tibet
3 Jul 2025 · EU Affairs
Response to Declaration of conformity and verification by independent auditor
16 Jun 2025
Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)
4 Jun 2025 · Simplification
JBCE urges simplified EU deforestation rules and broader exemptions
12 May 2025
Message — JBCE requests flexible due diligence statements and exemptions for small rubber components. They also propose excluding spare packaging and manuals from the regulation.12
Why — Proposed changes would significantly reduce administrative burdens and compliance costs for machinery manufacturers.34
Impact — Environmental groups lose transparency if regional data replaces specific geolocation for paper products.5
Meeting with Ralph Schmitt-Nilson (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)
7 Apr 2025 · Clean Industrial Deal
Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)
25 Mar 2025 · Simplification
Meeting with Eddy De Smijter (Head of Unit Competition)
11 Feb 2025 · Exchange of views on the experience with the enforcement of the Foreign Subsidies Regulation (“FSR”)
JBCE urges EU to include more categories in lead exemptions
10 Feb 2025
Topic — EU consultation on renewing lead exemptions for steel, aluminium, and copper alloys in electronics.
Message — The group suggests adjusting the scope to ensure medical devices and monitoring instruments are included. They request a longer validity period for products with long design cycles and certification requirements.12
Impact — Environmental safety suffers as toxic lead remains in the market for longer.5
Japan Business Council in Europe calls for harmonized EU regulations
31 Jan 2025
Message — The organization calls for harmonized customs and digital standards to reduce administrative burdens on businesses. They recommend using Regulations instead of Directives to prevent market fragmentation across Member States.12
Why — Standardized rules and international alignment would lower compliance costs and streamline their operations.34
Impact — National governments lose the flexibility to set their own technical regulations and product requirements.5
Japan Business Council seeks clarity on CBAM declarant procedures
26 Nov 2024
Message — The group seeks clarity on the content of applicant observations. They also request technical details for reactivating closed accounts.12
Why — Clearer rules would prevent redundant administrative steps and ensure stable global supply chains.34
Impact — Ambiguous procedures risk trade disruptions that harm the resilience of global supply chains.5
Response to Ecodesign requirements for air heating and cooling products (review)
29 Aug 2024
Japan Business Council seeks higher chemical limits and grace period
27 Aug 2024
JBCE urges broader spare part exemptions for Dechlorane Plus
24 Jul 2024
Message — JBCE requests that the Commission includes specific exemptions for spare parts in the regulation. They recommend adding outdoor power equipment and analytical instruments to the specific exempt categories.12
Why — Members would avoid manufacturing disruptions and extend the service life of their products.3
Impact — The circular economy suffers as shortened product lifetimes lead to rapidly increasing waste.4
JBCE demands changes to battery carbon footprint calculation rules
28 May 2024
Topic — Establishing a methodology for calculating the carbon footprint of electric vehicle batteries.
Message — JBCE recommends adjusting charge cycles for hybrid vehicles to reflect usage patterns accurately. They propose limiting transport emission measurements to prevent trade barriers for non-EU products. They also support recognizing green electricity certificates.123
Why — These changes would lower reported emissions for Japanese imports and reduce administrative burdens.45
Impact — Domestic EU battery manufacturers lose a competitive advantage gained from penalizing imported battery transport.6
JBCE Demands Confidentiality Safeguards in EU Chemical Data Proposal
2 Apr 2024
Message — JBCE requests a system to prevent accidental release of trade secrets on common platforms. They suggest providing advance notice to companies before their information is made public.12
Why — Protecting trade secrets ensures companies avoid financial damage and maintain their competitive edge.3
JBCE Urges Balanced Risk Assessments in Chemical Regulatory Streamlining
2 Apr 2024
Message — JBCE emphasizes the need for balanced risk assessments that consider diverse regulatory criteria. They request continued opportunities for flexible dialogue between agencies, stakeholders, and industry registrants.12
Why — Including socio-economic assessments helps Japanese companies protect their market access from purely hazard-based bans.3
Impact — Environmental advocates lose regulatory momentum if unified safety assessments are delayed by socio-economic requirements.4
Japan Business Council urges product-level focus in ECHA transition
2 Apr 2024
Japan Business Council urges realistic targets for vehicle recycling
1 Dec 2023
Message — The organization demands achievable timelines and practical targets for using recycled materials. They argue that including industrial waste and bio-based plastics is necessary to meet requirements.123
Impact — Environmental groups lose as the circularity of consumer waste recycling is weakened.6
Japan Business Council urges EU to simplify reporting rules
28 Nov 2023
Message — JBCE highlights that ambiguous definitions and standards cause excessive administrative burden and unnecessary costs. They recommend replacing directives with regulations to create a consistent EU-wide framework and prevent fragmented requirements. They also suggest aligning EU legislation with global standards to ensure clarity for international value chains.1234
Why — Companies would achieve significant cost savings by reducing their dependence on expensive external consultancies.5
Impact — External consultancies lose business as clearer reporting tools reduce the need for specialized advice.6
JBCE calls for B2C focus in Green Claims Directive
20 Jul 2023
Topic — The EU initiative requires companies to substantiate environmental claims using footprint methods.
Message — The group requests that the scope be limited to B2C commercial practices. They argue that B2B communications should be explicitly excluded to remain workable for global companies.123
Why — Excluding B2B communications reduces compliance costs and operational burdens for global firms.45
Impact — Business clients lose legal protections against misleading environmental claims from their suppliers.6
Japan Business Council urges aligned CBAM and ETS reporting
11 Jul 2023
Message — JBCE demands identical reporting requirements for importers and domestic producers to ensure fairness. They request exemptions for small emitters and involvement of non-EU governments.12
Why — This would prevent Japanese companies from facing higher administrative costs than EU competitors.34
Impact — EU regulators lose the ability to accurately verify emissions if reporting on facility-level data becomes voluntary.5
Japan Business Council Urges Safe Harbor for EU Sustainability Reporting
6 Jul 2023
Message — The group requests a "safe harbour on civil liability" for human rights and forward-looking disclosures. They also urge the Commission to "swiftly define 'equivalent' standards" to prevent duplicative reporting for non-EU firms.12
Why — Alignment with international rules would reduce administrative costs and lower legal risks for parent companies.34
Meeting with Raphaël Glucksmann (Member of the European Parliament, Shadow rapporteur)
8 Jun 2023 · APA level - Forced labour
Japan Business Council seeks taxonomy inclusion for e-fuel vehicles
3 May 2023
Topic — Amendments to the classification of sustainable economic activities for investment purposes.
Message — JBCE requests including e-fuel vehicles and harmonizing hydrogen sustainability criteria with other EU policies. They also advocate for removing the worldwide replacement ratio limit for aircraft manufacturing.123
JBCE calls for flexible EU environmental taxonomy criteria
3 May 2023
Message — JBCE requests deleting the ban on fluorinated gases to protect heat pump investments. They also propose lowering recycled resin targets for packaging and reducing software update support periods.123
Why — This would reduce compliance burdens for manufacturers and protect investments in energy-efficient equipment.45
Impact — Consumers lose a year of guaranteed software support for their electronic devices.6
Japan Business Council urges clearer rules and longer packaging deadlines
24 Apr 2023
Message — JBCE requests transitional periods to avoid supply chain disruptions. They seek exemptions for sensitive industrial goods like semiconductors. They want chemical recycling and bio-based plastics included in targets.123
Impact — Member States lose the power to implement stricter national environmental labelling.6
JBCE urges EU to align chemical rules with global standards
29 Mar 2023
Topic — Targeted revision of EU rules for classifying and labelling chemical substances and mixtures.
Message — JBCE calls for aligning chemical regulations with international standards for global supply chains. They request clear guidance and extended transition periods for new hazard classifications. They suggest allowing research materials to be labelled in a common international language.12
Why — Global alignment would reduce high administrative costs and the burden of region-specific labelling.3
Impact — Downstream sectors face unnecessary restrictions on products without a proper socio-economic risk assessment.4
JBCE seeks flexibility for temporary carbon storage certification
22 Mar 2023
Message — JBCE requests flexibility in defining storage periods to include temporary solutions like e-fuels and carbon farming. They also call for better alignment with existing carbon credit systems to simplify compliance for businesses.12
Why — This would reduce regulatory hurdles and lower compliance costs for Japanese firms.3
Impact — Environmental advocates may fear that short-term storage increases the risk of re-emissions.4
Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and
25 Jan 2023 · Corporate Sustainability Due Diligence
Japan Business Council in Europe urges longer CRA transition periods
23 Jan 2023
Message — JBCE recommends a transition period of six years for finished products to allow manufacturers sufficient time to adjust. They also advocate for alignment with other product-specific legislation and the NIS2 incident notification approach.123
Why — A longer transition period would reduce administrative burdens and lower immediate product redesign costs.4
Impact — Smaller companies and startups face high costs and difficulty complying with strict 24-hour reporting requirements.5
JBCE Urges EU Incentives for Biofuel Food Waste Technologies
22 Dec 2022
Message — JBCE requests EU incentives for circular technologies or transitional measures for food waste limits. They also want clarity on whether post-industry wastes are included and specific definitions for intermediate crops.123
Why — This would prevent disruption to current internal bioenergy use and external sales.4
Impact — Vague rules could cause confusion and undermine progress toward circular economy goals.5
Japan Business Council Urges Legal Certainty for Forced Labour Rules
30 Nov 2022
Message — JBCE requests high legal certainty and earlier guidelines to properly comply with all requirements. They propose increasing investigation response times to thirty days to reflect supply chain complexity.123
Impact — Forced labour victims lose immediate protections if market withdrawal actions are delayed.6
Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and EUROPEAN TRADE UNION CONFEDERATION and
7 Nov 2022 · Corporate Sustainability Due Diligence
Japanese industry urges EU chemical rules to align globally
17 Oct 2022
Topic — EU consultation on introducing new hazard classes to chemical classification and labeling rules.
Message — JBCE calls for consistency with international standards to prevent global supply chain confusion. They suggest that new hazard criteria require scientific consensus and clear implementation guidance prior to adoption.123
Why — This would reduce the massive costs and resources required to reclassify and relabel products.45
Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and
17 Oct 2022 · Corporate Sustainability Due Diligence
Meeting with Dragoş Tudorache (Member of the European Parliament, Rapporteur) and Albright Stonebridge Group LLC
13 Oct 2022 · Artificial Intelligence
JBCE Urges Risk-Based Alignment in Chemical Agency Reforms
10 Oct 2022
Message — JBCE requests excluding substances not deemed hazardous under REACH from RoHS restrictions. They advocate for sector-based assessments where consumers lack direct exposure to internal parts. They also insist on maintaining the current methodology for evaluating product exemptions.123
Why — This would prevent new regulatory burdens and protect existing exemptions for manufacturers.45
Impact — Environmental groups lose the ability to seek broader bans on chemicals in electronics.6
JBCE urges flexible biofuel testing to maintain price competitiveness
20 Jul 2022
Message — JBCE requests financial incentives for radiocarbon testing and more realistic error margins. They also propose relying on existing mass balance methods to verify bio-content.123
Why — Lowering testing standards would reduce compliance costs and prevent significant capital investments.45
Impact — Biofuel operators lose competitive advantage if expensive testing requirements remain in place.6
Japanese business council warns F-gas phase-down threatens heat pumps
29 Jun 2022
Topic — The European Commission is reviewing rules to further reduce fluorinated greenhouse gas emissions.
Message — JBCE proposes maintaining the current phase-down until 2030 to protect the heating transition. They suggest avoiding new bans on equipment to allow manufacturers flexibility in adopting safer alternatives.12
Why — Delaying the phase-down prevents expensive, rapid equipment redesigns and mandatory retesting requirements.3
Impact — Consumers in older buildings lose because safety standards restrict installing flammable alternative heat pumps.4
JBCE Urges Alignment with International Standards in Due Diligence
23 May 2022
Message — JBCE requests clearer definitions of business relationships to ensure the rules are implementable. They recommend aligning the directive with international standards and allowing a gradual phase-in. The group suggests removing requirements for annual policy updates and climate change plans.123
Why — Limiting liability and sanctions would significantly reduce potential financial and legal risks.45
Impact — Environmental groups lose a mechanism for forcing companies to adopt climate strategies.6
Japan Business Council seeks 36-month grace period for Data Act
13 May 2022
Topic — European Commission proposal to regulate data access and sharing among various stakeholders.
Message — The council requests extending the application deadline from 12 to 36 months to accommodate complex technical requirements. They also advocate for clearer definitions of data scope and stronger safeguards for trade secrets.123
Why — A longer transition period prevents immediate high costs of redesigning established manufacturing processes.45
Impact — Public authorities lose the ability to request business data during non-emergency situations.6
Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation
7 Apr 2022
Meeting with Dragoş Tudorache (Member of the European Parliament, Rapporteur)
17 Mar 2022 · Artificial Intelligence
Meeting with Petar Vitanov (Member of the European Parliament, Shadow rapporteur)
16 Mar 2022 · AI Act
Meeting with Kosma Złotowski (Member of the European Parliament, Shadow rapporteur)
15 Mar 2022 · Artificial Intelligence Act
Response to Review: Restriction of the use of hazardous substances in electronics
13 Mar 2022
Meeting with Silvia Modig (Member of the European Parliament, Shadow rapporteur)
18 Oct 2021 · Batteries and waste batteries
Meeting with Axel Voss (Member of the European Parliament)
8 Dec 2020 · Artificial Intelligence
Response to Report on the application of the General Data Protection Regulation
29 Apr 2020
Meeting with Alessandro Carano (Cabinet of Commissioner Violeta Bulc)
15 Feb 2018 · Introduce new Executive Director
Meeting with Eric Peters (Cabinet of Commissioner Mariya Gabriel)
15 Jan 2018 · EU Digital Policies and Priorities; EU-Japan cooperation
Response to Amendments of the Annexes to REACH for registration of nanomaterials
6 Nov 2017
Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)
16 Jun 2017 · Digitisation of industry
Meeting with Jon Nyman (Cabinet of Vice-President Cecilia Malmström)
12 Dec 2016 · Possible participation at a future event