OpenLobby.EU
Explore

RISE Research Institutes of Sweden AB

RISE

RISE is Sweden’s research institute and innovation partner.

Lobbying Activity

Response to General revision of the General Block Exemption Regulation

5 Oct 2025

Please see the attached file for our complete feedback. RISE, Research Institutes of Sweden AB, is Swedens research institute and innovation partner. In our capacity as a Research and Technology Organisation, through international collaboration with industry, academia and the public sector we ensure business competitiveness and contribute to a sustainable society. In this response to the call for evidence on the GBER, we emphasize in particular the need for guidance from the Commission on how to apply the state aid rules in practice; adequate and forward-leaning funding opportunities and conditions for technology infrastructures; and more leeway for national funding agencies. In short: 1. More detailed guidance on how to interpret and apply individual conditions. 2. The reference to technology infrastructures in the definition of testing and experimentation infrastructures should be deleted. It should be clarified that a technology infrastructure might perform either economic or non-economic activities (or both). 3. Significantly ameliorating the GBER conditions for testing and experimentation infrastructures and research infrastructures, at least where private actors do not show the way by taking responsibility for setting up, upgrading, investing in or operating such infrastructures. 4. Clarify the relation between and cumulation possibilities as for state aid and other public funding (EU funding). 5. More leeway for the national funding agencies.
Read full response

Response to European Innovation Act

3 Oct 2025

RISE welcomes the European Innovation Act as a way to strengthen Europes innovation system and global competitiveness. We particularly commend the Commissions new strategy for research and technology infrastructures, which is well aligned with a modern European innovation system. At the same time, we stress the importance of removing legal barriers to innovation and developing a fit-for-purpose regulatory framework for technology infrastructures to enable investments, cross-border collaboration, and long-term competitiveness. Read more about this and other aspects for a stronger innovation ecosystem in our attached EIA position paper.
Read full response

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

19 Jun 2025

RISE welcomes the European Commissions initiative to update the EU Bioeconomy Strategy. This is a timely and important step to unlock the full potential of Europes bioeconomy sectors and to pave the way for strategic investments that strengthen competitiveness, sustainability, and long-term resilience across the Union. Prioritizing research and innovation for scaling up is essential for the future of our bioeconomy sectors. While the EU has made significant progress in laying the groundworkthrough initiatives like CBE-JU, the Bioeconomy Knowledge Centre, and other instrumentsmaintaining momentum now requires bold, targeted investments. To truly unlock the potential of the bioeconomy, Europe must invest in state-of-the-art technology infrastructure and support systems, covering both capital expenditures (CAPEX) and operational costs (OPEX). This is not only necessary to accelerate innovation but also to ensure that new solutions can be deployed at scale, contributing to strategic autonomy, climate goals, and economic resilience. Equally important is creating an enabling environment for innovation that directly benefits primary producers, supports income diversification, and drives rural development. It must become easy to be a bioeconomy innovator in the EU. This means systematically identifying and removing barriers to innovation and market access, and ensuring that support mechanisms are fit for purpose. Exploring new instrumentssuch as an industrial alliance for the biobased sectors or other collaborative frameworkscould further accelerate scale-up efforts and stimulate private and public investments in sustainable, high-impact technologies. RISE is ready to contribute with expertise throughout the process of developing the updated strategy both at a strategic, cross-sectoral level and with deep sector-specific knowledge across the bioeconomy value chain.
Read full response

Response to European strategy on research and technology infrastructures

21 May 2025

RISE welcomes the growing recognition of Research and Technology Infrastructures (RTIs) in the European policy agenda. As the EU prepares its next Multiannual Financial Framework (MFF), shapes the future Framework Programme (FP10), and considers new instruments such as a Competitiveness Fund, there is a pivotal opportunity to modernise Europes approach to RTIs. This modernisation can significantly accelerate industrial transformation, support the development of critical technologies, and reinforce Europe's long-term competitiveness. In this context, RISE places particular emphasis on the policy development of Technology Infrastructures (TIs)a timely and essential complement to the European research and innovation landscape. TIs have strong potential not only to boost industrial competitiveness and drive innovation, but also to enhance Europes resilience in the face of increasing geopolitical and strategic uncertainties. To learn more about what RISE sees as fundamental for the future development of TIs and their role in a competitive and resilient Europe, we invite you to read our full position paper.
Read full response

Response to EU Life sciences strategy

16 Apr 2025

In response to this Call for Evidence A Strategy for European Life Sciences, we at RISE Research Institutes of Sweden ABa state-owned, independent research institute have compiled a position paper outlining what we consider to be essential actions to strengthen Europes life science sector. Our contribution reflects the deep expertise of our researchers and analysts, built on extensive experience at the crossroads of research, innovation, and industrial implementation. With a strong foundation in both public and private sector needs, and long-standing involvement in the management and development of technology infrastructures, RISE is uniquely positioned to provide future-oriented solutions that support a robust and competitive European life science ecosystem. In the attached position paper, we present our perspectives and recommendations on strategic priorities for the future development of life sciences in Europe. The paper focuses on several key areas where we believe coordinated action and targeted investment are critical: the green transition, digitalization, translational research, resilience and antimicrobial resistance, medical devices and diagnostics, and funding. RISE, together with our multidisciplinary network of experts, stands ready to actively engage in forthcoming expert groups and technology platforms aligned with the future strategy. We look forward to contributing to a cohesive, innovative, and resilient European life science landscape.
Read full response

Meeting with Thomas Skordas (Deputy Director-General Communications Networks, Content and Technology) and

2 Apr 2025 · Exchange of views on the AI Gigafactories initiative

Response to Carbon footprint methodology for electric vehicle batteries

28 May 2024

The purpose of promoting sustainability via harmonised carbon footprint declarations based on a life cycle perspective and the life cycle assessment (LCA) methodology is an initiative we encourage. However, it requires a lot from the design of the calculation methodology to be practically feasible for the practitioners. From this perspective, we want as a general comment to question the use of the circular footprint formula (CFF) for end-of-life modelling instead of the easy-to-use, easy to understand and widespread cut-off methodology where recycled material is accounted for on the input side. Even though the purpose of incentivising circularity and recycling is appreciated, we think it is problematic to prescribe a methodology that even many LCA experts struggle with understanding, giving results that are difficult to understand, and preventing comparisons with most of the earlier LCA studies in the field. There are also several identified implementation challenges with respect to the CFF, some of them highlighted in a report from the Swedish Life Cycle Center (2023), "Environmental Footprint in Swedish Industry - increased understanding and implementation". We see the relevance of implementing the proposed methodology also in research activities, why we will continue to work with this within our participation in ongoing Horizon battery projects such as NoVOC and GIGABAT. Additionally, we propose minor corrections and clarifications related to formatting, abbreviations, phrasing and the use of terms, as described in the attached document.
Read full response

Response to European Critical Raw Materials Act

12 Jun 2023

RISE believes that the commissions proposal to a large extent address relevant topics such as benchmark and goals, strategic projects and definitions, circularity and environmental assessment. RISE's views and comments on the present proposal mainly concern the parts that relate to definitions on strategic and critical materials, strategic projects and the proposal on stress test, permitting processes, value chain and a holistic system perspective including prolonged lifetimes and material recycling aspects. RISE comments are expressed in the attached file.
Read full response

Meeting with Ciarán Cuffe (Member of the European Parliament)

26 May 2023 · Heat Pump Conference

Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

1. General comments regarding new product priorities for Ecodesign for Sustainable Products: RISE supports the proposal for a regulation on ecodesign for sustainable products and has, in addition to a continuous focus on the environmental sustainability of materials and products, for a number of years actively worked with transparency and traceability issues and the importance of information transfer in value chains to enable circular flows. Since 2005, in the implementation phase of REACH, a supportive industry network was created at RISE focusing on chemical management. As expansion and targeted support, the Swedish Government pointed out substitution, whereby the Swedish Centre for Chemical Substitution at RISE was initiated. In addition, RISE has worked on technical development for recycling and reuse, material/product evaluation as well as guidelines, support, and tools to catalyze circular product and material flows. We see that the Commission's proposal to a large extent addresses the conditions we see as absolutely necessary to achieve set goals addressing the environment and sustainability. The right choice of materials and processes, design for circularity and making relevant information available from cradle to grave is a prerequisite for resource-efficient use of materials. In many sectors, we see an intensive development of circular business models, reuse, remanufacturing and recycling. Here, clear requirements regarding sustainable products and information transfer are key to success and upscaling. Also, there is a need for clear definitions and/or guidelines towards description of for instance reusable, recyclable or recycled content. RISE's views and comments mainly concern the parts that relate to information needs and the level of detail regarding information as well as technical aspects regarding information sharing. With regard to information sharing in value chains and the digital information carriers that may be relevant here, it is also important that harmonization with other product-oriented EU legislation, such as RoHS and WEEE, is carried out. In addition, harmonization between current chemicals legislation and envisaged regulation within the Ecodesign Regulation is needed, as well as a sufficient degree of flexibility to deal with future scenarios and rapid technology development. 2. Specific comments and viewpoints In addition to the comments that are provided as general comments (above), RISE also provides specific comments related to the product categories textiles, furniture and steel and non-ferrous metal products. This selection of specific comments should be seen as an exemplification of input on some of the product categories proposed by the JRC. For these product categories (amongst others) RISE also has extensive expertise. These comments are found in the file attached to this remittance.
Read full response

Response to European Critical Raw Materials Act

25 Nov 2022

RISE Research Institutes of Sweden welcomes the initiative on measures to secure more sustainable and resilient raw materials supply critical for the green transition and would like to give the following input to the development of the EU CRM Act. In relation to low diversification, untapped potential and adverse social and environmental impacts European mining, extraction and refinement often have a lower footprint (e.g., climate, biodiversity, water quality, and work force safety), than many of the producing countries our supply relies on, where environmental and working legislation is weak. Although the critical materials list has had its positive sides drawing attention to the problems with high supply dependence from outside EU, there are also risks. Many actors, including authority representatives and politicians, seem to miss-interpret the concept and think that non-critical metals and minerals are not needed. We also agree that more focus must be placed on the problem stated in future calls and funding, especially initiatives strengthening development of sustainable primary, secondary and tertiary extraction via waste and circularity frameworks. Actions that support entire value-chain actions are welcomed. This would support a level playing field for European actors.
Read full response

Response to A New European Innovation Agenda

10 May 2022

RISE, Research Institutes of Sweden AB, welcomes a new European Innovation Agenda that will contribute to a European RD&I landscape that will innovate faster, better and more sustainable. RISE, as a large European RTO, constantly seek to reduce the gap(s) between research & innovation in local, regional, national and European innovation ecosystems. Thus, the new European Innovation Agenda has the potential to facilitate RTO´s role as “system intermediaries” - linking research excellence to new innovative products/services being introduced on the market. RTO´s ability to contribute to the latter, and for tackling the problems described in the call effectively, the new European Innovation Agenda should consider: • Europe´s innovation capacity will increase with a stronger and more connected European landscape for technology infrastructures (TI). Today´s European R&I landscape lacks sufficient knowledge, coordination, public support and private investments for a connected European TI landscape. Thus, the new European Innovation Agenda and specifically the “initative on innovation ecosystem” should include actions to enable an open and financial sustainable TI landscape in Europe. • Creating synergies between different public programmes (all levels) is difficult in reality. Actors such as universities, RTO´s, larger companies often have the expertise (grants offices) which can identify and implement synergies between different funding streams. To also stimulate increased innovation capacity for SME´s/start-ups, and their ability to scale up and participate in European programmes and networks, an important first step is often public support/subsidies on SME´s access to test- and demonstrations environments. Collaboration between innovations actors is, as mentioned in the call text, a necessity to accelerate and master the innovative solutions needed for the European society. RTOs are equipped to balance public policies with private demands, which means that RTO´s often coordinate and enable public-private investments needed for the establishment and upgrade of test- and demonstration environments. In this context, and for European Pro-Innovation framework conditions, it is important that the state aid rules are devised and implemented well – considering; • Rules distinguishing economic from non-economic activities are efficient, but different national interpretations among the MS risk creating unnecessary gaps and different conditions for innovations actors depending on the national/regional context. • In the revised GBER regulation the new concept of “testing and experimentation infrastructures” (TEI) is welcomed, but should not be synonym to Technology infrastructures (TI) • The GBER and the RD&I State Aid Framework should differentiate infrastructures on their type of activities; Certain activities within technology infrastructures should fall under non-economic activities, reducing the risk of a misleading perception of the legal classification of the support for (aid to) technology infrastructures.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

RISE is an independent, state-owned Swedish research institute, which offers unique expertise and over 100 test and demonstration environments for future-proof technologies, products and services. Through our international collaboration programmes with industry, academia and the public sector, we ensure the competitiveness of the Swedish business community on an international level and contribute to a sustainable society. Our 2,800 employees engage in and support all types of innovation processes. RISE welcomes the final objective of the sustainable finance regulation – to enable financial flows to support sustainable growth and transition to a carbon neutral economy – and that this should not contradict the European Green Deal. In fact, an even stronger linkage to the European Union’s own objective of net zero greenhouse gas emission by 2050, including a declining ceiling to the greenhouse gas intensity of energy options is preferable. Finally, we welcome that the Taxonomy do not prescribe in detail where and how sustainable resources, such as bioenergy, should be employed. We are afraid that the proposal has several issues that create uncertainty in the marketplace hampering the development towards sustainability. The main concerns as the proposal is put forward is the inconsistencies with directives such as RED and the new “Strategy for Smart and Sustainable Mobility”, the fact that technology neutrality is not applied and continuous updates/revisions in three-year periods. The annex I part 9 is of particular importance to RISE. We advise a careful approach in defining which research, development and innovation activities that are sustainable. Methods to judge sustainability such as LCA can be applied but they have weaknesses even when applied to known systems. Applying them to research, development and innovation is not a recommended approach. It is better to define and align the foundation for research, development and innovation with sustainability as is the case for RISE. Our response in principle is focused on the following areas: • There should be full consistency between the Taxonomy and the EU’s Renewable Energy Directive (RED II). This goes both for feedstock inclusion and for sustainability criteria evaluation for bioenergy. • Regarding transport the Taxonomy should be revised to consider the perspective of life cycle emissions rather than tailpipe emissions only • Biofuels and the use of biomass and bioenergy in general should not be classified as a transitional activity. • We advise a careful approach in prescribing methods for research and innovation as these activities are of inherent exploratory nature and it is often not known how the end results will turn out. Research, development and innovation also enabling and transitional activities should be included.
Read full response

Response to Communication on the future of research and innovation and the European Research Area

3 Aug 2020

A renewed ERA should be based on the principle of a strong and seamless research and innovation ecosystem across Europe where education, research and innovation are integral parts to achieve the twin transitions of sustainability and digitalisation and be the basis for a competitive and inclusive Europe. RISE therefore welcomes the overview of ERA. The system of Research and Technology Organisations, RTO, is unique for Europe and hence, should continue to have a strong role in ERA. ERA should encourage regions and member states without a RTO structure to develop such, supported by already existing RTOs around Europe. The regional dimension is crucial for continue develop the research and innovation ecosystem and to increase inclusion, outreach and ultimately impact. The ERA should refocus on developing a strong industrial base, where SMEs play a key role, often being “the hidden champions”, with sustainable company management and strong corporate social responsibility. Addressing the technology development and diffusion challenges is essential to boost SMEs’ productivity and growth. The renewed ERA should champion a European Strategy on Technology Infrastructures. A strategic approach is needed to ensure that we have the technology infrastructures that are required in Europe to answer technology needs and support European industry to develop their innovation capacity and business transformation. Creating synergies and alignment between the different European programmes and strategies and national and regional strategies and programmes is essential. Strengthening of consistent mixed-funding schemes at European, national and regional levels would be very valuable in achieving the twin transitions across the EU. The PPP model is a success factor in replying to needs and opportunities with a high level of impact on business development and value for society. Therefore the PPP model should be integrated to other policy areas and used as a model to achieve co-design/co-creation ambitions. ERA should support a full integration of RDI into the EU industrial strategy, to prioritise enabling technologies and boost investments in Europe. RTOs will play a key role to support the creation of such alliances by their industrial partners.
Read full response