Lobbying by Siemens AG | OpenLobby.EU

Siemens AG

SAG

Siemens AG is a leading technology company focused on industry, infrastructure, and mobility.

Focus Areas

2025

2023-2024

2015-2022

Links

Website Transparency Register Profile

ID: 4266797770-31

Lobbying Activity

Meeting with Valérie Hayer (Member of the European Parliament) and Amazon Europe Core SARL and

28 Jan 2026 · Politique commerciale de l'UE

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology)

22 Jan 2026 · Exchange on innovation for European competitiveness

Siemens urges EU to prioritize digitalization in materials act

7 Jan 2026

Topic — The European Commission initiative aims to accelerate the development and production of advanced materials.

Message — Siemens recommends establishing a digital backbone for materials research using AI and digital twins. They propose targeting simplification measures specifically at producers to avoid impractical rules for diverse stakeholders. Public funding should prioritize automated manufacturing and circular design through product lifecycle software.1 2

Why — Digital manufacturing allows Siemens to achieve high performance using standard, cheaper, and accessible materials.3

Impact — Diverse researchers and users may face administrative burdens if simplification measures exclude them.4

Read full response

Meeting with Alvydas Stancikas (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

12 Dec 2025 · Collect stakeholders’ input on barriers to the Single Market

Siemens Urges Industrial Focus for EU Quantum Act

11 Dec 2025

Topic — The initiative aims to accelerate the research, development, and industrial deployment of quantum technologies.

Message — Siemens proposes focusing R&D on industrial optimization, simulation, and post-quantum cryptography. They advocate for diverse funding mechanisms instead of using a single overarching platform. They also suggest establishing an Important Project of Common European Interest for Quantum.1 2

Why — This approach would reduce operational costs and create market opportunities for their cybersecurity solutions.3 4

Impact — Protectionist policy advocates lose if the EU rejects restrictive regional procurement clauses.5 6

Read full response

Meeting with Ekaterina Zaharieva (Commissioner) and

11 Dec 2025 · Innovation policy and funding; Artificial Intelligence

Meeting with Bonifacio Garcia Porras (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

11 Dec 2025 · Foreign Subsidies Regulation Review Report Siemens AG provided feedback regarding the Foreign Subsidies Regulation Review Report.

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

9 Dec 2025 · Global Gateway Priorities in LAC

Meeting with Brando Benifei (Member of the European Parliament)

9 Dec 2025 · Digital Omnibus in AI

Response to EU taxonomy - Review of the environmental delegated act

5 Dec 2025

Siemens main recommendations: 1. Scope: Recognise the role of energy efficiency solutions for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2. Low-carbon transport: Address usability challenges for railway activities, ensuring rolling stocks (CCM 3.19) are included in CCM 3.3 and refining the application scope of the PPC DNSH to avoid inconsistencies with Omnibus and FAQs. 3. Electrical transmission and distribution (CCM 3.20): explicitly mention medium voltage equipment, products and software and clarify that consistency (rather than compliance) with technical standards to improve legal certainty. Avoid lowering the carbon intensity threshold without firstly addressing unintended consequences for renewables integration in the electricity grid. Clarify that PPC and WTR DNSH do not apply to software. 4. Buildings: Ensure consistency of ambition levels for CE 3.1 and CE 3.2 with CCM 7.7, clarify technical screening criteria regarding circular design and adaptability and review requirements related to raw material consumption with market practices. Address usability difficulties of buildings built before 2020 and applicability limitations beyond Europe as per CCM 7.7. 5. Electrical & Electronic Equipment (CE 1.2): review substance-related requirements to ensure consistency within the criteria and existing legislation (incl. REACH restrictions, RoHS). 6. Generic DNSH: Provide relevant supporting tools to ensure proper implementation of generic DNSH criteria, esp. for activities outside Europe. Refine terminology in Appendix A and Appendix C to facilitate common interpretation across preparers. For more details, please refer to the attached position paper.

Read full response

Meeting with Bjoern Juretzki (Head of Unit Communications Networks, Content and Technology)

4 Dec 2025 · Discussion about industrial large-language models

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and ELECTRICITE DE FRANCE and

1 Dec 2025 · 4th meeting of the Working Group on Regional Electricity Integration in Latin America and the Caribbean

Siemens urges broader EU Chips Act beyond manufacturing focus

27 Nov 2025

Topic — EU Chips Act 2.0 aims to strengthen semiconductor ecosystem and value chain.

Message — Siemens requests expanding the Act beyond frontend manufacturing to include chip design, design enablement, backend activities, and substrates/PCBs. They want involvement of large end-users in projects with attractive funding schemes and support for existing fabs using Industrial AI.1 2 3

Why — This would secure their access to diverse chip technologies and reduce compliance burdens.4 5 6

Read full response

Meeting with Jessika Roswall (Commissioner) and

18 Nov 2025 · Circularity, non-toxic environment and simplification

Meeting with Vanessa Debiais-Sainton (Cabinet of Executive Vice-President Roxana Mînzatu)

18 Nov 2025 · Skills and job transitions

Meeting with Ioan-Dragos Tudorache (Cabinet of Executive Vice-President Stéphane Séjourné) and Alstom

17 Nov 2025 · Digital omnibus and Cybersecurity Act application to railway sector

Meeting with Hildegard Bentele (Member of the European Parliament, Rapporteur)

17 Nov 2025 · Global Gateway

Meeting with Borys Budka (Member of the European Parliament, Committee chair) and TotalEnergies SE and

12 Nov 2025 · ITRE ongoing work

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

5 Nov 2025 · Exchange on the collaboration opportunities related to the AI Lighthouse project (notably the industrial-data-pooling partnership) promoted by Siemens.

Meeting with Estelle Goeger (Cabinet of Executive Vice-President Stéphane Séjourné) and Bundesverband der Deutschen Industrie e.V. and

4 Nov 2025 · Overview of the Commission's Single Market Strategy.

Siemens urges EU to prepare grid infrastructure for AI deployment

3 Nov 2025

Topic — New EU strategy for leveraging digital technologies and AI in the energy sector.

Message — Siemens requests investments in digital grid infrastructure, harmonized data standards using Asset Administration Shell, streamlined AI regulations without duplication, and AI training for energy professionals.1 2 3

Why — This would reduce infrastructure costs and accelerate deployment of their digital grid solutions.4 5

Read full response

Siemens urges ambitious EU research funding and stronger industry voice

3 Nov 2025

Topic — Future EU budget proposals for competitiveness funding and Horizon Europe research programs.

Message — Siemens requests increasing Horizon Europe budget to €200-220 billion with 55% allocated to collaborative research, expanding digital and defense research funding, integrating Industrial AI and software technologies into funding priorities, and guaranteeing major corporate representation on the Strategic Stakeholders Board. They seek clarity on EU Preference rules and simplified participation requirements.1 2 3 4

Why — This would increase funding for collaborative research projects where Siemens participates and ensure favorable rules for large companies.5 6 7

Impact — Smaller research institutions and SMEs may lose funding share as budget reallocates toward large corporate collaborative projects.8

Read full response

Siemens Urges Digital Standards to Streamline EU Building Carbon Assessments

30 Oct 2025

Topic — EU framework for calculating life-cycle global warming potential of new buildings from 2030.

Message — Siemens requests integration of the Asset Administration Shell digital standard into EU building regulations. They argue this would enable standardized, machine-readable data exchange for carbon calculations and reduce administrative burdens.1 2 3

Why — This would position Siemens' Industry 4.0 digital framework as a standard for EU building data.4

Read full response

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

27 Oct 2025 · EU competitiveness. The interlocutors presented the Evian Declaration

Meeting with Christian Doleschal (Member of the European Parliament)

22 Oct 2025 · Konformitätserklärung auf Basis gelisteter Normen

Meeting with Pierpaolo Settembri (Cabinet of Commissioner Apostolos Tzitzikostas) and UNIFE and Alstom

22 Oct 2025 · Cyber Resilience Act (CRA), Data Act, and Artificial Intelligence (AI) Act in the scope of the Digital Omnibus

Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and Schneider Electric

14 Oct 2025 · Switchgears and F-Gas Regulation

Siemens urges EU to repeal Data Act and exempt industrial AI

10 Oct 2025

Topic — EU simplification package for digital regulations including AI Act, Data Act, and Cyber Resilience Act.

Message — Siemens requests repealing the Data Act or exempting B2B cases, exempting industrial AI from the AI Act, extending CRA implementation by 36 months and AI Act deadlines by 24 months, and eliminating regulatory overlaps between digital acts.1 2 3

Why — This would reduce massive compliance costs and implementation burdens while allowing more time to adapt systems.4 5 6

Impact — Consumer groups and smaller companies lose protections as exemptions favor large industrial players.7 8

Read full response

Siemens urges simplified CBAM reporting with grid-specific emission factors

24 Sept 2025

Topic — EU regulation on calculating embedded emissions for Carbon Border Adjustment Mechanism implementation.

Message — Siemens requests standardized emissions methodology with user-friendly reporting systems and minimal verification requirements. They want grid-specific emission factors for electricity defined to incentivize low-carbon energy use. The company seeks flexibility to use default values for small suppliers while focusing actual values reporting on bigger contributors.1 2 3

Why — This would reduce compliance costs by avoiding duplicate reporting and focusing resources on major suppliers.4 5 6

Impact — Smaller suppliers lose as flexibility measures may exempt them from detailed emissions tracking.7 8

Read full response

Siemens urges system-level efficiency focus over component mandates

22 Sept 2025

Topic — EU review of ecodesign requirements for electric motors and variable speed drives.

Message — Siemens requests prioritizing overall system efficiency rather than individual components, excluding servo drives from energy efficiency mandates, and implementing a stepwise Digital Product Passport introduction until 2032. They advocate for mandating frequency converters in specific applications like pumps and fans instead of stricter component requirements.1 2 3 4

Why — This would reduce compliance complexity and costs while avoiding additional material efficiency requirements beyond existing standards.5 6 7

Impact — Environmental advocates lose stronger material efficiency targets and faster implementation of recycled content requirements.8

Read full response

Meeting with Stéphane Séjourné (Executive Vice-President) and

5 Sept 2025 · - Compétitivité des entreprises - Marché intérieur - Protection de la souveraineté et du pouvoir d’achat - Relation US/EU

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

28 Aug 2025 · Exchange of views on the EU AI strategy, including the AI Continent Action Plan and the development of the future Apply AI Strategy

Response to Revision of the 'New Legislative Framework'

25 Aug 2025

Siemens AG is a strong advocate of free trade and, logically, the free movement of goods within the European Union. As a manufacturer and distributor of technical industrial products, we have a keen interest in a regulatory framework that is well functioning, efficient and lean. Like any institution thats no longer in its youth, the NLF could use a bit of renovation and modernization to continue serving all stakeholders effectively. Some thoughts on this are outlined in the attached memo. We wish the EU Commission a sure hand in its efforts! Kind regards, M. Reigl / Siemens AG

Read full response

Meeting with Lukas Mandl (Member of the European Parliament)

12 Aug 2025 · EU-Wettbewerbsfähigkeit, Omnibus

Siemens Urges Digital Transformation of European Electricity Grids

4 Aug 2025

Topic — EU initiative to accelerate the upgrade and digitalization of energy infrastructure.

Message — Siemens calls for treating digital technologies as strategic assets and streamlining grid connection processes. They advocate for prioritizing smart, flexible assets over a "first-come, first-served" model.1 2

Why — Focusing on digital-centric grid regulation would drive significant market demand for Siemens' specialized technology.3

Impact — Developers of less efficient infrastructure lose their current priority status for grid connections.4

Read full response

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva)

25 Jul 2025 · Scaleup Europe Fund and European Industrial AI Lighthouse

Response to Revision of the Standardisation Regulation

21 Jul 2025

Siemens AG and its affiliated companies have a strong interest in a functioning and high-performing European standardization system to support legal certainty for manufacturers, traders, vendors and users, to maintain the free movement of goods within the internal market, and to accompany innovation in competitive markets. Siemens therefore welcomes the Commissions initiative modernize the system by revising Regulation (EU) 1025/2012. An opinion statement is attached. Best wishes for a successful outcome, Siemens AG.

Read full response

Meeting with Rigo Belpaire (Acting Head of Unit Directorate-General for International Partnerships)

17 Jul 2025 · Exchange of views on the approach to and process of project preparation, structuring and financing and implementation in DG INTPA target countries.

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Bertrand L'Huillier (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

3 Jul 2025 · Digital Industries, Smart Infrastructure, Mobility and broad, diversified global footprint.

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

3 Jul 2025 · Trade policy (US, China)

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

3 Jul 2025 · Simplification agenda Competitiveness

Meeting with Pascal Leardini (Deputy Secretary-General Secretariat-General)

3 Jul 2025 · Exchange of views on the simplification agenda of the commission

Siemens urges EU to delay AI rules and simplify grid access

2 Jul 2025

Topic — The EU initiative aims to triple data processing capacity through industrial investments and innovation.

Message — Siemens requests faster grid connections and permitting to eliminate bottlenecks for data centers. They also demand a two-year delay for the AI Act to simplify the digital regulation landscape.1 2

Why — This would allow Siemens to sell more infrastructure solutions while reducing administrative burdens.3 4

Impact — Delaying AI safety rules harms public oversight and digital security for European citizens.5

Read full response

Meeting with Sven Gentner (Head of Unit Financial Stability, Financial Services and Capital Markets Union) and Schneider Electric and

23 Jun 2025 · CSRD omnibus

Meeting with Jutta Paulus (Member of the European Parliament)

10 Jun 2025 · Clean Industrial Deal

Meeting with Miguel Gil Tertre (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

3 Jun 2025 · Digitalisation and sustainability

Response to Quantum Strategy of the EU

2 Jun 2025

We welcome the European Commissions call for evidence and opportunity to comment on EUs envisaged Quantum Strategy. Indeed, lack of skills, well-equipped R&D centra, cross-border public private efforts and sufficient production of quantum processors for and within the EU, are all major challenges to address. We welcome the Strategys focus on: Collaborative R&D to trigger public and private investments. Fostering a competitive environment that enables start-ups and scale-ups to remain in Europe and thrive globally thanks to easier access to capital and finance; Prioritizing skills and talent development, improving training and education measures Strengthening supply chain resilience and reducing strategic dependencies. Engaging like-minded international partners on standards development. Siemens recommendations: 1. Europe must play its strength! In addition to addressing climate change, the EU cannot lose sight of other fields of technology such as quantum technologies. Many potential applications are not yet recognizable today. 2. Establish Europe as a global leader in this future technology. Place game changer quantum technologies as a key strategic competence with very high relevance in terms of competitiveness, sovereignty and resilience. 3. Think and support quantum technologies in application fields/systems. Resolutely drive forward the transfer of knowledge between industrial sectors and from science to the economy. 4. The support activities today are mainly focused on science. The economy must also be given equal consideration here and be an integral part of the ecosystem to ensure economic utilization. This applies to both the hardware and software sectors. 5. The development of sensible, innovation-promoting guidelines and standards with a global pioneering function should be tackled promptly and in close cooperation with industry. 6. Consider the effects of quantum technologies and prepare for them. Keyword: Post Quantum Cryptography. At Siemens Quantum technologies are considered as one of our major R&D focus themes for the coming years. Example: Quantum Technology use Case: Drug Discovery Why It Matters: Quantum computing can simulate molecular interactions at an unprecedented scale and speed, accelerating the discovery of new drugs and treatments. This has the potential to revolutionize healthcare and pharmaceuticals. Industries Impacted: Healthcare, Pharmaceuticals, Biotechnology. Economic Impact: Positions Europe as a leader in cutting-edge medical and pharmaceutical technology, attracting investment and fostering innovation and resilience in pharma industries. Further R&D is required in the following areas: Basic Science for Quantum Technologies Quantum AI: exploring quantum use cases in industrial AI Next generation quantum sensing technologies Quantum encryption and future quantum network technologies, Developing the first large-scale quantum computers Post Quantum Cryptography (PQC) The EU Quantum strategy must at least have the above areas up taken in its planned quantum strategy. An in-depth excursion on Post Quantum Cryptography (PQC) is enclosed in the uploaded document. This upload document presents the complete input to this Call for evidence

Read full response

Siemens opposes new EU rules for reconfigurable radio equipment

27 May 2025

Topic — The EU is updating rules ensuring radio equipment stays compliant after software updates.

Message — Siemens rejects new requirements for reconfigurable radio systems, advocating for the status quo. They argue manufacturers already ensure software-hardware combinations comply with existing safety and spectrum legislation.1 2

Why — This position protects the company from unnecessary compliance costs and burdensome administrative procedures.3 4

Read full response

Meeting with Henna Virkkunen (Executive Vice-President) and

23 May 2025 · Presentation of Siemens AG. Exchange of views on the Commission’s work on simplification.

Meeting with Christian Doleschal (Member of the European Parliament)

16 May 2025 · New Legislative Framework

Meeting with Alexandra Geese (Member of the European Parliament) and Deutsche Telekom and

29 Apr 2025 · Event: DACH-Tech

Response to Technical description of important and critical products with digital elements

18 Apr 2025

From a Siemens AG perspective, it is essential that companies are being given sufficient time to prepare the implementation of the CRA. We feel that the current deadlines are very challenging and force companies to allocate significant resources to it. This is also valid for the European standardisation activities which will rely on those technical descriptions. Simplification of the framework is therefore critical. This is why it is also important to start with a clearly defined set of products rather than very global technical descriptions.

Read full response

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque) and Manufacture Française des Pneumatiques Michelin and ABB Ltd

14 Apr 2025 · Sustainability Omnibus

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and UNIFE and

9 Apr 2025 · Rail Supply Industry challenges and opportunities

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · Plenary Feedback round on previously held GGIA Working Group sessions of 9 different thematical groups regarding Latin America and the Caribbean (LAC).

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Vincent Hurkens (Cabinet of Executive Vice-President Stéphane Séjourné) and

1 Apr 2025 · Simplification of sustainability reporting

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · In the context of the EU-LAC Global Gateway Investment Agenda, the European Commission’s Directorate-General for International Partnerships (DG INTPA) launches an initiative with a view to develop circular economy value chains in Latin America

Meeting with Ondřej Krutílek (Member of the European Parliament)

1 Apr 2025 · Clean Industrial Deal

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

31 Mar 2025 · Shaping a new Team Europe approach towards LAC in order to increase the success rate of EU Railways industry on tenders on the region.

Meeting with Jozef Síkela (Commissioner) and A.P. Møller - Mærsk A/S and

27 Mar 2025 · Dinner with key stakeholders to discuss the enlargement project of the Port of San Antonio

Response to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies

23 Mar 2025

Siemens main recommendations: To ensure business certainty and legal clarity, the European Commission shall promptly publish the finalized Delegated Act in the EUs Official Journal, and most notably as soon as the scrutiny period of the EUs co-legislators ends. The European Commission shall adopt technical screening criteria for energy efficiency in industrial processes when finalizing its Delegated Act, thus integrating the recommendations of the Platform on Sustainable Finance as to the additional activities to be covered in the scope of the Taxonomy Regulation. To avoid uncertainties, the European Commission shall clarify the wording on the 25% threshold for the OpEx KPI. The European Commission shall further rework the reporting templates, privileging a single path approach (i.e. remove multiple contribution reporting requirements) and removing the description of the activities. These improvements will deliver on simplification and comparability objectives. The European Commission shall decide on option 1, hence the deletion of paragraph (f) bis, and improve further Appendix C provisions. The European Commission shall urgently conduct an in-depth review of DNSH criteria with the aim of aligning them with existing EU legislation and thus improving their usability. Beyond Taxonomy: Further usability improvements can be fostered by better connecting the Taxonomy and the CSRD. The European Commission shall reduce the ESRS definition to a manageable level. In the context of the upcoming SFDR revision, the European Commission shall work to further increase the Taxonomy update within the financial community, so as to truly boost investments and market demand in sustainable activities.

Read full response

Meeting with Lucilla Sioli (Director Communications Networks, Content and Technology) and

21 Mar 2025 · Exchange on AI development and the EU’s upcoming initiatives

Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

19 Mar 2025 · the role of research and innovation for EU competitiveness

Meeting with Tomislav Sokol (Member of the European Parliament)

19 Mar 2025 · Health policy

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and Deutsche Bank AG and

12 Mar 2025 · Meeting of the South America Critical Raw Materials (CRM) Coalition of the Willing – Dialogue with private and public sector stakeholders, and financial institutions on sustainable critical raw materials value chains in Latin America.

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

11 Mar 2025 · Exchange of views between the Comission and Siemens on trade relations

Meeting with Claudia Olazabal (Head of Unit Environment) and Veolia Environnement and

25 Feb 2025 · Exchange of views on digitalisation in the water sector

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Feb 2025 · Exchange of views with UNIFE CEOs on the margins of the 18th European Railway award event

Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur)

6 Feb 2025 · Grids INI

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships)

5 Feb 2025 · Exchange of views on the Global Gateway in Latin America and the Caribbean and the Global Gateway Investment Agenda.

Meeting with Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

4 Feb 2025 · Omnibus

Meeting with Radan Kanev (Member of the European Parliament) and Orgalim – Europe's Technology Industries and

28 Jan 2025 · European Forum for Manufacturing Dinner- Decarbonisation through a technology neutral approach

Response to COM Prop Regulation EP+EC for public interface to IMI for posting of workers declaration + SWD

24 Jan 2025

Have Your Say (24/01/2025): On the proposal for a regulation on a public interface connected to the Internal Market Information System for the declaration of posting of workers and amending Regulation (EU) No 1024/2012 General remarks We welcome the opportunity to comment and have our say and highly appreciate the Commissions' proposal to harmonize and regulate the declaration of posting of workers. Consulting with industry and additional stakeholders is fundamental to allow us to express our views and specific needs to ensure freedom to provide services in another Members States. As a mayor industry player, Siemens and its affiliated group companies within the European Union have one of the largest volumes of cross-border posted workers notification within the Member States. Labor and skill shortage in the EU leading to increasing requirements to provide Services across the Member States complying with the defined terms and conditions of each employment as established by the Directive 96/71/EC and the Directive 2014/67/EU. Siemens view on the current status The member states have implemented declaration obligations through their national systems differing significantly in design, technology, content requirements and functionality. Complying with these diverging systems creates not only a considerably high administrative burden within Siemens, but also requires expertise and language knowledge to ensure compliance with the posted workers notification that lead to a high-cost impact and longer lead times. The notification itself to enable control measures and ensuring proper reporting by the Member States will not be called into question by Siemens. The need to ensure an appropriate level of protection of the right of posted workers for cross-border provision of service is undoubtful a requirement to fulfil. However, we doubt that the current diversity of national systems and requirements do fulfill the controlling and reporting requirements. Siemens` recommendations 1. Put focus on to use one public interface with one common standard form consisting of exhaustive set of relevant information. There should be no additional information requirements imposed at national level. 2. Multilingual interfaces and upload options would reduce the translation costs and time efforts by providing all required documents. 3. There is a high need to ensure that all Member States are participating to ensure end-to-end process as cross-border assignments always include two countries views. Phased implementation may be an acceptable way forward. 4. There is a need for a strong and streamlined framework for posting declarations to scale and reduce administrative burden on authority and industry level. 5. Additional points of attention for the European Commission a. With a public interface and simplified administrative procedures the Member States authorities will be able to reduce their administrative burden as well. b. One common approach with strength service provision throughout the EU Members States ensuring strong EU business during the current volatile times. c. One interface and data exchange will increase the level of data protection as personal related data is exchanged. d. As the Internal Market Information System is already existing it will ease the access for the cross-border service providers.

Read full response

Meeting with Stéphane Séjourné (Executive Vice-President) and

22 Jan 2025 · Economic State of play of sector

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné) and UNIFE and

12 Dec 2024 · RAIL SUPPPLY INDUSTRY PRIORITIES

Meeting with Christian Ehler (Member of the European Parliament)

11 Dec 2024 · Competitiveness

Meeting with Radan Kanev (Member of the European Parliament)

11 Dec 2024 · Clean Industrial Deal

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and Orange and

8 Oct 2024 · General discussion on Taxonomy and CSRD deployment.

Meeting with Sigrid Friis (Member of the European Parliament) and Schneider Electric and

8 Oct 2024 · Upcoming term in relation to energy policy

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

Siemens urges harmonized spectrum for private industrial networks

28 Jun 2024

Topic — The consultation explores scenarios to improve Europe's digital infrastructure and connectivity.

Message — Siemens calls for a harmonized European approach to spectrum assignment specifically for local private networks. Access to this spectrum should be easy and affordable to benefit vertical industries. They also advocate for a holistic resilience strategy supported by dedicated funding programs.1 2 3

Why — Uniform spectrum access allows Siemens to deploy standardized industrial connectivity solutions across all European markets.4

Impact — Traditional telecom operators may face more competition for spectrum resources and less control over industrial connectivity.5

Read full response

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis)

27 Jun 2024 · Trade / geopolitical priorities for the next EU institutional cycle

Meeting with Mairead McGuinness (Commissioner) and Orange and

26 Jun 2024 · Sustainability policies, in particular CSRD, Taxonomy

Response to Format of the carbon footprint declaration for batteries

28 May 2024

Siemens AG is a technology company focused on industry, infrastructure and transport. We have a strong digitalisation expertise and long experience as providers of software solutions and manufacturers of highly complex electronics. For years, we have been working to create maximum transparency over the emissions across the value chains - the aims being creating a PCF matrix for our as well as for our customers' procurement and further boosting our environmental ambition when calculating environmental product declarations. We welcome the Commission's Delegated Acts as these would bring more clarity and help us in implementing the Batteries Regulation. However, we have some concerns regarding the proposed texts: we observe these would create more unclarities and reduce the transparency, that is sought by the Battery Regulation. For instance, the circular footprint formula which cannot be transferred to other product systems without creating millions of additional specifications would trigger complexity, and therefore undermining the implementation of the Batteries Regulation. The mentioned data and calculation requirements cannot safely be operated by many stakeholders in our value chain and therefore would cause data chains to break. What is more is that the generated complexity with the use of different methodologies for reporting the same components feeding into different products would reduce transparency and generate misleading declarations. For these reasons, we recommend the Commission to review the proposed methodology and data model along the following lines: a) Calculation methodology: - Maintain the application of Environmental Footprint (EF) 3.1 as this is one of the most widely used methods. - Avoid using the circular footprint formula (CFF). This adds complexity. - Use average EU mix rather than national average electricity consumption mixes. The risks of not following this recommendation would be to widen the gap between countries with low carbon and high carbon energy mixes, and complexify the report (which would ultimately lead to less accurate declarations). - Allow for more data aggregation in the LCA study to avoid risks of disclosing sensitive data. We fear that adding the full BOM-information will disclose confidential business information. b) Data model: - Avoid splitting the production phase of the lifecycle into two stages (i.e. resource extraction stage, manufacturing stage). We do not believe this approach adds on transparency. On the contrary, it would create more confusion, and cause false or inconsistent declarations, since the two stages tend to differ from product system to product system. - Set up a harmonised classification of the batteries to be shown in the format. - Mention the use phase contribution separately in the format since this is the most relevant contribution to the calculation. We remain available to provide additional clarifications and contribute to a carbon footprint methodology and data model that steer transparency all along the value chains.

Read full response

Siemens warns EU battery carbon rules create unnecessary complexity

28 May 2024

Topic — Proposed methodology for calculating and verifying the life-cycle carbon footprint of batteries.

Message — Siemens recommends maintaining existing footprint standards and avoiding complex circularity formulas. They suggest using EU average electricity mixes and allowing data aggregation to protect confidential business information.1 2 3

Why — Using familiar methodologies and protecting data would reduce technical complexity and safeguard secrets.4 5

Impact — Manufacturers in high-carbon energy countries lose competitiveness compared to low-carbon regions.6

Read full response

Meeting with Markus Ferber (Member of the European Parliament)

26 Mar 2024 · Revision of European Works Councils Directive

Meeting with Svenja Hahn (Member of the European Parliament) and BUSINESSEUROPE and

21 Feb 2024 · Stakeholder Roundtable on Late Payment Regulation

Meeting with Wopke Hoekstra (Commissioner)

17 Feb 2024 · Latest developments on EU climate and energy policy

Meeting with Deirdre Clune (Member of the European Parliament, Shadow rapporteur)

30 Jan 2024 · Artificial Intelligence

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and Policy Hub - Circularity for Apparel and Footwear

29 Jan 2024 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Response to Reporting scheme for data centres in Europe

15 Jan 2024

Please find attached Siemens' feedback on a common Union rating scheme for data centres.

Read full response

Response to Enhancing research security in Europe

22 Dec 2023

Siemens AG is a global technology powerhouse that has stood for engineering excellence, innovation, quality, reliability and internationality for more than 170 years. The company is active around the globe, focusing on the areas of intelligent infrastructure for buildings and distributed energy systems, and automation and digitalization in the process and manufacturing industries. Further information is available on the Internet www.siemens.com. We welcome the opportunity offered for providing feedback and would like to underline we support the already submitted feedback from BDI and ZVEI to which we contributed. In addition, our main comment points are the following: - We acknowledge the concerns that the sharing of sensitive technologies could jeopardize national security if used for military purposes or to suppress fundamental rights. - From the provided Call for Evidence document it is not clear whether also industrial Research and Innovation activities are also meant to be included in the scope of these planned principles and policy actions at national and sector level (We observed that the words Industry or industrial research do not appear once in the whole Call for Evidence document for this feedback survey) - If industrial research would come into scope, then we would at least have following points to remark: 1. In the light of the many new and additional regulatory burdens which the EU recently introduced (DSA, Green Deal regulations, Data Act, AI Act) or intends to introduce (CRA, .) we strongly recommend avoiding any additional burdens for the industry (or European economy). 2. We must not forget that the success of the EU economy depends largely on its access to our export markets around the world. Any measures or activities driven by the EU which indicate or lead to restrictions related to the EU economys freedom to do business, or to perform research and innovation activities with, or in other countries, might lead to countermeasures taken by the affected countries, i.e. important export markets for European companies. 3. It is of utmost importance that the EU carefully considers any potential negative effects on EU-based companies. 4. The policy makers should take the necessary measures to ensure that the proposed recommendations and/or guidelines are applied in a harmonized way across all 27 EU Member States (avoiding a patchwork of different national recommendations or guidelines)

Read full response

Meeting with Marion Walsmann (Member of the European Parliament, Rapporteur) and Volkswagen Aktiengesellschaft and

29 Nov 2023 · Standard Essential Patents

Meeting with Nicolas Schmit (Commissioner) and

16 Nov 2023 · Technology and Skills, reskilling/upskilling

Meeting with Ursula von der Leyen (President) and European Round Table for Industry

6 Nov 2023 · Meeting with Chair of ERT and Chair of Siemens (Topic: Discussion on Competitiveness)

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and DIGITALEUROPE and

3 Nov 2023 · Support period in CRA

Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur)

23 Oct 2023 · Green Claims Directive.

Meeting with Michael Bloss (Member of the European Parliament) and Salzgitter AG

23 Oct 2023 · Industrietransformation

Meeting with Nicola Beer (Member of the European Parliament, Rapporteur)

20 Oct 2023 · Critical Raw Materials Act (Meeting held by parliamentary assistant)

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur) and Textile Exchange

16 Oct 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Meeting with Cyrus Engerer (Member of the European Parliament, Rapporteur)

27 Sept 2023 · Green Claims Directive

Meeting with Maurits-Jan Prinz (Cabinet of Commissioner Thierry Breton) and Airbus and

7 Sept 2023 · discussion on AI Act

Siemens AG claims new EU patent regulation is unnecessary

25 Jul 2023

Topic — The consultation addresses a new framework for standard essential patent licensing.

Message — Siemens asserts there is no need for this new EU Regulation. The rules should only apply upon a specific request.1 2

Why — This would prevent unnecessary administrative complexity and reduce rising compliance costs.3

Impact — Consumers could face higher prices as stakeholders pass on increased regulatory costs.4

Read full response

Siemens Urges Narrower Scope for EU Sustainability Reporting Rules

6 Jul 2023

Topic — The European Commission is defining mandatory sustainability reporting standards for large companies across the EU.

Message — Siemens requests limiting reporting requirements to direct suppliers rather than the entire value chain. They also recommend removing requirements to disclose sensitive business strategies and harmonizing definitions for social metrics.1 2 3

Why — These changes would protect proprietary business secrets and significantly reduce the administrative burden of data collection.4

Impact — Environmental and human rights groups lose visibility into impacts occurring deep within global supply chains.5

Read full response

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

26 Jun 2023 · Data Act

Response to Extension of the date of applicability of the RED delegated act on cybersecurity, privacy and protection from fraud

20 Jun 2023

Siemens AG welcomes and supports an extension of the transition period of Delegated Regulation (EU) 2022/30. Justification: - Directive 2014/53/EU obliges the manufacturer to mandatorily involve a Notified Body in the conformity assessment of a product (if Art. 3 (3) is applicable) in case harmonised ENs are not listed in the OJEU under the legal act. - Even in the case a Notified Body has to be involved, a hEN would support comparability of measures implemented in the product and in addition comparability of conformity assessment results. - Sufficient additional time is needed by ESOs, HAS-consultants and the Commission to develop / assess and list the required hENs in the Official Journal of the EU. - Notified bodies need sufficient time to build up necessary competences and resources to support the conformity assessment. - It is crucial, that hENs are available in due time in order to support the correct implementation and that a sufficient transitional period allows to perform the conformity assessment procedures. We are therefore in favor of an extension of the current transition period as set out in Delegated Regulation (EU) 2022/30 at least until Aug. 2025.

Read full response

Meeting with Antoine Colombani (Cabinet of Executive Vice-President Frans Timmermans), Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and

14 Jun 2023 · EU Green Deal Industrial Plan

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Ørsted A/S and

9 May 2023 · Energy markets; CEO meeting under the Baltic Offshore Wind Forum; Other participants: Litgrid, Latvenergo, AST, Gasgrid Finalnd, Suomen Hyötuuli

Siemens AG Urges Practical Standards for EU Green Taxonomy

2 May 2023

Topic — The EU is defining which economic activities qualify as environmentally sustainable for investment purposes.

Message — Siemens requests explicit inclusion of medium voltage equipment to ensure legal certainty for grid investments. They propose replacing cumulative technical requirements with a single-criterion approach to recognize environmental contributions. They also recommend relaxing waste recycling thresholds for buildings to match current industry practices.1 2 3 4

Why — These changes would reduce administrative complexity and ensure more Siemens products qualify as sustainable.5 6

Impact — Environmental groups might argue that lowering recycling thresholds and substance restrictions weakens ecological protections.7 8 9

Read full response

Response to Virtual worlds, such as metaverse

28 Apr 2023

BRIEF SUMMARY (Full input in attached upload document): 1. Put focus on the industrial metaverse, with clear distinction between B2B and B2C The specific challenges and characteristics of the industrial metaverse should be tackled in parallel with the ongoing dialog around the B2C metaverse use cases. 2.There is a high need to stimulate and accelerate the uptake of Digital Technologies in Europe. Today the uptake of digital technologies by European companies is much too slow and there is insufficient awareness of the potential brought by the industrial metaverse. The Metaverse enabling technologies, such as Digital Twins, Edge/Cloud, 5G, 6G Blockchain (NFTs), AI, AR/VR, need further support both from the public and the private sector, as well as more awareness raising about all potential benefits for industry. Because the Industrial metaverse is making use of already available technologies and building blocks, and these are already being regulated (like eg. Data, AI, Cloud,) there is no need for any additional regulation! 3.There is need for a strong, industry-led (international) standardization effort. A strong European industrial representation will help secure a European leadership in the global industrial metaverse ecosystem. Europe must engage also in relevant international standardization efforts, such as The Metaverse Standards Forum, as well as in related initiatives within the OECD and other international organization. As the Industrial Metaverse must take existing industrial assets into account (brownfield) it has to be based on the respective international standards and norms from ISO and IEC that are currently preparing a Joint Systems Evaluation Group on the subject of Metaverse applications. 4. Next generation connectivity is crucial. In the Industrial Metaverse companies of all sizes will be able to employ digital twins with real-time performance data. To enable this, real-time connectivity, a fast and dedicated roll out of next generation connectivity networks will be crucial because the future of the industrial metaverse will rely heavily on the available next-generation networks (5G-6G), including dedicated spectrum allocation for industry like private campus networks- and licensing spans (Benchmark: 5G bandwidth for industrial campus networks in Germany) 5.Global collaboration among industry players will be key. Interoperability is essential to foster cross-company exchanges, requiring extensive collaboration among all involved industrial players, including non-European companies. 6.Additional points of attention for the European Commission: - Provide support for an enabling Intellectual Property and cybersecurity framework: an appropriate framework for IP protection and cybersecurity will be crucial for the success of the industrial metaverse. - Strengthen the links with EU research and academia: collaboration between the industrial sector and research institutions needs to be reinforced. - Address the shortage of skilled experts: there is a growing shortage of skilled professionals in the sector: high need for EU-wide support for the training of the next generation of designers and VR experts. - Ease the access to finance regime in Europe to support public investment into new technologies. Horizon Europe and its planned successor must be used as potential financing vehicle to support industrial metaverse development. - Future of work: create adequate framework conditions in order to raise the job quality, to enhance inclusion while also fostering qualification offerings that enable employees to use and benefit from industrial metaverse applications. Mitigate potential risks, e.g. concerning privacy and digital identity issues or new physical strains. A constructive opportunity-oriented dialogue and support of the labor unions is required

Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

13 Apr 2023 · Sustainability

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

13 Apr 2023 · discuss the technology used on holistic energy management systems to monitor energy consumption, electric vehicle charging stations, and the use of AI technology and digitalization to optimize design, production, inventory

Meeting with Florika Fink-Hooijer (Director-General Environment)

13 Apr 2023 · Exchange of views on sustainability and green transition and Siemens commitments.

Meeting with Sabine Weyand (Director-General Trade)

30 Mar 2023 · Latest geopolitical developments, open exchange of views on other topics of relevance.

Response to Detailed procedures for addressing distortive foreign subsidies

6 Mar 2023

Suggestions for improvement March 2023 The draft Commission Implementing Regulation (IR) to Regulation (EU) 2022/2560 (FSR) contains good ideas to make the FSR workable for the Commission and less burdensome for the industry. It is positive, that the notifying parties may ask the Commission to waive the obligation to provide information that is not reasonably available or unnecessary for the assessment of the case. The envisaged pre-notification talks could serve to discuss how to best limit the information required in the notification forms. It is good that Annex 1 on concentrations (Annex 1) only requires financial contributions (FC) to be listed if they reach certain thresholds. However, with the current draft, the huge and disproportionate burden put on companies by the FSR has not been effectively limited. The introduced thresholds for reporting to the Commission mainly protect the Commission from heavy files. In contrast, the companies need to internally report on all kinds of FC, e.g., for threshold calculation or declarations required by Annex 2, section 7. In the following we summarize our main concerns and ask the Commission to significantly improve the IR and its Annexes to make the FSR regime work for both the Commission and the companies. For further details, please consult the PDF/document attached to this contribution.

Read full response

Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur) and TIC Council

1 Mar 2023 · EU Cyber Resilience Act

Meeting with Tomislav Sokol (Member of the European Parliament, Rapporteur)

8 Feb 2023 · European Health Data Space - EHDS

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and DIN Deutsches Institut für Normung e. V.

8 Feb 2023 · AI Act

Meeting with Nicola Danti (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

25 Jan 2023 · Stakeholder consultation on the CRA

Siemens calls for single EU cybersecurity law for industry

20 Jan 2023

Topic — New EU rules setting mandatory cybersecurity requirements for all connected digital products.

Message — Siemens wants the Cyber Resilience Act to replace all other overlapping cybersecurity laws to simplify compliance. They request a 36-month transition period and the right to charge for security patches.1 2 3

Why — Streamlined rules would reduce regulatory overlaps while allowing the company to monetize software maintenance.4 5

Impact — Customers and critical infrastructure operators could face new costs for vital security updates and repairs.6 7

Read full response

Meeting with Ursula von der Leyen (President) and Vodafone Belgium SA and

18 Jan 2023 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, Chairman of Vodaphone, President of IFO Institute (Topic: Competitiveness)

Meeting with Kathleen Van Brempt (Member of the European Parliament)

12 Jan 2023 · Decarbonisation of the heavy duty vehicle road sector: ERS (APA)

Meeting with Mairead McGuinness (Commissioner) and

10 Jan 2023 · Taxonomy, ESG ratings, CSRD

Meeting with Günther Sidl (Member of the European Parliament)

15 Dec 2022 · General Exchange of Views

Meeting with Nikolaj Villumsen (Member of the European Parliament, Shadow rapporteur)

30 Nov 2022 · F-gases

Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Nov 2022

We welcome the ALD (AI Liability Directive) as being a directive and not a Regulation leaving the details of the liability regime to the Member States We also welcome the proposed fault-based regime (and that the EC does not entertain previous attempts to introduce strict liability for AI). We would prefer that the ALD set this principle as a standard to avoid fragmentation among the Member States. We advise to ensure consistency with and maintain the same risk-based approach as in the AI Act and keep the liability framework harmonized only for high-risk AI systems, especially with regard to stimulating AI uptake in EU. A definition/restriction/limitation of what is proportionate and limited to what is necessary to support a claim is missing; there are no sufficient safeguards to protect intellectual property, trade secrets and confidential or personal information. It is not clear what standard the courts will apply for allowing the defendant to rebut the causality presumption. Requiring a proof of absence of causality will often be impossible given the specifics of AI (opacity, autonomy, complexity). If non-compliance with AI Act leads to damage, we recommend to better clarify the allocation of obligations among different stakeholders in the supply chain in the AI Act. It is important to avoid overlap between ALD and PLD as they both may overlap to some extend for some products, so we are lacking a clear regulatory order of precedence.

Read full response

Meeting with Ibán García Del Blanco (Member of the European Parliament, Rapporteur) and Volkswagen Aktiengesellschaft and

29 Sept 2022 · Exchange of views on the Data Act

Meeting with Andreas Schieder (Member of the European Parliament, Rapporteur) and Schneider Electric and

5 Jul 2022 · Exchange of Views on EPBD

Siemens urges switch to F-gas-free solutions for power grids

29 Jun 2022

Topic — The EU is updating rules to phase out fluorinated greenhouse gases in cooling and electrical systems.

Message — Siemens recommends a direct move to F-gas-free switchgear to ensure long-term regulatory compliance. They caution against replacing SF6 with hazardous chemicals like PFAS that could harm health. Any new alternatives should follow the same strict safety and reporting rules as current gases.1 2 3

Why — Stricter rules would boost Siemens' market share for their existing fluorinate-free product portfolio.4 5

Impact — Manufacturers using PFAS-based alternatives could see their products restricted or subject to heavy oversight.6 7

Read full response

Meeting with Reinhard Bütikofer (Member of the European Parliament)

20 Jun 2022 · Exchange of views

Response to Data Act (including the review of the Directive 96/9/EC on the legal protection of databases)

12 May 2022

The Data Act constitutes a horizontal regulation for all IoT application fields even though there appears to be no apparent evidence of market failure or information asymmetries, or only in very specific market segments. Therefore, such a broad regulatory intervention seems premature and could even create new obstacles for the desired market uptake of the European data economy in industry. Consequently, there should be no one size fits all approach with mandatory data sharing obligations for data holders. Data sharing in the B2B context should primarily be based on contractual freedom and market incentives. We noticed several critical points of concern and we would therefore favor an industry- or sector-specific approach to data regulations. Furthermore, the definitions and concepts in the Data Act require further clarification. Some key points of concern: - Additional legal uncertainties due to high regulatory density, which may inhibit rapid market uptake in industrial B2B (IoT). - Very broad and insufficiently defined understanding of data - Broad and unclear scope of data processing services - Inadequate protection of trade secrets and intellectual property - Focus on the role of the asset user vs. non-consideration of the role of the component provider - Assumption that the IoT asset provider is in fact the data holder: in many cases, this does not apply to industrial practice - Administrative burden/cost: more difficult or more expensive to place IoT devices on the market by imposing additional product requirements - Access by design as a concept seems to be too broad and vague, thereby causing unintended side effects regarding the desired goals of the EU Data Act We have laid out our key concerns and recommendations for each chapter of the Data Act. More details and recommendations to be found in uploaded document.

Read full response

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

25 Mar 2022

Siemens welcomes the work of the Commission in revising the Energy Performance of Buildings Directive (EPBD) as part of the ‘Fit for 55 Package’ and coherently connecting it with both the Renovation Wave, the Digital Decade and the Energy System Integration Strategy. The proposed recast contains numerous clarifications and new provisions, notably the introduction of Zero-Emission buildings, the setting of national building renovation plans, renovation passports, data exchange and databases for energy performance of buildings, together with a significant effort to bring more consistency in European energy & climate laws. Altogether, the proposal has potential for fostering a more energy efficient and climate friendly building stock, however the acceleration in the digital transition of the building sector should be improved. Our key recommendations are as follows: • Base the data exchange on defined international standards and a common EU building data management framework in line with the EU strategy for data. • Mandate the use of digital twins in certain new construction and deep renovation projects to facilitate integrated building design and operation • Require the use of real performance data in energy management and digital certificates, passports, reports and logbooks for simplified exchange and update. • Include relevant provisions to apply a district approach related to new and “deeply” renovated buildings aligned with the first building renovation plans timeline • Promote buildings as demand-side flexibility providers and active contributors for energy system integration and system efficiency Siemens is committed to the climate neutrality goals and expects from the policymakers to create the enabling regulatory environment for the industry to contribute to the full.

Read full response

Meeting with Ursula von der Leyen (President) and Volvo AB and

18 Mar 2022 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Response to European chips act package – Regulation

17 Mar 2022

Overall, we welcome the Chips Act proposal from the European Commission. It underlines the vital importance of semiconductor in every aspect of industry and daily life, and it shows that the current chips shortages have awakened Europe. Europe must increase its Electronic Components and Systems (ECS) supply chain resilience by ramping-up the design and manufacturing capabilities of European companies and by having American and Asian companies investing in new fabs in Europe. More focus must be put on technologies along the whole lifecycle of electronics - from design and manufacturing to end of life - aimed to make electronics (more) sustainable, as such focus will differentiate Europe and increase the resilience of the ECS supply chain for Europe. More details and recommendations to be found in uploaded document.

Read full response

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

14 Feb 2022 · e-fuels

Meeting with Ursula von der Leyen (President) and Volvo AB and

20 Jan 2022 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Caroline Nagtegaal (Member of the European Parliament, Shadow rapporteur)

7 Dec 2021 · AFIR

Meeting with Ursula von der Leyen (President) and Volvo AB and

25 Aug 2021 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Response to Revision of the Machinery Directive

4 Aug 2021

Siemens AG as a global manufacturer of machinery and electrical equipment for machinery, and at the same time operator of factories worldwide appreciates the possibility to submit comments on the proposed Regulation on Machinery Products. 1) We welcome that certain administrative requirements have been removed compared to the MD, particularly the possibility to provide the instructions and declaration of conformity in digital format. However, there is a need for more consistency in the removal of formalities which in practice have proved to be without added value: - digital format should also be allowed for other documents, including assembly instructions and declaration of incorporation; - identification of versions of documents (instructions, declarations) as ‘original’ vs. ‘translation’ should not be mandatory. 2) We welcome the introduction of ‘substantial modification’ since most machinery products are durable assets and subject to regular modifications. However, - the definition of ‘substantial modification’ in Article 3 (16) needs clarification insofar as the modification should be considered as substantial only if compliance with the relevant EHSR is (not just ‘may be’) affected; - Article 15 needs to ensure that a) the obligations of a manufacturer are placed on the economic operator who takes the responsibility for the (substantial) modification. This may be the machinery operator or the party contracting the modification, depending on the individual case. However, it should be excluded that the installer or craftsperson etc. who simply carries out the modification on behalf of the economic operator could be considered a ‘manufacturer’; b) only professionals should become ‘manufacturers’ (the current text appears to cover ‘natural persons’ irrespective of whether they are professionals or not. 3) We call for the maintenance of the Internal Production Control procedure (‘module A’) also in the case of products listed today in Annex IV of the MD. There is no compelling reason why the manufacturer should not be allowed to demonstrate compliance based on the relevant hEN, in the same way as a 3rd party body would do. There is a substantial difference between voluntary and compulsory certification. No additional burden should be imposed on manufacturers without clear evidence of the need for it, in terms of risks and accidents/numbers of non-compliance. 4) Some risks from artificial intelligence and cybersecurity are addressed in an impracticable way and may hinder innovation. Cybersecurity requirements for products should be covered in a separate horizontal legislative act rather than in sector specific harmonisation legislation limited to safety-related security aspects. - The requirements for tracing logs and security-related data recording must be limited to relevant applications. Also, the obligation to keep data logs must be restricted to the extent such logs are under the control of the manufacturer. - The requirements for protection against corruption [EHSR 1.1.9] are too extensive and do not make a clear distinction between software related cybersecurity and material safety aspects. 5) Listing of harmonised standards: It has to be ensured that the standards harmonised under the Machinery Directive and listed in the OJEU continue to provide presumption of conformity under the new Regulation, if necessary, with restrictions re. artificial intelligence. The current list of hEN needs to be transferred to the new Regulation before the expiry of the transition period. 6) Deletion of Article 50 (1) – Transition period: It cannot be the goal of a sustainable product policy to set a deadline for the further marketing of products that were placed on the market in conformity with the current MD. If at all such a deadline should be envisaged the transition period needs to be extended to min. 10 years considering the durability of assets under the Regulation. See our detailed comments in the attachment.

Read full response

Response to Standardisation Strategy

28 Jul 2021

Siemens remarks on the guiding questions identified in the EC roadmap paper. Functioning of NLF/CE hEN system Since the controversial interpretation of the “James Elliot” judgment and the subsequent modifications of the established processes, stakeholders have regretted a deterioration in the performance of the system and its processes. Many good remedial proposals have been made and should be implemented quickly to restore efficiency. For the sake of well serving the free movement of goods in the internal market. Inclusiveness and stakeholder participation The good conditions for the involvement of broad stakeholder groups are laid down in 1025/2012. Especially in the field of digitization, the problem does not lie in the broadness of the representation of interest groups, but in the lack of real experts. Standardisation projects, regardless in which SDO they are run, must offer to the experts, who are to be "Computer and IoT nerds", attractive, dynamic, and agile working conditions. The financing of such work can also promote the willingness of scarce experts to participate in standardisation. Education There are good examples in member states of integrating standardisation into vocational training, industrial education and university research and teaching. These best practice methods should be exchanged and multiplied throughout Europe. This can be another way to attract junior staff as experts in future-oriented standardization. Fit for future challenges The EU ambitious goals around “Digitisation” and the “New Green Deal” can hardly be supported by the capabilities of the existing ESS. The need to provide many standards in a short time to substantiate new regulations (ideally NLF/CE directives) in a supporting way are likely to overwhelm the current system and the actors involved. Adverse processes can be improved, but the lack of expert capacity on the part of the ESS and its stakeholders is difficult to replace. New ways, including the opening of the ESS to further sources, but also the funding of operational standardisation work through EU funds should be considered. International context The dynamics of standardization work in the People's Republic of China and its powerful influence on the international level pose challenges for the ESS. A demarcation from China or even an attempt to create a counterweight does not seem expedient and would damage the idea of multilateralism. Professional and efficient cooperation with the "standardization superpower China" as well as with the USA in the transatlantic context must remain the goal of internationally harmonious standardization work to keep global trade free and fair. This requires a strong and agile ESS, for which the existing system must be upgraded, especially in the areas of digitization. Any form of European unilateralism in contrast to China or the USA would lead to the establishment of further technical trade barriers that would ultimately harm all economies. Furthermore, a special concern of Siemens The political design areas “New Green Deal” and “Digitalization” should be considered in unity, i.e. without contradiction and viewed from a holistic perspective. It is essential to promote that "digital twins" are used to accompany products over their entire life cycle, also from the viewpoint of sustainability in the circular economy. Digital twins of raw materials, intermediate products, final goods and services, in which the characteristics of resource consumption (Eco Design) and climate friendliness (Product Carbon Footprint) will help to keep the European industry at the leading edge and guide its economy into the era of sustainability and climate neutrality. Standardization and Standards make an important contribution to this. This is precisely why the ESS must function well. And maybe partially rethought.

Read full response

Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

28 Jul 2021

Siemens welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence. For many purposes, specifically in the industrial domain, AI is a powerful technology which helps to make our lives and work easier. There is a real threat that additional horizontal regulations on strict liability for AI will prevent innovations of this technology in the EU. Innovative companies may be induced to realize and deploy new AI in markets outside of Europe. In any event, revisions of strict liability and/or a change in burden of proof should follow a risk-based approach and not apply to any AI system, but remain technology neutral. Finally, any revision of the Product Liability Directive should take into account and be in line with the final version of the AI Act where a clear responsibility split between manufacturer and operator of products will be key.

Read full response

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

23 May 2021

We appreciate the opportunity to comment on the Commission’s proposal regarding disclosure obligations in accordance with Article 8 of the taxonomy regulation. Overall, we believe that the proposed disclosure obligations are not fit for purpose to accomplish the Commission’s overall target to expedite the transition to more sustainable economic activities by ensuring reliable and comparable information for investors while refraining from putting unnecessary burdens or endangering the competitiveness of EU companies. In that respect, we particularly disagree with the proposed granularity of information to be provided. Investors must make a decision whether they invest in the company as a whole; they do not have the option to invest in parts of the company. Accordingly, the proposed granular additional information will not provide investors with substantial additional benefits, while at the same time increasing the cost of disclosure for preparers. To the contrary, the proposed granularity of disclosures, in particular those with respect to capital expenditures, will very likely require preparers to publish information that is commercially sensitive and presents valuable information for competitors. Many companies listed in the EU capital markets compete on a worldwide basis with competitors that are located and listed in jurisdictions outside the European Union that do not have comparable disclosure requirements. These proposed disclosure requirements would put companies in the European Union at a competitive disadvantage. From a conceptual point of view, the proposed granular disclosure, which will required to be presented in management reports, runs counter to several of the long-established and well-trusted principles of management reporting, most notably the principles of relevance and materiality. These disclosure requirements will contribute to disclosure overload and as mentioned above, will not provide substantially more decision-useful information to investors, the target group of the new disclosures. On a technical note, the draft delegated act uses multiple terms that so far have not been defined in the legal framework of the European Union or in other reporting standards such as IFRS, or are not currently in use in established reporting systems. This leaves substantial room for interpretation and uncertainty, thus jeopardizing the desired qualitive information characteristics of reliability and comparability. We also believe that the requirement in Article 9, Nr. 3 that requires non-financial undertakings to disclose the key performance indicators covering the previous five reporting periods to be overly burdensome. This additional information is readily available to those interested in the prior-period reports and will be easily retrievable in the new European Single Access Platform to be introduced. This requirement does also not fit into management reporting principles that typically require only one period of comparison. In addition, we believe that the requirement in Annex I, Chapter 1.2.3.4 to disclosure future objectives and targets for the KPIs and their plans to achieve them is overly burdensome and does not provide substantial additional information since non-financial undertakings already will be required to provide comprehensive disclosures about their capital expenditures. Finally, on a general note, we find it surprising that with each round of review by the European institutions and the Commission, the proposed disclosure requirements multiply. In this respect, we question whether the original legislative intention was to require such comprehensive disclosure. If so, this intention could have been reflected more strongly in the Level 1 rule, the taxonomy regulation, where it would have been subject to more scrutiny in the democratic deliberation process. In addition, we note that a response time of three weeks for such a complex, far-reaching rule is too short for a comprehensive review.

Read full response

Meeting with Ursula von der Leyen (President) and Volvo AB and

29 Mar 2021 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Volvo AB and

19 Feb 2021 · Meeting with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Axel Voss (Member of the European Parliament) and SAP

19 Jan 2021 · AI Whitepaper

Meeting with Michael Hager (Cabinet of Executive Vice-President Valdis Dombrovskis) and Robert Bosch GmbH and Bitkom e.V.

6 Jan 2021 · RRF, industry strategy, digital strategy

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

17 Dec 2020 · DSA, DMA

Meeting with Thierry Breton (Commissioner) and

16 Dec 2020 · Roundtable - Cloud Alliance

Meeting with Ursula von der Leyen (President) and Volvo AB and

6 Nov 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Ursula von der Leyen (President) and Volvo AB and

9 Oct 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans) and Shell Companies and Netherlands Organisation for Applied Scientific Research TNO

8 Oct 2020 · Keynote speech on the European Green Deal at Energy Reinvented Community Online Event

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

17 Sept 2020 · AI Civil Liability

Response to Review of EU rules on fluorinated greenhouse gases

4 Sept 2020

Siemens AG likes to address 3 topics regarding aspects of SF6 management in its feedback to (EU) No 517/2014. For further details and annotations please refer to the attachment. A. Countries that adopted a self-commitment on SF6 emissions reduction, show significantly higher reductions from 2.G.1 sector than others. We recommend implementing the content of these well-working commitments into a regulation recast. B. Reclaiming SF6 is mandatory. Although this obligation has already in place since (EC) No 842/2006, its national implementation shall be closely monitored. It shall be considered that SF6 equipment, started being installed in larger scales beginning of the mid 1980’s, is now reaching its end-of-life. MV hermetically sealed products enable a designated closed loop process w/o gas release into atmosphere. C. OEM have been working successfully to reduce SF6 emissions and to research for alternatives. Products/pilots with alternative gases are available, today serving limited applications. To cover the full range of SF6-insulated products & systems, significant development and gaining long-term operational experience is required. It also requires sufficient time achieving rated safety margins in service, ensuring a consistent performance over lifetime. An emerging market trend towards SF6 alternatives is beginning to establish itself "tenderly", however, it materializes still in selected applications/submarkets. Nevertheless, to limit the amount of circulating SF6 it is necessary to come stepwise forward with those products, following technological progress and industrialized availability. It shall be considered that variants developments for MV equipment, customer-specific portfolio extensions and industrialization for series production require much more time & effort than known from HV applications, namely typically more than 5 years. Siemens supports a regulation driving a stepwise SF6 phase-down in MV equipment, that is aligned with the technological progress and industrialized availability of a broad, market-oriented and market-accepted portfolio. This progress shall be reviewed and assessed at regular intervals. 1. Stepwise phase-down of MV SF6 (primary) equipment in HV/MV substations and large industrial applications <=24 kV starting 2022 until 2027. Stepping into SF6-free technologies is facilitated by broader availability of alternatives and the potential to “mix” specific SF6-free switchgear with existing SF6 equipment in case of replacements or extensions. 2. Stepwise phase-down of MV (secondary) SF6 equipment in MV/LV substations in urban/rural areas (e.g. RMU) <=24 kV starting 2025 until 2030. In EU, 12 kV application only cover a small niche market; a separate 12 kV regulation is not adequate. 3. Stepwise phase-down of MV SF6 equipment for >=36 kV starting 2030. Exemptions shall be considered for specific applications, installations or if homologation processes are still running. The only sustainable path is avoiding F-gases with new design principles as the technical optima, which shall be established as new mainstream and industry standard. These technologies require additional effort and material to compensate properties of F-gases, however, at the same time, provide a positive and distinct path forward; SF6-free solutions completely renouncing F-gases are possible. A clear, effective regulatory framework and a staggered market introduction should be the goal for ordinary applications of new MV SF6-free technologies from 2022 onwards. Economic concerns of manufacturers and operators must be considered for a complete, cost-intensive, complex, time-consuming overall portfolio industrialization and for its further development application by application. The world-wide leading industrial position of EU T&D OEM’s shall be considered, ensuring employment in the EU, an important aspect of EU COM’s Green Deal. Any regulatory framework must avoid jeopardizing the leading position of this industry sector in Europe

Read full response

Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen), Bjoern Seibert (Cabinet of President Ursula von der Leyen), Fernando Sampedro Marcos (Cabinet of President Ursula von der Leyen), Maria Luisa Cabral (Cabinet of President Ursula von der Leyen), Mary Veronica Tovsak Pleterski (Cabinet of President Ursula von der Leyen), Nicole Dewandre (Cabinet of President Ursula von der Leyen), Olivier Smith (Cabinet of President Ursula von der Leyen), Per Haugaard (Cabinet of President Ursula von der Leyen), Valeria Miceli (Cabinet of President Ursula von der Leyen) and

31 Jul 2020 · The State of the Union in 2020 - The Digital Transition at the core of Europe's Recovery - [Via Webex]

Meeting with Ursula von der Leyen (President) and Volvo AB and

22 Jul 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide (Topic: European Economic Recovery)

Meeting with Axel Voss (Member of the European Parliament, Rapporteur)

7 Jul 2020 · AI Civil Liability

Meeting with Ursula von der Leyen (President) and AIR LIQUIDE and

12 Jun 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide (Topic: European Economic Recovery)

Response to Strategy for smart sector integration

8 Jun 2020

Thank you very much for giving us the opportunity to provide feedback to the strategy on smart sector integration. Please find our contribution attached.

Read full response

Response to A EU hydrogen strategy

8 Jun 2020

Thank you very much for giving us the opportunity to comment on the EU hydrogen strategy. Please find our contribution attached.

Read full response

Meeting with Thierry Breton (Commissioner) and

28 May 2020 · Impacts of COVID-19 on rail industry

Meeting with Ursula von der Leyen (President) and Volvo AB and

19 May 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide (Topic: European Economic Recovery)

Meeting with Ursula von der Leyen (President) and Volvo AB and

30 Apr 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Thank you very much for giving us the opportunity to comment on the Commission’s work on drafting the delegated act creating screening criteria for the EU taxonomy. Please find our full contribution attached. In it, we argue that a successful taxonomy must build on Europe’s industrial strength and enable as many sectors and jobs as possible to transform alongside the economy towards carbon-neutrality. This requires building bridges. We also highlight that the impact of the taxonomy may reach well beyond its intended scope with potentially negative consequences on Europe’s relevance and influence in shaping future energy systems in developing and emerging countries. Specifically, we comment on the following economic activities (a) we propose criteria under which gas technologies should be considered transition and enabling activities; (b) we propose an alternative approach to green hydrogen production with electricity taken from the grid; (c) we argue for the inclusion of CCU and electric fuels; and (d) propose adjustments related to the gas infrastructure and recommend the inclusion of dedicated hydrogen infrastructure.

Read full response

Meeting with Ursula von der Leyen (President) and Volvo AB and

17 Apr 2020 · Videoconference with Chairman of Volvo, Chairman of Siemens and Maersk, CEO of Air Liquide

Response to Union inventory system, global warming potentials and internationally agreed guidelines to be used in reporting

2 Apr 2020

Thank you very much for giving us the opportunity to provide feedback. Please find our contribution to the consultation in the attached .pdf document.

Read full response

Meeting with Ursula von der Leyen (President) and

25 Mar 2020 · Videoconference with CEOs on COVID-19

Response to Evaluation of the Electromagnetic Compatibility Directive

21 Feb 2020

In Siemens' view, the EMC Directive 2014/30/EU, which has been mandatory since April 20, 2016, fully fulfills its regulatory purpose. Equipment (an apparatus or fixed installation) that is made available on the market or put into service in accordance with the technical and non-technical (formal) requirements of the Directive limit the emissions sufficiently for the environmental class provided by the manufacturer and have a sufficient level of immunity to interference. The phenomenon-related EMC Directive should remain clearly delimited from e.g. safety-related Directives (or others) to avoid any inconsistencies and implementation problems for economic operators and market surveillance authorities. The coverage of products that do not themselves have EMC potential is not meaningful (e.g. cables). Siemens currently sees no need to revise the EMC Directive. Elements to further clarify and facilitate the application of the Directive (such as 5G, ...), especially for SME, should be included in the EMC Guide, if necessary.

Read full response

Meeting with Mariya Gabriel (Commissioner)

10 Dec 2019 · Innovation

Response to European Partnership on High Performance Computing

27 Aug 2019

Via its Board role in BDVA, Siemens AG is member of the EuroHPC advisory committee. Considering the increasing digital transformation of industry and society, intertwined with the use and processing of huge amount of all kinds of data and with the use of AI and robotics in a cybersecure industrial environment, we fully support the continuation of the EuroHPC JU under the next MFF. A world-class exascale and post-exascale supercomputing infrastructure, European processor development supporting e.g. AI on edge devices and innovation ecosystem in the EU, is an absolute necessity when Europe wants to keep or increase its global industrial competitiveness.

Read full response

Meeting with Jolana Mungengova (Cabinet of Vice-President Cecilia Malmström)

12 Jun 2019 · EU Economic Diplomacy

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

9 Apr 2019 · AI PPP

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip) and Alstom

31 Jan 2019 · Siemens Alstom merger

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

31 Jan 2019 · Industry 4.0

Meeting with Mauro Raffaele Petriccione (Director-General Climate Action)

29 Jan 2019 · Exchange views on how European industry can contribute to emission abatement

Meeting with Miguel Arias Cañete (Commissioner)

23 Jan 2019 · Long-term strategy and electricity market

Meeting with Bernd Biervert (Cabinet of Vice-President Maroš Šefčovič)

5 Dec 2018 · State of play European Battery Alliance, Clean Energy Package

Meeting with Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis) and ArcelorMittal and

22 Nov 2018 · taxonomy and EU IFRS

Response to Ecodesign requirements for (other) electric motors

20 Nov 2018

Siemens Germany likes to add some comments to the draft of the Regulation. Please the attached file

Read full response

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström) and WindEurope and Vestas Wind Systems A/S

16 Nov 2018 · safeguard investigation on steel products

Meeting with Kilian Gross (Cabinet of Vice-President Günther Oettinger)

16 Nov 2018 · Industriel Policy

Meeting with Maximilian Strotmann (Cabinet of Vice-President Andrus Ansip)

26 Oct 2018 · Intelligent mobility, C-ITS roll-out via delegated act

Response to Multiannual Financial Framework: Specific Programme implementing the 9th Framework Programme for Research and Innovation

19 Jul 2018

Find attached our actual Siemens Feedback as first reaction to the published Horizon Europe proposal dated 7/06/2018 (Siemens-Feedback_COM_Proposal_2018_07_19).

Read full response

Meeting with Mariya Gabriel (Commissioner)

25 Jun 2018 · eHealth

Meeting with Michel Barnier (Head of Task Force Task Force for Relations with the United Kingdom)

23 Apr 2018 · Meeting with the Task Force for the Preparation and Conduct of the Negotiations with the United Kingdom under Article 50 TEU

Response to Proposal to create a cybersecurity competence network with a European Cybersecurity Research and Competence Centre

17 Apr 2018

In general, Siemens favors Option 1. Argumentation: Option 0 – Baseline scenario (status quo) • Even though the continuation with known instruments (ECSO) appears to be positive, Siemens however observes in ESCO a mismatch between the set-up and the industry representation. ECSO does not address the gaps listed and is therefore not our favorite choice. Option 1 – Joint Undertaking (JU) based on Art. 187 of the Treaty on the Functioning of the EU • Siemens favors this option 1 since it presents an approach to improve the current situation by developing ECSO further. Similar to what the NIS Directive has targeted in the first place, it provides the opportunity to talk to different Competence Centers and it has the potential to represent a more balanced stakeholder view. • In particular, Siemens welcomes that the budget is fully earmarked (what is a property of a JU); a JU also provides a greater thematic visibility and allows more ownership for the industry partners. • However, we advise to take the following recommendations into consideration: o Given the industry’s key role for innovations, industry should be adequately represented and involved when the content of research & innovation programs (like e.g. the strategic research agenda) is defined. o The JU should not treat cybersecurity similarly for all industry domains and sectors but should distinct between application areas and levels of criticality. o The respective EU Commission responsibilities for regulations in specific sectors and industry domains should remain as they are (e.g. DG ENER will still be in charge for cybersecurity in the energy sector) but a cross DG coordination and synchronization to avoid silo-thinking is highly advisable. o Cybersecurity shall be anchored at the highest level in the EU Commission and this responsibility must go cross-DG o Option 0 should be continued until Option 1 is in place. • From a governance viewpoint, this option makes it likely that industry partners are embedded deeper in the decision making process than in a cPPP. Nevertheless, we advise to avoid creating more administrative efforts than necessary. Option 2 – a Centre based on Art. 173 of the Treaty on the Functioning of the EU and Art. 58 and 208 of Regulation 966/2012 (Financial Regulation) • Siemens rejects this option, because linking R&D activities with defense contradicts our position to exclude military research from the EU R&D&I framework actions and might bear the risk to have security implementation regulated while violating the technology neutrality. • Further, R&D in technologies and products developed for Defense markets are subject to strict export control rules. For this reason, innovation would be hindered. In addition, the defense industry’s influence on our markets in general, and on the EU civil security architecture in particular would increase. • From a governance viewpoint, the notion of “Centre” refers to the example of the European Institute of Technology (EIT) which was created on this very, somewhat vague, legal basis. This does –in our view- not appear to be the fastest and leanest approach in the ever-changing and ever-challenging field of cybersecurity. If chosen nonetheless, we would strongly recommend a new set-up that is very different from EIT’s (e.g. by drawing on pre-existing national associations and the like). This would avoid the time-consuming and high-maintenance creation of multi-layered (European and regional) “Knowledge and Innovation Communities”. We attach our Charter-of-Trust what better explains our position regarding cyber security.

Read full response

Meeting with Mariya Gabriel (Commissioner)

12 Apr 2018 · Women in Digital

Meeting with Günther Oettinger (Commissioner)

20 Mar 2018 · Healthineers

Meeting with Vytenis Andriukaitis (Commissioner)

24 Jan 2018 · Medical devices, eHealth, HTA, ERNs

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska) and Alstom

8 Dec 2017 · future of European railway industry

Meeting with Vivian Loonela (Cabinet of Vice-President Andrus Ansip) and Microsoft Corporation and

7 Dec 2017 · Cybersecurity package

Response to Evaluation of the Low Voltage Directive 2014/35/EU

24 Nov 2017

On behalf of Siemens AG, we would herewith like to submit our comments on the proposed evaluation of the Low Voltage Directive as follows: - In the opinion of Siemens, the LVD - still - fully satisfies its regulatory objectives, in particular ensuring a high level of safety as well as the effective functioning of the internal market for the products covered. - Electrical equipment that is placed on the market in conformity with the provisions of the Directive ensures that persons, domestic animals and property are adequately protected against hazards that might be caused by such equipment, no matter the hazard. We see no evidence that a significant number of safety incidents were caused by products that were found to be in conformity with the Directive. The RAPEX system in particular shows that there are virtually no problems concerning industrial (B2B) products. RAPEX entries also indicate that products are considered to be unsafe because they are not in conformity with the safety objectives of the Directive (and/or harmonized standards), which we interpret as a clear sign that the provisions of the Directive are sufficient. - In particular, the conformity assessment procedure (internal production control) foreseen by the Directive is still effective and adequate. We see no evidence for the need to introduce other conformity assessment procedures that require the compulsory involvement of a Notified Body. - The safety objectives of the Directive are formulated in a general way and are independent of future technology developments. Therefore, there is no need to modify or amend the general safety objectives in view of new, evolving technologies (e.g. digitalization). - We continue to consider the concept of the „New Approach“ as a success story of the European technical regulation, proven and tested to support the interests of all actors concerned, including end users (industrial/consumer) and manufacturers. By and large, European standardisation has shown that it is capable of supporting the safety objectives of the LVD in an appropriate and effective manner. Also, the Directive has already been successfully aligned with the provisions of the NLF.

Read full response

Meeting with Alina-Stefania Ujupan (Cabinet of Commissioner Mariya Gabriel)

10 Nov 2017 · Merger between Alstom and Siemens Mobility and Impact on digitalization

Meeting with Günther Oettinger (Commissioner)

23 Mar 2017 · stand visit

Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska) and Volkswagen Aktiengesellschaft and

22 Mar 2017 · trade barriers between EU and Russian federation

Meeting with Günther Oettinger (Commissioner)

18 Oct 2016 · Digitisation of industry

Meeting with Andrus Ansip (Vice-President) and

18 Oct 2016 · Data economy

Meeting with Nils Behrndt (Cabinet of Vice-President Neven Mimica)

21 Sept 2016 · Healthcare in development cooperation and European External Investment Plan

Meeting with Günther Oettinger (Commissioner) and Orgalim – Europe's Technology Industries and

15 Sept 2016 · digitising european industry

Meeting with Henrik Hololei (Director-General Mobility and Transport)

5 Sept 2016 · Low-emission mobility, Electric Road Systems, Shift2Rail

Meeting with Kilian Gross (Digital Economy) and DIGITALEUROPE and Bitkom e.V.

28 Jul 2016 · trade policy

Meeting with Michael Hager (Digital Economy)

19 Jul 2016 · DSM

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

14 Jun 2016 · European Digital Strategy; “Smart strategy for smart industry” initiative

Meeting with Juhan Lepassaar (Cabinet of Vice-President Andrus Ansip), Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip)

14 Jun 2016 · Progress of DSM and role of industrial sector

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

14 Jun 2016 · European Digital Strategy

Meeting with Johannes Laitenberger (Director-General Competition)

8 Jun 2016 · To review competition trends

Meeting with Nils Behrndt (Cabinet of Vice-President Neven Mimica)

22 Apr 2016 · Private sector investments in developing countries

Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action)

15 Mar 2016 · Industrie 4.0

Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Mar 2016 · Digitalisation of transport systems

Meeting with Nils Behrndt (Cabinet of Vice-President Neven Mimica)

19 Feb 2016 · Role of private investors in development cooperation

Meeting with Jos Delbeke (Director-General Climate Action)

15 Feb 2016 · Low carbon technologies

Meeting with Roberto Viola (Director-General Communications Networks, Content and Technology)

4 Feb 2016 · DSM, Siemens prospective

Meeting with Dominique Ristori (Director-General Energy)

22 Jan 2016 · Energy market design

Meeting with Renate Nikolay (Cabinet of Commissioner Věra Jourová)

16 Dec 2015 · Data protection issues

Meeting with Michael Hager (Digital Economy)

27 Nov 2015 · introductory meeting

Meeting with Daniel Calleja Crespo (Director-General Environment)

13 Oct 2015 · Circular Economy

Meeting with Dominique Ristori (Director-General Energy)

13 May 2015 · Energy Union

Meeting with Maria Asenius (Cabinet of Vice-President Cecilia Malmström), Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

7 May 2015 · Anti-dumping duties GOES

Meeting with Robert-Jan Smits (Director-General Research and Innovation)

6 May 2015 · Interview - Pictures of the Future - Research and Development 2030

Meeting with Daniel Calleja Crespo (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

21 Apr 2015 · Industrial Strategy - Internal Market

Meeting with Günther Oettinger (Commissioner)

4 Mar 2015 · Industrie 4.0; DSM