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Technology Industries of Finland (Teknologiateollisuus ry)

TIF

Technology Industries of Finland represents 1800 Finnish technology companies in electronics, mechanical engineering, metals, IT and consulting engineering.

Lobbying Activity

Meeting with Pekka Toveri (Member of the European Parliament)

15 Jan 2026 · Current Topics in EU

Meeting with Eero Heinäluoma (Member of the European Parliament)

15 Jan 2026 · Kriittiset teknologiat: Sirut ja kvantti

Meeting with Elsi Katainen (Member of the European Parliament)

10 Dec 2025 · Digitalisation, artificial intelligence and algorithmic management in the workplace - Legislative initiative procedure

Meeting with Arba Kokalari (Member of the European Parliament) and DIGITALEUROPE and Workday

4 Dec 2025 · Employment policy

Finnish tech industry urges light-touch EU Quantum Act regulation

1 Dec 2025
Topic — A legislative initiative to accelerate quantum technology research and industrialization in Europe.
Message — The organization requests a light regulatory framework and funding based on industrial excellence. They want the EU to prioritize quantum computing while avoiding rules that constrain experimentation.123
Why — Shifting to excellence-based funding ensures established industry leaders capture a larger share of resources.45
Impact — Countries with emerging tech sectors lose funding opportunities as geographic balance is discarded.6
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Meeting with Aura Salla (Member of the European Parliament)

20 Nov 2025 · Horizon Europe, MFF

Meeting with Pekka Toveri (Member of the European Parliament) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

17 Nov 2025 · Current Topics in EU

Meeting with Gelu Calacean (Cabinet of President Ursula von der Leyen)

12 Nov 2025 · Artificial Intelligence in the world of work

Finnish tech industry demands multi-billion euro EU semiconductor fund

27 Oct 2025
Topic — Second EU Chips Act to strengthen Europe's semiconductor ecosystem and competitiveness.
Message — The federation requests a dedicated semiconductor budget within the European Competitiveness Fund, prioritising chip design, MEMS sensors, photonics and quantum chips. They want funding based on excellence, expanded First-of-a-Kind facilities, and industry-led alliances connecting chip providers with end users. They also seek streamlined IPCEI procedures and a specialised EU Tech Talent Visa.123456
Why — This would triple their R&D investment leverage and secure anchor customers for Finnish chip technologies.789
Impact — Non-European semiconductor equipment and materials suppliers lose market access as EU prioritises domestic producers.1011
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Meeting with Eero Heinäluoma (Member of the European Parliament)

15 Oct 2025 · AI at workplace

Finnish Tech Industry Demands Digital Regulation Overhaul and Compliance Delays

13 Oct 2025
Topic — EU initiative to streamline digital policy through regulatory simplification and fitness check.
Message — The organization requests the Commission withdraw unnecessary digital initiatives and focus on targeted amendments to the AI Act, Data Act and GDPR. They want legislation designed in machine-readable formats with automated reporting, stronger EU enforcement coordination, and a dedicated RegTech program. They propose merging AI Act annexes, delaying high-risk requirements until standards are available, and permitting lawful data re-use for AI testing.1234
Why — This would reduce compliance costs and give them more time to adapt to new AI and data requirements.5678
Impact — Data subjects and consumer groups lose stronger protections as delayed AI requirements and relaxed GDPR rules reduce privacy safeguards.91011
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Meeting with Isabella Lövin (Member of the European Parliament) and Fortum Oyj and

1 Oct 2025 · CBAM, competitiveness, net-zero products etc

Meeting with Eero Heinäluoma (Member of the European Parliament)

30 Sept 2025 · Digital Omnibus, AI and other topical discussions

Meeting with Katri Kulmuni (Member of the European Parliament)

25 Sept 2025 · Yleiset EU-asiat

Meeting with Katri Kulmuni (Member of the European Parliament)

19 Sept 2025 · Puheenvuoro Clean Indurstial Dealista & ajankohtaisista EU-asioista

Meeting with Dóra Dávid (Member of the European Parliament)

17 Sept 2025 · Digital simplification, AI Act implementation

Technology Industries of Finland Urges Harmonization of Fragmented Digital Rules

11 Jul 2025
Topic — The European Data Union Strategy aims to streamline data rules and improve infrastructure.
Message — The organization calls for streamlining existing regulations like the GDPR, Data Act, and AI Act to eliminate overlaps. They recommend withdrawing low-impact proposals, making targeted amendments to current laws, and promoting a trust-based framework for SMEs.123
Why — This would reduce their administrative burden and provide legal certainty for business transactions.45
Impact — Large platforms may lose influence as regulators shift focus toward platform-based data governance realities.6
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Meeting with Stéphane Séjourné (Executive Vice-President) and

30 Jun 2025 · Roundtable discussion

Finnish Industry Urges Faster Energy Permits for Data Centres

19 Jun 2025
Topic — The consultation aims to triple the EU's cloud and AI processing capacity.
Message — TIF advocates for prioritizing energy access and streamlining permits for new infrastructure. They urge the EU to focus on AI over traditional cloud computing.12
Why — Finnish firms benefit from rules favoring energy-efficient locations with cold climates.3
Impact — Traditional cloud providers lose priority as investments shift toward specialized AI hardware.4
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Response to Digital services for simplifying business operations and reducing administrative costs – the business wallet

12 Jun 2025

Technology Industries of Finland (TIF) is an industry association that promotes the competitiveness and business environment of Finland's most important export sector. TIF represents 1,800 member companies. The forthcoming EU Business Wallet will create real value only if it primarily supports business-to-business (B2B) interactions rather than being limited to business-to-government (B2G) compliance. Since most transactions occur between companies, a wallet restricted to public-sector use would likely see low uptake and limited impact. Regarding a study done in Finland, the most relevant business wallet use cases for the companies are: 1. Identifying a business customer/partner 2. Identification as a company 3. Check your partner's trustworthiness 4. Authenticated signing of contracts 5. Permits and certificates for your own company To boost the adoption of the business wallets, we recommend: - Focus regulation on verifiable credentials, not on wallet implementation - Secure public-sector participation through clear mandates - Designate competent authorities as trust anchors for issuer legitimacy - Preserve flexibility to foster market-driven innovation - Leverage existing eIDAS provisions and avoid redundant technical mandates
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Technology Industries of Finland urges simplified EU AI rules

3 Jun 2025
Topic — This initiative aims to accelerate industrial AI adoption and improve public services across Europe.
Message — The association recommends empowering company-led AI networks and fostering industry-specific AI verticals. They urge simplifying the European regulatory framework and ensuring that all new legislation is born digital for automated compliance.12
Why — The organization would benefit from significantly lower compliance costs and reduced administrative burdens across the single market.3
Impact — Market surveillance authorities lose oversight capabilities if they are denied the power to inspect proprietary source code.4
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Meeting with Ville Niinistö (Member of the European Parliament)

20 May 2025 · EU affairs

Meeting with Jussi Saramo (Member of the European Parliament)

24 Apr 2025 · Verotus ja komission työohjelma

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

11 Apr 2025 · Teknologiateollisuuden ajankohtaiset asiat

Meeting with Anniina Iskanius (Cabinet of Executive Vice-President Henna Virkkunen), Silke Dalton (Cabinet of Executive Vice-President Henna Virkkunen)

9 Apr 2025 · Exchange of views, Commission priorities, Industrial policy, simplification

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

9 Apr 2025 · Research and innovation partnerships

Meeting with Lara Wolters (Member of the European Parliament, Shadow rapporteur) and Nokia

27 Mar 2025 · Omnibus

Meeting with Hildegard Bentele (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V.

20 Mar 2025 · Water policy

Meeting with Henna Virkkunen (Executive Vice-President)

19 Mar 2025 · Advancing AI and Data Strategies in Europe: Legislation, Innovation, and Economic Growth

Meeting with Aura Salla (Member of the European Parliament)

19 Mar 2025 · Circular economy and R&D, priorities for European research and sustainability policies

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Nokia

11 Mar 2025 · Omnibus

Meeting with Katri Kulmuni (Member of the European Parliament)

10 Mar 2025 · CID

Meeting with Li Andersson (Member of the European Parliament, Committee chair)

10 Mar 2025 · Technolocy policy

Meeting with Aura Salla (Member of the European Parliament)

6 Mar 2025 · EU Policy

Meeting with Eero Heinäluoma (Member of the European Parliament)

5 Mar 2025 · Semiconductor industry

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

21 Feb 2025 · Meeting minutes - Water Resilience Strategy and Circular Economy Act

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

20 Feb 2025 · Advancing AI Adoption and Industry Growth Through Regulatory Simplification, Data Center Development, and EU Collaboration

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

19 Feb 2025 · The state of the new European Commission's policy agenda for the green transition and the promotion of the EU circular economy

Meeting with Katri Kulmuni (Member of the European Parliament)

17 Feb 2025 · Clean Industrial Deal ja Omnibus

Meeting with Agnieszka Skonieczna (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

11 Feb 2025 · Exchange on the Finnish best practice in R&I, presentation of the Locomotive Model, a successful example of a new innovation model aligning the industrial policy with the research and innovation.

Meeting with Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen), Fausto Matos (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

11 Feb 2025 · AI Continent

Meeting with Kirsi Haavisto (Head of Unit Research and Innovation)

10 Feb 2025 · Finnish Best Practice in RDI

Meeting with Caroline Vandierendonck (Head of Unit Budget)

10 Feb 2025 · Launch of a new type of challenge competitions in the area of applied research How to boost innovation with a stronger bridge between applied research and companies in the EU

Meeting with Benjamin Angel (Director Taxation and Customs Union)

7 Feb 2025 · BEFIT, TP, HOT, FASTER, Pillar 2 .

Meeting with Markus Ferber (Member of the European Parliament)

6 Feb 2025 · EPP priorities on EU tax policy

Meeting with Terhi Lehtonen (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

6 Feb 2025 · Green and sustainable transition.

Technology Industries of Finland calls for Single Market regulatory simplification

31 Jan 2025
Topic — The European Commission is seeking to enhance the single market for services and goods.
Message — The association advocates for a risk-based approach to data processing and harmonized cybersecurity standards. They request the standardization of carbon handprint metrics and the digitalization of taxation across the EU. The group seeks to eliminate burdensome national tax concepts that hinder worker mobility.123
Why — Harmonized digital and tax rules would reduce high compliance costs and administrative burdens.4
Impact — Companies in countries with large state aid budgets would lose their competitive advantage.5
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Meeting with Maria Guzenina (Member of the European Parliament)

11 Dec 2024 · Current affairs

Meeting with Pekka Toveri (Member of the European Parliament)

11 Dec 2024 · EU defence market

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Technology Industries of Finland appreciates the opportunity to provide early feedback on the upcoming delegated regulation that defines the requirements for digital product passport (DPP) service providers. Recommendations for the upcoming delegated regulation defining requirements for Digital Product Passport service providers: 1. Recommendations for contractual freedom:According to ESPR, economic operators can decide whether to store the DPP in their own systems or use third-party services. Therefore, we emphasize that contractual freedom should be the basis of the B2B relationship, and the use of third-party services should be the free choice of the economic operator. Flexibility would also make it easier for the two parties to agree on optional digital services built on top of the minimum DPP requirements or on contractual agreements for the use and re-sharing of DPP data. Not all economic operators, especially many SMEs, have the resources to create, verify, process, store, and maintain all DPPs in their own systems. In these cases, the use of third-party DPP service providers is necessary. The DPP service provider must ensure a level of service that allows the responsible economic operator to meet all ESPR requirements for the DPP and DPP data. 2. Security of DPPs:DPP service providers must ensure the security of DPPs, in particular, the security of restricted information. The backup data of DPP should only be available to authorities in cases of liquidation, insolvency, or cessation of operations to prevent data leakage and breaches of data access principles. Additionally, DPP services are expected to provide the cybersecurity level mandated by applicable cybersecurity laws and comply with relevant platform standards. 3. Technological Neutrality and Certification:Requirements must be technologically neutral, and any certification systems should be voluntary. DPP services can be provided in various ways, and new methods may emerge in the future as companies innovate. The delegated regulation should not unnecessarily exclude certain technological options from the market, as responsible operators must be able to choose the technological offerings that best suit their situation and systems. Certification systems should be voluntary if needed. Instead of certification, the first option to secure trustworthiness of data, should be built on basis of metadata and distributed digital trust solutions. However, the principles and structure of the DPP could be defined in the CSRD report of service provider in accordance with the sustainability reporting directive. This would ensure public accountability for the quality of the DPP, transparently and responsibly, without an overly bureaucratic or burdensome process for companies. The sustainability report's assessment of the DPP structure would strengthen companies' responsibility to ensure that the ESPR requirements for the DPP are genuinely met and that end-user information is provided of high quality. 4. Legal Framework for DPP Services:The legal framework for providing DPP services must be the same in all EU member states to ensure legal certainty and equal operating conditions in the internal market.
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Meeting with Aura Salla (Member of the European Parliament)

10 Dec 2024 · Digital fairness act

Meeting with Andrea Wechsler (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

4 Dec 2024 · EU Energy and Industry Policy

Meeting with Sebastian Tynkkynen (Member of the European Parliament) and Confederation of Finnish Industries EK and

3 Dec 2024 · Ajankohtaiset aiheet

Meeting with Maria Ohisalo (Member of the European Parliament)

2 Dec 2024 · AI at workplace

Meeting with Mika Aaltola (Member of the European Parliament) and Suomalaiset kehitysjärjestöt Fingo ry

25 Oct 2024 · EU Affairs

Meeting with Mika Aaltola (Member of the European Parliament)

17 Oct 2024 · Quantum Technology

Meeting with Sebastian Tynkkynen (Member of the European Parliament)

17 Oct 2024 · Keskustelu kvanttiteknologiasta

Meeting with Miriam Lexmann (Member of the European Parliament)

2 Oct 2024 · AI in the workplace

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

25 Sept 2024 · to discuss the reflections from the Commission´s current term in light of the next Commission, including among others as topics the main themes in the current term and the EU´s digital development.

Meeting with Aura Salla (Member of the European Parliament)

24 Sept 2024 · Research and innovation

Meeting with Aura Salla (Member of the European Parliament)

18 Sept 2024 · Introductory meeting, EU competitiveness

Meeting with Eero Heinäluoma (Member of the European Parliament) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

17 Jul 2024 · Ajankohtaisaiheet

Meeting with Anna-Maja Henriksson (Member of the European Parliament) and Teknikföretagen

15 Jul 2024 · Upcoming mandate and Nordic research & innovation policy

Meeting with Emma Wiesner (Member of the European Parliament) and Teknikföretagen

15 Jul 2024 · Europeisk industripolitik med finska och svenska MEPs och företag

Meeting with Alviina Alametsä (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

26 Jun 2024 · Exchange of views

Meeting with Elsi Katainen (Member of the European Parliament)

24 Jun 2024 · Next EU mandate and priorities

Response to Options for support for R&D of dual-use technologies

30 Apr 2024

In turbulent times, the European business environment needs to focus on safeguarding its critical know-how. Technology Industries of Finland (TIF) advocates for a market-driven approach to de- risk industrial value chains. Excessive governmental intervention should be minimized, focusing instead on fostering conditions conducive to technological leadership and long-term global competitiveness. When taking cautious measures, the EU must provide compensating measures and make sure that critical technologies may grow in additive ways. Our key messages are: Promoting Economic Security Boost EU RDI funding, especially in critical technological areas, to ensure economic competitiveness and resilience. Do not divert resources away from competitive sectors of European industry. Bolster digital transformation by investing in critical technological infrastructure. Partnering for Economic Security Forge strategic global partnerships and actively pursue new free trade agreements. Lead in setting international norms and standards that favour innovation, fair competition, and European values. Research and innovation create a more secure Europe: EU funding for RDI and security must follow the criteria of excellence and expected impact. Throughout the business environment, the EU needs to make funding more attractive for cross-border partnerships. We should increase industry-driven projects in Framework Programme 10. Programmes such as the Digital Europe Programme (DEP) should be developed into more strategic direction. On the other hand, underperforming funding schemes need to be deprioritized. The Commission should analyse their performance and introduce adjustments. On critical technologies, vertical approach on funding can be used, also covering manufacturing phase but always under criteria of excellence and impact, to secure European excellence and competitiveness. Investments in leading-edge technologies and critical digital infrastructure The EU should emphasize investments into groundbreaking foundational technologies. One area we would like focus is quantum computing, but also advanced communication networks are ripe for wide scaling, presenting an opportunity for the EU to lead these innovative fields. To remain frontrunners, EU companies need further funding, comparable to those of competing economies. There's a pressing need to invest in the modernisation and expansion of critical digital infrastructure. This includes enhancing mobile networks and submarine cables, which are essential for catering to the growing European demands and aiding in a seamless green and digital transition. The Arctic region's unique advantages its cool climate, clean energy sources, and efficient resources could greatly benefit data centers and the development of a robust technological infrastructure. One of Europes HPC computers, Lumi in Kajaani, Finland, should be utilised to build strong company network around it. The Arctic region is also the powerhouse of wireless communications technologies such as 6G. The development of EU-wide capabilities in generative AI and Large Language Models (LLMs), particularly for underrepresented language groups, is a strategic imperative. Such advancements are key not only to boosting the reliability and trustworthiness of AI systems but also to attracting a diverse, skilled workforce. With the options presented, we would prefer option 2 as the primary option and option 3 as the secondary.
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Response to White Paper on Dual-Use Export Controls

30 Apr 2024

The European business environment needs to focus on safeguarding its critical know-how. Technology Industries of Finland (TIF) advocates for a market-driven approach to de-risk industrial value chains. Excessive governmental intervention should be minimized, focusing instead on fostering conditions conducive to technological leadership and long-term global competitiveness. When taking cautious measures in export control, the EU must provide compensating measures and make sure that critical technologies may grow in additive ways. In promoting Economic Security, we must boost EU RDI funding, especially in critical technological areas, to ensure economic competitiveness and resilience. With the urgence of enforcing European strategic autonomy the EU cannot divert resources away from competitive sectors of European industry, but rather bolster digital transformation by investing in critical technological infrastructure. In protecting Economic Security, we must implement balanced protective trade and investment measures to shield against economic vulnerabilities and security threats after careful joint assessments with industry. In partnering for Economic Security, EU should forge strategic global partnerships and actively pursue new free trade agreements. It is in line with the horizontal views of European strategic autonomy that we aim at leading in setting international norms and standards that favor innovation, fair competition, and European values. TIF is wary of revising the dual-use export control regime soon after its recent update. Such changes could increase regulatory burdens, create uncertainty, and disrupt value networks. We suggest that any future revisions or harmonization in national export control regimes be based on evidence and only after an extensive evaluation period of the current framework. From regulatory alignment and safety framework perspective we also highlight reassessing export control regulations to optimal level for European needs and introducing a product safety sandbox. It is important to also highlight the active restructuring of EU funding (FP10). It is crucial to have elements for critical technologies, as well as, directly to SMEs. We wish to emphasize public-private risk assessment to support innovation. Additionally, the EU should utilize different platforms to collaborate with like-minded partners and industry stakeholders on this matter. One of the strategically important coordination frameworks is the EU-US Trade and Technology Council. Moreover, there is a significant risk that export control implemented by different countries and regions, each aiming for similar objectives through varying approaches, will complicate and increase the resource demands for global industries to adhere to this control compared to a scenario with nearly uniform regulation. As the complexity of export control compliance grows, Member States and the European Commission should look into wide collaboration with industries in easing or eliminating some existing controls, where feasible. Maintaining controls on technologies that have become universally accessible would be inefficient, and such technologies ought to be periodically reviewed. Enhanced international collaboration, achieved through coordinated control measures, licensing policies, enforcement, and interoperability all building on established principles within the EU export control system would be advantageous.
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Meeting with Ville Niinistö (Member of the European Parliament)

17 Apr 2024 · EU affairs, Industry

Meeting with Pirkko Ruohonen-Lerner (Member of the European Parliament)

13 Feb 2024 · EU:n strateginen kilpailukyky

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

13 Feb 2024 · Industry priorities for the upcoming European elections

Meeting with Daniel Mes (Cabinet of Commissioner Wopke Hoekstra)

30 Jan 2024 · green industrial policy

Response to Business in Europe: Framework for Income Taxation (BEFIT)

24 Jan 2024

Please find attached the Technology Industries of Finlands submission to the public consultation: Business in Europe: Framework for Income Taxation (BEFIT)
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

3 Jan 2024

Please find attached Technology Industries of Finland's submission to the public consultation: Proposal for a Council Directive on Transfer Pricing.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

21 Dec 2023

Technology Industries of Finlands submission to the public consultation: Proposal for a Council Directive establishing a Head Office Tax System for micro, small and medium sized enterprises (HOT) The European Commission (EC) has requested comments regarding the so called HOT-directive proposal. According to the European Commission the purpose of the proposal is to make it easier for SMEs to do business in the EUs internal market and ease the heavy tax administrative burden and reduce SMEs compliance costs. This could also boost the competitiveness of the EUs single market and lift barriers to cross-border operations, as well as decrease the risk of double taxation and costly disputes. The goal is to ease the administrative burden of SMEs by creating a system where a SME can continue to comply with the tax legislation of their home country and deal only with the tax authorities of the country where their head office is located, also concerning permanent establishments located in another EU Member State. A one-stop shop will enable in-scope SMEs to interact only with the tax administration of the Member State of their head office both for filing obligations and paying taxes. Technology Industries of Finland (TIF) welcomes the opportunity to comment the HOT initiative. We agree with the Commission that tax compliance is too burdensome and complex at the moment. Thus, we welcome the idea to ease up the administrative burden of business, especially of the SMEs. TIF supports the principal idea of the proposal. It has potential to lighten the administrative burden of SMEs. When introducing new administrative models, it should be thoroughly analysed, whether the administrative burden will factually turn less burdensome, not just generate an extra layer of compliance. Thus, Teknologiateollisuus ry supports that the model is optional for the companies. Even though the majority of TIFs member companies are SMEs, there are very few that operate in a permanent establishment structure. Therefore, it seems that the significance of the model would be low. TIF suggests that the HOT-model would be extended to also apply to SMEs operating in a subsidiary structure. The model would only apply to corporate income taxation, and the SMEs would still have to obey the tax obligations of e.g. value added taxation. HOT should be so attractive that companies will prefer joining it rather than staying outside of the system. To increase the attractiveness of HOT, TIF proposes that the model would be gradually extended to cover all tax obligations of the SMEs. On a country level the HOT-proposal is more problematic, also affecting the companies. The tax base and tax rate would be defined in separate countries, which would limit the possibility for Member States to regulate their own corporate income tax system. Taxation provides means for Member States to finance the most important functions, e.g. education, defense, health care. Decision making regarding EU taxation must require unanimity also in the future. Technology Industries of Finland EU Transparency Register number: 39705603497-38 more information: Maria Volanen, Head of Taxation Policy, maria.volanen@teknologiateollisuus.fi Technology Industries of Finland (TIF) represents Finnish technology industries and has over 1,800 member companies, sizes varying from small SMEs and start-ups to world leading MNEs. The technology industry is comprised of five sub-sectors: electronics and the electrotechnical industry, mechanical engineering, metals industry, consulting engineering and information technology. Technology industry is the most important export industry in Finland, with operations constituting over 50 % of all Finnish exports and responsible for 65 % of all private investments in R&D carried out in Finland. Over 350,000 Finns work in technology companies, while a total of around 700,000 people work in the technology sector directly or indirectly (of a t
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Meeting with Elsi Katainen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

13 Dec 2023 · Current political agenda

Meeting with Nils Torvalds (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

12 Dec 2023 · Finnish export industries

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

5 Dec 2023 · Relevant current legislation

Meeting with Timo Pesonen (Director-General Defence Industry and Space)

19 Oct 2023 · Meeting to discuss ways and means to enter defence industry value chains

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

12 Oct 2023 · AI ecosystems

Meeting with Henna Virkkunen (Member of the European Parliament)

19 Sept 2023 · EU Tech Policy

Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion)

19 Sept 2023 · Discussion on competitivenes of European businesses and the new Commission's agenda.

Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion)

8 Sept 2023 · Discussion on Hydrogen bank and Finnish hydrogen cluster

Meeting with Sirpa Pietikäinen (Member of the European Parliament, Shadow rapporteur for opinion)

13 Jul 2023 · CSDDD

Meeting with Nils Torvalds (Member of the European Parliament)

7 Jun 2023 · Ecodesign for sustainable products regulation

Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion)

15 May 2023 · Meeting on Net Zero Industry Act

Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion) and Association of Finnish Local and Regional Authorities

11 May 2023 · Discussion on the Net Zero Industry Act with stakeholders

Finnish technology industry urges flexibility in EU packaging rules

24 Apr 2023
Topic — This consultation reviews EU rules to reduce packaging waste and improve recycling design.
Message — TIF wants reuse and recycling to be treated as complementary strategies. They request exemptions for specialized packaging and removal of administrative conformity declarations.123
Why — Flexible rules and harmonized standards would reduce compliance costs and operational burdens.4
Impact — Groups advocating for a strict waste hierarchy lose when companies bypass reuse requirements.5
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Meeting with Henna Virkkunen (Member of the European Parliament)

24 Apr 2023 · EU Corporate Due Diligence

Response to Virtual worlds, such as metaverse

20 Apr 2023

Virtual worlds, otherwise known as metaverse, are a fast-growing frontier of the digital space, consisting of a wide variety of immersive environments. They touch many different areas of economy from consumers to companies, offering novel ways to access and offer services, for example games and social networking, as well as to design and innovate material objects, like equipment and factories. In the field of manufacturing industry, a related and noteworthy development is the creation of digital twins for connected machines and production lines. Once deployed, these virtual doubles will improve energy and material efficiency, and remote diagnostics and maintenance, and thereby increase productivity and decrease environmental footprint. In parallel with the development of purely virtual worlds, it can be foreseen that the virtual and physical realms will also merge into an extended reality where everyday surroundings will be augmented with a layer of digital projections. For manufacturing companies and their networks of suppliers and customers, this will make the industrial Internet of Things more modifiable and accessible. Virtual and mixed realities will open new interfaces to the Internet and become platforms for people, businesses, and public authorities to interact. To maximize the benefits of these digital interfaces and platforms and to avoid the undesirable consequences of market concentration and lack of compatibility, the European Union must foster the development of shared soft infrastructure. This includes harmonized rules and standards that underpin virtual environments and ensure their interoperability, contestability, openness, and security in the Single Market and beyond. All the while, the EU must focus its efforts on creating incentives, be it R&D support or innovation-friendly regulation, for European companies to invest in skills and knowledge needed to make the successful shift to virtual and augmented environments. With this in mind, we recommend the following guidelines for the EUs policy approach to the virtual and digitally augmented worlds: 1. Collaborate closely between European policymakers and stakeholders, including industry, when planning initiatives, legislative or other, on virtual and augmented worlds. 2. Develop harmonized rules, protocols, and standards together with like-minded international partners and organizations such as the International Standards Organization (ISO) to ensure the interoperability and contestability of virtual worlds in the EU and beyond. 3. Foster an open and competitive environment that encourages innovation, entrepreneurship, and competition by requiring interoperability and portability of data and assets in virtual worlds, as a rule, while also ensuring fair and non-discriminatory access to the underlying technologies and platforms. 4. Support research, development, and deployment of virtual and augmented reality technologies, including with a view to industrial use-cases, through EU programs such as Horizon Europe and Digital Europe. 5. Implement the existing EU regulatory framework of the digital space, especially the Digital Markets and Digital Services Acts, in a flexible and adaptive fashion to adjust to the fast pace of technological changes in virtual reality platforms and related services. 6. Produce soft law instruments, like recommendations, guidelines, codes of conduct, model contractual terms, to promote the market-driven uptake of common industry practices around virtual worlds. 7. Resort to new regulation only when there is a significant risk of fragmentation of rules in the Single Market for virtual world products and services. 8. Before introducing new regulation on virtual worlds, use dynamic and collaborative ex ante impact assessment mechanisms, such as regulatory sandboxes, to ensure the proposed legislation is fit for purpose, innovation-friendly, risk-based and future-proof.
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Response to VAT in the Digital Age

4 Apr 2023

Please see attached our submission on the VAT in the Digital Age -package.
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Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen) and Valmet Oyj and

8 Mar 2023 · Energy, competitiveness

Meeting with Axel Voss (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and

8 Mar 2023 · Corporate Sustainability Due Diligence

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

8 Mar 2023 · Technology Industries of Finland present on how European institutions and European companies can work together to implement efficiently the legislation and improve structures that facilitate European companies’ competitiveness in the future.

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur)

8 Mar 2023 · Meeting on Data act

Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur) and Neste Oyj and Nokia

7 Mar 2023 · CS3D and Finnish Tech Sector

Meeting with Petri Sarvamaa (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

7 Mar 2023 · IED and Zero Pollution

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen), Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

8 Feb 2023 · current EU affairs

Technology Industries of Finland Urges Postponing BEFIT Tax Reform

26 Jan 2023
Topic — The Commission is consulting on a common framework for corporate income taxation.
Message — The organization recommends delaying the proposal until international tax standards are fully implemented. They argue the system must be optional and include intangible assets in profit calculations.123
Why — A voluntary system prevents small businesses from facing burdensome costs during cross-border expansion.4
Impact — Small export-driven nations would lose tax revenue to larger countries with more consumers.5
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Meeting with Henna Virkkunen (Member of the European Parliament, Shadow rapporteur)

11 Jan 2023 · Cyber Resilience Act

Response to European Critical Raw Materials Act

25 Nov 2022

Technology Industries of Finland (TIF) warmly welcomes the European Commissions planned adoption of a European Critical Raw Materials Act. Raw materials are indispensable to ensuring that the transition towards a green and digital European economy is successful. At the same time, they are also commodities that are at high risk of supply disruption. Unless the European Union can reduce demand for and, where indispensable, secure a reliable supply of raw materials in the long-term, the transformation of the European economy cannot and will not happen. In turn, consolidating the EUs responsible use of and access to these materials will greatly strengthen the EUs economic, environmental, and geopolitical resilience. For more information, please see the position paper attached.
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Meeting with Elsi Katainen (Member of the European Parliament) and Suomen sähkönkäyttäjät ry (Association of Energy Users in Finland)

16 Nov 2022 · Electricity market

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)

10 Nov 2022 · Meeting on electricity markets

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

7 Nov 2022 · Energy crisis related issues

Meeting with Suvi Leinonen (Cabinet of Commissioner Jutta Urpilainen)

4 Oct 2022 · Electricity market design

Meeting with Alviina Alametsä (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry)

13 Jul 2022 · Stakeholder Reception

Meeting with Henna Virkkunen (Member of the European Parliament)

29 Jun 2022 · EU Digital Policy

Response to Sustainable Products Initiative

20 Jun 2022

TIF supports the Commission’s aim to modernise regulation of ecodesign requirements of products and set a legal framework for digital product passports, facilitating the combination of data with material flows. Our key messages are: The EU should be the global leader in setting standards together with industries for a sustainable and responsible market economy. It is a great opportunity for advanced European companies to establish new markets. We need a single, sustainable market, based on harmonised requirements, effective enforcement and market surveillance. Practical challenges are sizeable, and industry needs to be closely involved when setting the harmonised standards and requirements to achieve proportionate and workable solutions. On digital product passports, we need a carefully balanced approach to data. By adjusting access and usage rights based on true needs of different players, we can maintain protection of trade secrets and have the data needed for new business models of circular economy. Setting up the arrangements for digital product passports is a highly complicated task. The system needs to be built gradually on sound general principles that consider the potential implications to the companies.
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur) and Suomen Yrittäjät ry

20 Jun 2022 · Data Act

Meeting with Henna Virkkunen (Member of the European Parliament)

6 Jun 2022 · RePowerEU

Technology Industries of Finland urges data sharing limits

13 May 2022
Topic — EU legislation facilitating access and fair value allocation in the business data economy.
Message — The association demands sharing obligations cover only raw, unprocessed data. They suggest enhancing manufacturers' access to machine data and excluding small-business contracts.123
Why — Narrowing the data definition helps companies safeguard trade secrets and avoid losing competitive advantages.4
Impact — Public authorities and service providers would have more restricted access to valuable, processed industrial data.5
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Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion) and Confederation of Finnish Industries EK

29 Apr 2022 · Discussion on EU Chips Act

Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

11 Apr 2022 · Topical discussion around energy and digital politics and Ukraine, Finnish trade politics

Response to Minimum level of taxation for large multinational groups

6 Apr 2022

Please find our comments in the attached file.
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Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion)

16 Jan 2022 · Meeting on AI Act

Response to Policy Program - Digital Decade Compass

12 Dec 2021

The Commission has proposed an ambitious programme, Path to the Digital Decade, to boost the digitalisation development throughout the EU. Technology Industries of Finland finds the four-pronged approach of the Compass in principle balanced and well-founded. GENERAL The Compass is missing a few essential themes, and we urge the Commission to include targets for data economy development and soft infrastructures. The programme proposal limits the digital infrastructure solely to hard infrastructure. As to data economy development, we would recommend having metrics on, e.g. number of functioning data spaces or availability of public sector open data and available APIs. The Digital Economy and Society Index DESI has been given a prominent position in the digital status assessment of the Member States and the EU. We encourage the Commission to consult the Member States on updating DESI. We suggest enriching the DESI indicators with OECD Digital Government Index indicators, especially when assessing the public sector prerequisites in digitalisation management and coordination. SKILLS One of the Commission targets in skills is to have 20 million ICT specialists in the EU by 2030. The target is ambitious and requires actions on several fronts. - We need to pay attention to immigration leading to work and especially immigration from outside the EU. - Continuous learning combined with upskilling and reskilling of the working age population is paramount. - Possibilities for remote working from outside the EU should be enabled, and the appeal of the EU as a remote work target area improved. - The proportion of female ICT specialists should have a target value. - The foresight of future skill demand and avoidance of employment mismatches could be achieved, e.g. by creating an EU-wide data space. It is necessary to emphasise that technological competence is not enough. For reaping the benefits of digitalisation, the EU must secure the availability of business expertise, data, and service design competencies as well as basic level digital skills and STEM skills throughout the EU. SECURE AND SUSTAINABLE DIGITAL INFRASTRUCTURES This section should include targets for the “soft” infrastructure, such as data spaces in active use and proliferation of data intermediaries. Investments in semiconductors should not go only to projects of cutting-edge chips. The investments should be based on market needs. The whole semiconductor supply network and existing European strengths should be considered. DIGITAL TRANSFORMATION OF BUSINESSES The Commission approach focuses on technology and tools. However, the core of digitalisation is the transformation of operational modes and business models enabled by innovative use of technology. We suggest considering ecosystem or platform type of activities to be assessed in the metrics. As to innovation promotion, it is important to acknowledge the role of trailblazer companies as drivers pulling along the smaller companies in large innovation projects. The common European target and national sub-targets for total R&D expenditure should be included in the Digital Decade metrics. These could be adopted from the new pact and governance structure for the European Research Area (ERA). DIGITALISATION OF PUBLIC SERVICES Digital service is not a synonym for electronic service. Digitalisation at its best can mean automation of the whole service with a throughput time of seconds. The interoperability of cross-border public services is an important dimension that is rather vaguely treated in the Compass. MULTI-COUNTRY PROJECTS The national roadmaps must be drawn up to create ambitious targets for digitally developed Member States. Participation in the multi-country projects should be included as an indicator to direct the advanced countries to multi-country cooperation. Further elaboration of comments in the attached file.
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Meeting with Silvia Modig (Member of the European Parliament)

1 Dec 2021 · Fit for 55 -package

Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

EU:n energiatehokkuusdirektiivi – arviointi ja uudelleentarkastelu Teknologiateollisuus ry kiittää mahdollisuudesta lausua otsikkoasiassa. Tiivistelmä lausuntomme pääviesteistä: • Teknologiateollisuus kannattaa energiatehokkuustavoitteen kiristämistä EU-tasolla, sillä se synnyttää markkinoita ja kysyntää energiatehokkaille ratkaisuille. • Energiatehokkuutta voidaan teollisuudessa parantaa monin eri tavoin, esimerkiksi parantamalla tuotantokoneiden, rakennusten energiatehokkuutta ja hyödyntämällä tuotannon hukkalämpöjä. • Energiankulutuksen rajoittaminen on teollisuuden vähähiilitiekarttojen toteuttamisen kannalta ongelmallinen. Ehdotamme energiankulutuksen katon poistamista. • Nykymuotoisen energiatehokkuussopimustoiminnan jatkuminen on erittäin tärkeää. Järjestelmän laajentaminen tulee perustua vapaaehtoisuuteen. • Teknologiateollisuus tukee komission “Renovation Wave Initiative” -ehdotuksen täytäntöönpanoa. Olemassa olevien rakennusten energiansäästöpotentiaali on valtava ja siihen tarvittava teknologia on jo olemassa. • Komission ehdottamat muutokset lämmityksen ja jäähdytyksen energiatehokkuuden yhteydessä käytettäviin bioenergiaan koskeviin määritelmiin on hylättävä tai vaihtoehtoisesti jätepohjaisten polttoaineiden ja teollisuusjätteiden rinnakkaispoltto on rinnastettava maakaasuun. • Emme kannata ajatusta sosiaalisten kysymysten kytkemisestä energiatehokkuusdirektiiviin. Yksityiskohtaisemmat tiedot liitteessä
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Response to Revision of the Energy Tax Directive

18 Nov 2021

The Technology Industries of Finland (TIF) is committed to the fight against climate change and sees that the EU and its Member States must make rapid progress in implementing their emission reduction commitments under the Paris Climate Agreement. We are in favor of tightening the EU's 2030 emissions reduction target to 55% and the goal of climate neutrality in the Union by 2050. We support the Commissions position that the Energy Tax Directive should be updated in line with the EU's energy, climate and environment policy framework. Competitively priced sustainable electricity is a prerequisite for achieving the low carbon targets. It must be ensured that the amendments to the Energy Tax Directive do not significantly weaken the competitiveness of the EU and European companies. Without competitively priced sustainable electricity, there is a risk of carbon leakage if manufacturing is located outside of EU, in countries with lower sustainability requirements. Also, energy taxation on transport fuels is critical for European industries because logistics costs form a major share of production costs. Global co-operation should be supported to reach an agreement on global (floor) price of carbon. Energy taxation should be well designed so as to prevent overlapping with Emission Trading System, which is the most important and the most effective market driven tool for reducing GHG emissions. Changes to energy taxation must not lead to double taxation. Our summarized comments: • We support reforming energy taxation so that sustainable fuels and electricity are subject to lower taxation. Fossil fuel subsidies should be removed. TIF is in favor of adding hydrogen to the list of energy products in the Energy Tax Directive. • Nuclear electricity is a zero-carbon source of energy and it should be taken into account as such in the directive. • We support the transition from volume taxation to energy content-based taxation. • Technology neutrality should be ensured. • Simple and predictable taxation is very important for businesses. We support simplifying energy tax legislation. However, the ETD should be carefully prepared so that the result will not to actually complicate taxation. • Current two-category electricity tax rate model applied in Finland should be accepted since it prevents carbon leakage and ensures competitiveness of the Finnish energy intensive industries. • The European Commission has proposed to increase EU’s own resources with revenues from the Carbon Border Adjustment Mechanism (CBAM) and Emissions Trading system would be allocated directly to the EU budget. Thus, these funds would not be available to Member States. The potential overlap of instruments should be taken into account in the preparation of energy taxation, considering that one of the objectives is to "preserve the possibility for Member States to generate energy tax revenues". • The proposal of changing the legal basis of Energy Taxation Directive so that it could be amended by through the ordinary legislative procedure by Qualified Majority Voting (QMV), is not acceptable. • The authorization rules proposed to the Commission should be very clear and precise, and in line with the current rules. We do not think that the authorization rules should be extended. In particular, the proposal to extend the control procedure raises questions. Commission should refrain from setting up a new excise supervisory authority. • The OECD’s preparation of global energy taxation rules should also be taken into account, as appropriate, in the preparation of the EU Energy Tax Directive, so that EU taxation does not conflict with global taxation.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Teknologiateollisuus ry on sitoutunut Suomen hiilineutraaliustavoitteeseen vuonna 2035 ja osana Euroopan unionia kansainvälisiin ilmastotavoitteisiin ja sopimuksiin, kuten Pariisin ilmastosopimukseen. Tavoite edellyttää pitkän aikavälin ilmastotoimien rakentamista siten, että EU:n hiilineutraalius saavutetaan sosiaalisesti, taloudellisesti ja ekologisesti kestävällä tavalla ennen vuotta 2050. Teknologiateollisuus on samaa mieltä siitä, että 55-valmiuspaketista käytävien neuvottelujen lopputuloksena kokonaisuudessaan saavutetaan vuodelle 2030 asetettu vähintään 55 prosentin ilmastotavoite, joka voidaan myös ylittää. Yksityiskohtainen lausuntomme hiilirajamekanisista on esitetty liitteenä olevassa muitiossa, jonka pääviestejä ovat: Pidämme hyvänä sitä, että FF55-valmiuspaketin kunnianhimotason ylläpitämistä kokonaisuutena korkostetaan, vaikka nähdäksemme valmiuspaketin ehdotuksilla on lukuisia ristikkäisvaikutuksia. Euroopan kilpailukyvyn tulee perustua globaaliin teknologiseen johtajuuteen, ei protektionismiin. Tarpeettoman yksityiskohtaista sääntelyä tulee välttää. Valittujen politiikkatoimien tulee olla teknologianeutraaleja sekä kannustaa teollisuutta uudistumaan. Paras päästövähennysten ohjauskeino on markkinaehtoinen päästökauppa, jota ei pidä laajentaa muille sektoreille ennen kuin on selvitetty huolellisesti mahdollisen laajentamisen vaikutukset päästöoikeuden hintaan ja vientiteollisuuden kansainväliseen kilpailukykyyn. Fit For 55-pakettia luotaessa on tärkeää tunnistaa kaikki keinot, joilla voidaan ehkäistä hiilivuotoa eli tuotannon siirtymistä EU:n ulkopuolelle. Näkemyksemme on, että hiilivuotoa ehkäistään tehokkaimmin vahvistamalla nykyisiä hiilivuotoriskin hallintamekanismeja - ilmaisjakoa ja sähköistämistukea. Ilmaisjako ja epäsuorien kustannusten kompensaatio tulee säilyttää, kunnes globaali hiilipäästöjen hinnoittelu saadaan toteutettua. CBA-mekanismin asettamisen ei tule merkitä päästöoikeuksien ilmaisjaon ja epäsuorien kustannusten kompensaation ennenaikaista vähentämistä. Puolueeton ja perusteellinen vaikutusarviointi, käyttäjäsektori huomioiden, tulee tehdä ennen mekanismin voimaansaattamista. EU:n tulee edistää globaalia hiilen hinnoittelua. Se kasvattaa eurooppalaisen puhtaan teollisuuden kilpailukykyä ja luo uutta liiketoimintaa. CBA-mekanismi ei ole välttämättä sopiva kaikille sektoreille ja tuotteille. Täydentäviä mekanismeja tarvitaan tasapuolisen kilpailun varmistamiseksi. CBA-mekanismin tulee pohjautua päästökaupan aiheuttamiin lisäkustannuksiin EU:n teollisuudelle. CBA-mekanismin tulee kohdistua kaikkiin sovittuihin tuontituotteisiin alkuperästä riippumatta. Vientiteollisuuden kilpailukyvyn heikkeneminen tulee välttää tai kompensoida teollisuudelle. Järjestelmä ei saa luoda monopoliasemaa Euroopan markkinoille niille tuottajille, joihin se kohdistuu. Järjestelmällä kerätyt varat tulee ohjata teollisuuden vähähiilisyysinvestointeihin koko päästökauppasektorille.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

18 Nov 2021

Teknologiateolisus ry kannattaa EU-tason toimia uusiutuvien lentopolttoaineiden käytön lisäämiseksi. Valittavat toimet tulee toteuttaa tavalla, joka vähentää tehokkaasti lentoliikenteen päästöjä, ehkäisee hiilivuotoa ja huomioi lentoliikennealan toimintaedellytykset sekä jäsenvaltioiden saavutettavuuden. Globaali kehitys avaa paitsi uusiutuvien polttoaineiden valmistajille, myös kehittyvälle vetyklusterille kiinnostavia uusia markkinoita ja edelleen vientimahdollisuuksia. Synteettisten sähköpolttoaineiden kehittämiseen ja tuotantoon panostaminen on tärkeää. Asetusehdotuksen käyttöönotto lisäisi lentoliikenteen kustannuksia arviolta 40 miljoonalla eurolla vuosittain vuoden 2030 tilanteessa. Aloitteen kustannus- ja päästövähennysvaikutuksia on kuitenkin tarkasteltava yhdessä muiden FF55-ilmastopaketin aloitteiden kanssa. Ilmailu on globaali toimiala, joten EU:n ja alan kansainvälisen järjestön ICAOn päästövähennystavoitteiden ja toimien yhteensovittaminen on ensiarvoisen tärkeää. EU:n tulee vahvistaa vaikuttamistaan ICAOssa, jotta päästöjen vähennystoimet saadaan globaalisti tasaveroisiksi ja vaikuttavimmaksi. Maksutulot tulisi kanavoida alan ilmastotoimia palveleviin toimiin.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

TIF feedback to REDII: REDII should be amended so as to include hydrogen and RFNBO-fuels produced from low carbon sources. Also nuclear power contributes to reducing GHG emissions and therefore it must be regarded as low carbon energy. The EU-level target should remain indicative. Member States should have the obligation to include their targets in the National Energy and Climate Plans (NECP). These plans are adequately controlled by the Governance of European Energy Union. Power generation may be decarbonized by renewable energy and nuclear power. Use of electricity contributes to decarbonizing industries, services, residential heating, electric mobility and light transports. However, there are hard to electrify sectors like heavy road transport, aviation and maritime sector. These sectors need hydrogen and synthetic power-to-x -fuels. Fostering new digital energy services to customers through integrating consumers flexibilities, energy storage potentials, small scale electricity production e.g. photovoltaics, EV-batteries and building automation systems and aggregating these at large scale all support the electrification of energy consumption. There should be incentives to promote CCU in cases where bioenergy is used and there are industries that could use the captured CO2 as feedstock. Public authorities should be encouraged to prefer low carbon energy technologies e.g. through more flexible conditions on public procurement rules. District heating networks can promote the use of windpower and solar energy by utilizing heat storages. When there is excess cheap renewable energy available, heat could be produced and stored for later use in district heating and save fuel usage. Storing heat is much cheaper than storing electricity. The possibility of increasing renewable energy in district heating and cooling depend very much on local conditions. A straightforward measure to increase the share of renewable energy in district heating and cooling is to include them in the NCEP’s. Third party access to district heating networks would increase alternatives for energy users and may promote renewable heat supply. The use of renewable energy in buildings depends on local conditions in each Member State. That is why it is not possible to set any percentage share. It is more important to make sure that investments according to NECP’s are made in all Member State. Industries are implementing low carbon technologies voluntarily according to their low carbon roadmaps. The main investments are targeted to electrification, digitalization and energy efficiency. Where electrification is not possible, the solution is very often hydrogen produced either by renewable electricity or nuclear power. Industrial processes differ very much on how they can make use of renewable energy. Very often industrial processes generate waste heat that is presently poorly exploited. Inspection of the potential uses of waste heat e.g. in district heating should be included in energy audits. Biofuels are the only viable options for replacing fossil fuels in heavy road transports, aviation and maritime sectors in the foreseeable future. This is why it is important that the blending obligation is maintained in road transport fuels up to 2030. Fulfilling the obligation should be neutral between different renewable and low carbon fuels. Fuel market functioning shall determine the shares of each fuel through competition. It is important to make sure that investments in bioenergy production continue to replace fossil fuels. Rules and sustainability criteria must not be changed. All relevant feedstocks should be available in bioenergy production, because the resources are scarce. It is important to maintain a stable regulatory framework for biomass installations producing heating/cooling and power. The investments are made for several decades and if there is uncertainty about GHG emission saving thresholds in the future, the investments may
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

30 Sept 2021 · Data policy and Artificial Intelligence

Response to Requirements for Artificial Intelligence

6 Aug 2021

The Commission has come along with an ambitious proposal to regulate AI. Getting the balance right in ensuring that obligations drive policy outcomes, while allowing AI innovators sufficient flexibility in meeting those obligations, is going to be critical. Especially the ethical requirements will drive forward trust and sustainable use of AI solutions. AI one of the key technologies for reforming the European industry as AI-driven analysis and optimization tools can easily be implemented to any process of which data is available. AI plays a major role in making energy-consuming processes green. Use cases for AI can be numerous and it is essential to concentrate on regulation on truly horizontal issues, that are good software development practices. AI is software but the proposed definition covers not only AI, but basically all software. The proposal sets horizontal AI regime on top of harmonised NLF EU law. This structure brings along risk to cohesion of EU requirements. At least, this is an issue that needs close coordination from the Commission and close cooperation with the industries. Scope is set so that societally important use cases (Annex III) and AI-driven safety components and stand-alone AI products meant in the NLF framework are regarded being high-risk use cases. General requirements of the Chapter II are quite well oriented with the process of development of AI systems. However, the requirements on data – complete and free form errors - veer away from realism. As a rule, requirements should follow good AI development practice, e.g. MLOps. Set of general and role-based requirements are not essentially well-suited for in-house or specifically developed AI systems. As the Act is so detailed, it will place a heavy administrative burden, that is most heavily felt on SME companies. As a new field of technology, there are no existing standards or technical requirements for many use-cases of AI. Commission cannot fix this by setting common specifications on its own, without any interaction with the industries. Here, the proposed regulatory sandboxes should be put into use. Commission has extensive powers to adopt delegated acts to adjust the definition of AI, use cases and set common specifications for AI. These major powers not only to fine-tune but to essentially adjust major elements of the Act bring along concern of legal predictability. Our suggestions • Put more emphasis on due process and lineate requirements with good industry practices, such as MLOps. • Remove excessive, casuistic, and highly detailed requirements. • Concentrate on ethical issues and take good care of cohesion of regulatory requirements. • Put regulatory sandboxes into proper use when developing common specifications for AI. • Introduce proper limits for Commission powers to adopt delegated acts. • Ensure there is a predictable lot for low-risk AI needed to optimise promises in many areas of society by limiting the scope, definition and introducing strict criteria for adjustment of high-risk use cases. • To fuel innovation, build clarity on how privacy-preserving technologies can be used to facilitate processing of personal data. Ensure full lineation with the GDPR to have high-quality learning data for AI systems.
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

1 Jul 2021 · Presenting their ideas on implementing EU industrial policy linking it to single market implementation

Meeting with Arto Virtanen (Cabinet of Commissioner Jutta Urpilainen)

28 Jun 2021 · Fit for 55 package.

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

25 Jun 2021

Initial Comments to the Data Act Technology Industries of Finland has more than 1,600 members in various fields of technology, of which roughly 1,500 are SME companies. We have been actively advancing data usage within our member companies and developing balanced and practical models for data usage and sharing. Commission proposes new practices for public sector access to business data. GDPR is quite rightly taken into account – legal basis for transfer of the data should be crystal clear as should be businesses’ responsibility over transferred (personal) data. The first option should be to have APIs in place for continuous data transfers. Public sector should be bound by ask only once principle and have processes in place to deploy data already transferred by businesses. It is important that law on B2G access is predictable and causes no unproportionate burden for companies. Here, ask only once -principle would help. As to fairness of data access on business-to-business relations, we emphasise that though this is an issue that has been discussed a lot, data practices in a great number of companies are still at nascent stage. Industry has developed model clauses (most recently Orgalim Legal on Industrial Data) and arrangements for interoperability and standards are developing. An important pre-requisite for data access is trust between the companies and as starting point it is good to let companies choose who they want to trust. It may not be easy to find a general measure for ‘fairness’ in data agreements as practices are still developing. As a general approach, hard law may be too blunt an instrument at this stage. However, it might be possible to identify some key datasets having considerable market effect and to which access is a pre-requisite for entering the market, it might be reasonable to use regulation to grant access to such datasets on e.g. FRAND basis. There are good examples of data access on mobility side but forced access must be based on careful case-by-case analysis. We would like to remind that the division of data to personal and non-personal categories will not work in practice – the scope of personal data is so wide, that in industrial context many very technical datasets can be linked back to an individual, due to work shift data that employers are required to keep. This underlines the necessity to develop solid data practices (especially privacy enhancing technologies) for processing and transferring data on a manner that respects privacy and keeps data usable. Data does not need new forms of protection in IPR regime, and it is a good to review current database directive – it was created for quite a different data landscape and discussions on limits and scope of copyright and sui generis protection are needed to maintain balance of the system. We do see value in establishing pro-competition data portability rules for cloud computing, if necessary, to create trust. Third country officials’ access to data is an issue that causes serious burden for companies. This is a topic that lies at the heart of European data capabilities and it requires thorough analysis and clear legislative solution. Companies’ obligations should be crystal clear. Notification and transparency on access requests by third country officials is a balanced and reasonable requirement. Smart contracts are essentially trust services, so we would see them in same regulation as other trust services. In this context, smart contracts would be one of the trust services to be used when digitalising business models. Usually, smart contracts would need a secure and trustworthy trigger to initiate the automated contract. Underlying data systems should be mature enough (structured, standardised) to have a meaningful lot for smart contracts.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

14 Apr 2021 · Artificial Intelligence

Response to Europe’s digital decade: 2030 digital targets

9 Mar 2021

Technology Industries of Finland sees that being able to provide the twin transition throughout the society is a must-win battle for the EU. It is also a key challenge for Europe to put its values into action. This poses a leadership challenge: digital solutions provide important pieces of shared soft infrastructure that give us the ability to have right data at the right place, to be able to use our – both persons’ and organisations’ - electronic identities on a trustworthy manner and give access to our data to the ones we choose to trust. It is not worthwhile to develop these solutions separately for private and public sectors. EU must aim for shared, flexible and intelligent solutions, stemming from the needs people and businesses - as visualised in attached picture. To facilitate this, we need to rethink leadership in digital domain, a new political approach to possibilities of digital, both at the EU and national level. European industries play a key role in making the twin transition reality. European industry also plays a key role in keeping this continent competitive and prosperous. We need a good dialogue, both in setting the targets and monitoring progress. Digital has a sizeable role to play in diminishing administrative burden and putting data into use to serve people and businesses. ‘Ask only once’ is a good principle to build upon, followed by APIs and other means of efficient data management. Cutting unnecessary administrative and regulatory burden and providing support for digitalization of SMEs are likely to be major foundations for keeping our industries at the forefront. Setting clear goals and building systematically European trustworthy and modular soft infrastructure for data and monitoring the development are the right steps to the future that is both green and digital.
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Response to Legislative framework for the governance of common European data spaces

8 Feb 2021

Technology Industries of Finland (TIF) represents more than 1,600 companies operating in Finland in various areas of technology. In Finland, the technology industry directly employs more than 300 000 people. Technology Industries of Finland regards the Data Governance Act a key piece of regulation and would like to provide the following comments: Chapter I Concept of Data Sharing Service Provider should be defined. We will provide more detailed comments under Chapter III but in any case, there is a need for proper definition. Chapter II We do see value in providing a skeleton model for making available or usable sensitive datasets. However, we are not convinced that this model would be suited for making available sensitive business data held by public authorities. In these cases, control over data should remain at their originators. For non-sensitive business data, such as annual reports, there is no need for such arrangements referred to in this chapter. The proposed arrangement might prove highly valuable in making available or usable highly sensitive data, such as health data for private research and development. we support European federated data networks that contribute to optimal research, development and healthcare delivery. Data access challenges are critical and the DGA and associated EU legislation must support data access for healthcare purposes. Thus, the relationship with the GDPR/Open data directive as well as non-legislative initiatives should also be taken into account (e.g. data spaces, 1+MG, GAIA-X). Chapter III Identifying the role of data intermediaries is a big step in European regulation. Due to the general wording of the article 9 of the proposed regulation and preamble 22, there is a wide confusion about the nature and content of the proposed regulation. Data sharing arrangements are still very nascent among European companies and practices are still at early development stage. In our view it is important at this stage to be very clear about policy objectives so that they can be taken into account by the industry. However, establishing a regulation with strict requirements, such as structural separation at this nascent stage of development might have a stifling effect on the market. It needs to be very clear whether the regulation is obligatory or optional for industries and what is the actual scope. There is concern that chapter III may have negative impact on especially SMEs if the scope is not carefully defined. Many tech companies provide data sharing platforms for their customers or for exchanging data with their suppliers. It would seem plausible to exclude companies’ mutual data sharing arrangements and regulate only those players that need the regulation to establish trust, e.g. the ones providing value-added services as a third party, such as services consisting of anonymisation, pseudonymisation or annotation of data. We do see value also in protecting already established contractual data sharing arrangements. The role of MyData operators is rather limited on the proposed regulation, compared to the MyData organisation’s White Paper. One crucial aspect and policy objective is interoperability of the operators (not the data conveyed, though). At this early stage, it is not an issue of regulation, but it is time to clearly express the policy objective. Here, it might be good to take inspiration from design of GSM networks, where by means of standards and requirement of interoperability, we were able to create a robust platform for competitive market.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Finnish Technology Industries supports the EU Commission’s comprehensive strategy on sustainable finance with the aim of redirecting capital flows to help generate sustainable and inclusive growth. However, this objective can only be achieved if the EU sustainable finance taxonomy takes into consideration the relevant aspects on how to decarbonize energy production, energy intensive industries (such as steel) and the respective enabling low carbon technologies like high efficient electrical motors, variable drives and equipment. As discussed profoundly in the EU Green Deal and related Commission documentation, successful transformation of the EU energy sector is undoubtedly the most important single task to successfully achieve the climate change mitigation targets and lead the global mitigation efforts. The energy transformation represents clearly also the biggest investments needs. To ensure European technology leadership and innovation, and the subsequent green recovery, we call upon the Commission to consult the members states and main industrial sectors about the widespread desire to postpone the enactment the first delegated act until the necessary fine-tuning has been accomplished. The technical screening criteria set by the draft act should be fine-tuned to accommodate different energy, energy efficiency and circular technology solutions and related maintenance and service activities, which all contribute to the reduction of the users carbon footprint (positive handprint) while rewarding innovation and competitiveness. We see a compelling need to amend the regulation at last in the following main substantial topics: a) Allow flexibility for tailor-made low carbon, ICT and emerging technologies b) Consider low carbon technologies at the manufacturing phase and not only at their end-use phase c) Maintain technology neutrality in energy production, storage and transfer • Nuclear power • Hydropower • Bioenergy • Hydrogen • Multifuel technology • Gaseous and liquid fuels • Transmission, storage and distribution of electricity • Research, development and innovation d) Include all maintenance and services activities that are required to support enabling technologies e) Consider the higher energy efficiency impact of newly installed technologies, especially products under Ecodesign Directive regulation f) Build up policy coherence on transitional activities with key energy legislation h) Recognize steel as enabler Each of the listed topics have been broken down to concrete amendment proposal in the attached longer version of our proposal. Further Information: Kimmo Järvinen, kimmo.jarvinen@techind.fi, +358 (0)43 825 7642 Matti Mannonen, matti.mannonen@tehcind.fi, +358 (0)40 544 7047
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Response to Sustainable Products Initiative

10 Nov 2020

Sustainable Product Policy – a necessity to fulfil Circular Economy Technology Industries of Finland welcomes the commissions initiative on Sustainable Product Policy. It is crucial for our industries that the sustainable product policy legislative initiative will provide a stable framework, while upholding the basic principle of technology neutrality which is a key enabler of ensuring a variety of technology options applicable to sustainable design requirements and choices related to material efficiency. The product design which stands at the beginning of the products’ life cycle is essential for ensuring circularity Life cycle approach in Ecodesign is supported by our industries because it is fundamental to defining requirements and should be a guiding principle for authorities. The top priority when designing products, and when establishing legal requirements on products, is to take a view from the life cycle perspective. All other aspects and requirements should be seen as complementary and as support for a circular business model. Designing sustainable products Our industries see the sustainable product policy as an opportunity for a win-win situation for the environment and the economy provided that the key principles described below are respected when developing product and information requirements: First undertake an impact assessment. Apply the “SMERC" principle: - Specific – requirements must be considered on a product group-specific basis. Even within the same product group and within individual categories of equipment in our sector, the products and their environmental impact differ significantly, especially depending on ambient and operating conditions. - Measurability – the parameters must be clear to determine, and measurement methods must be accurately defined. - Enforceability – it must be possible to verify and enforce requirements through market surveillance. - Relevance – new parameters and corresponding requirements must be relevant for the environment, the users and relevant even within specific life cycle phase(s). There must be evidence of clear and significant potential for improvement. - Competitiveness – there must be no significant negative impact on the industry’s competitiveness and the competition must be fair. Ensure that the product sustainability requirements will be harmonised at EU level. Product requirements (for example information requirements) should be technology neutral and not hinder the development of new innovations, business models and products. Policy makers should focus on products that all together stand for a great environmental impact so that the effect of the measure is proportionate (Article 15 Ecodesign Directive). When designing products, many aspects are taken into consideration by manufacturers, such as product safety and quality, material and energy efficiency, and above all the benefits for the customer. The safety, quality and performance of products and proprietary product systems must always be guaranteed. Effective market enforcement and surveillance are needed to ensure a level playing field. Establishing requirement on products requires a high level of responsibility. Requirements need to be specific on corresponding defined product groups. The product requirements developed by the policy makers must be based on science and lead to clear goals and targets. We also wish to highlight the responsibility of politicians towards companies. Politicians decide on the political objectives, which need to be clear and their decisions need to be transparent. However, decisions on the technology development, product design and technical requirements must be left to the manufacturers who are the technical experts. Therefore, the cooperation between policy makers and the industry is fundamental for the success of the measures.
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Response to Requirements for Artificial Intelligence

10 Sept 2020

Technology Industries of Finland (TIF) represents more than 1,600 companies, active in Finland in various sectors of technology industries. Our member companies cover both developers and deployers of AI. Our main messages are: • There is no one, overarching AI. AI is a set of technologies for processing and extracting value out of data, automating decisions and extracting insights. • According to latest studies, solutions and tools of data economy, such as AI will play a major role in the green transformation of the industries. • Existing Product Safety legislation is technology-neutral and has stood the test of time. We urge Commission to carefully analyse whether use of AI would call for a piece of technology-specific piece of regulation? • Instead of technology, the attention should be on data and the purpose of its processing. These define the riskiness of the use case. • On assessment of regulatory options, it is wise to apply legislation only when it is needed. However, singling out high-risk cases may prove problematic in terms of predictability and legal certainty. • Green transformation and ramping up productivity of European industries are our major challenges. Technology plays a major role when solutions are developed. To achieve this, we need steady and predictable environment for investments. • Europe needs to remain a predictable member in global value networks and not use regulation for short-sighted leaps. Excellence is best built by building on strengths and agile solutions for European data economy. Please see the attachment for detailed comments.
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Response to Legislative framework for the governance of common European data spaces

31 Jul 2020

Technology Industries of Finland (TIF) warmly welcomes initiatives that enhance data usage and interoperability and would like to especially highlight importance of following factors: • Personal data is to be found on many public and private datasets. In order to put this data to use, we need to have in place solutions to provide consent and better understanding on effect of privacy enhancing technologies. • Environment that encourages use of APIs and both technical and legal standards that make sharing and using data straight-forward. • Clear understanding on role and functioning of intermediaries Unlocking the potential of personal data Due to wide scope of personal data, it is to be found in various datasets. Therefore, strict division to personal and non-personal data is hard to make. In order to be able to use data to its full potential, we need to have a horizontal personal data space. By so doing we could facilitate usage of mixed data sets containing personal data and advance technologies and solutions that facilitate usage of personal data on a trustworthy manner. On some instances, legislation could be used to enhance usability of data, especially when dealing with special categories of sensitive data. Supporting structures: Business, Legal and Technical solutions to enhance data usage The Commission should leverage industries’ initiatives on standards, APIs as well as balanced standard legal solutions in order to build environment that encourages fair and balanced standard models for governing data. One example of these initiatives is SITRA Rulebook for Data Networks. When developing these models, the role and ongoing activities of global standards developing organisations should be leveraged to avoid duplication and encourage the development of voluntary, consensus-based and industry-driven standardisation efforts. One important factor on usability of data are legal models that give clear and sufficiently allowing usage rights to data. These model terms or rulebooks play a crucial role in establishing balanced and workable data governance practices. Governance models that provide clear usage rights and enhance trust on managing data networks encourage investments to data solutions. Naturally, business secrets and IP rights of the companies must be respected. Role of intermediaries Availability of data can be enhanced by clarifying the role of certain data intermediaries. Such intermediaries can be MyData operators, that provide scalable solutions for management of consent, digital identities and data transfers. Emergence of these operators can be enhanced by clarifying their role by means of soft and hard regulation. A key objective of regulation should be interoperability of functional elements between the operators.
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and Intel Corporation

13 Jul 2020 · European Partnership for Responsible Minerals (EPRM)

Response to 2030 Climate Target Plan

15 Apr 2020

Technology Industries of Finland supports the Paris agreement and 1.5-degree policies, and we are fully committed to the implementation of all necessary measures to mitigate climate change. We also support climate neutrality target of 2050 for the EU and 2030 energy and climate framework in general. However, we have serious concerns towards revising 2030 target level as discussed in detail below. The EU recently adopted legislation to reduce GHG emissions by at least 40 % by 2030 compared to 1990 levels. It also adopted new targets for renewable energy sources and energy efficiency for 2030 and implemented these by establishing the Energy Union and its Governance Regulation. It has been estimated that in order to reach the carbon neutrality target, investments needed in new infrastructure, industries and energy system in the EU are as high as 520-575 billion euros by 2050. Most of this must come from the private sector industries. Therefore, the EU must create a stable and predictable framework for a long term for industries that supports their international competitiveness and enable their investments in low carbon products, services and technologies in EU. This why it is of utmost importance to keep the new EU’s GHG emission reduction target at 40 % as agreed. Intermediate targets and review clauses may become necessary to ensure that milestones on the road towards carbon neutrality keep on track with the 2050 target and build in innovation and technological progress. Global stocktaking under the Paris Agreement takes place in 2023 and this is the right moment for the EU to set an intermediate target for reducing GHG emissions for 2040. Then we also have the knowledge of the contributions that other parties of the Agreement are ready to make and gives the EU the background to plan the necessary measures for safeguarding its industries global competitiveness. Opening of the present 2030 targets could also be hazardous so soon after their adoption. The risk is that revisiting e.g. effort sharing regulation in the non-ETS sector ignites a lengthy political dispute between the Member States making the legal framework of climate policy uncertain and, in the worst case, private investments in low carbon technologies could be paralysed for years. Decision-making for the 2030 target needs to be based on a proper impact assessment, which clearly indicates that are the consequences with different options, how to share the increased ambition between EU ETS and non-ETS sectors and what are the economic influences as well as to climate ones. Also, the realistic timeline and content of coming 2030 proposal need to assess against the present enormous COVID-19 economic and human crisis in Europe. We know already that major low carbon investments will take place in Finnish energy intensive industries and energy production by the end of 2030’s, but the GHG emission abatement trajectory from now to 2050 won’t be linear. Therefore, all binding mid-term objectives might limit the options available or force to use less cost-efficient technologies. The 2030 Climate Target Plan initiative should build on enhancing economic competitiveness of European enterprises, through accelerating low carbon innovations. Access to secure and competitive energy must be secured to European businesses. European industrial value chains must be strengthened. The EU should keep the legislation including free allowances and compensation of indirect costs of ETS in order to defend its energy intensive industries and create a stable and predictable framework at least to 2030. Our full commentary is attached.
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Response to Action Plan on fight against tax fraud

1 Apr 2020

Technology Industries of Finland supports the EC’s call for use of digital taxation tools and procedures. The goal should be to make the EU’s single market a competitive, appealing and well functioning environment for all businesses, as well as fair and effective for all Member State. This can be achieved by building up on the best practices of all Member States’ such as the Nordic and Baltic states’ enthusiastic and fruitful work with digitalisation and automation of taxation as well as real time economy, which could lead to notable savings to both the tax administrations and the companies, as well as minimise the tax gap and tax evasion. In addition, automation of taxation would mean a better functioning Single Market, an appealing location for businesses to locate and grow. Need for additional tax revenues will grow even more as Europe struggles with the economical crisis caused by the COVID-19 pandemic. TIF is of the view that the EC’s proposals to simplifying tax system and making taxation simpler is the best way forward. Implementing new globally different taxes (e.g. EU digitax), causing double taxation and harming tax certainty for numerous years would harm the competitiveness and growth of the EU, and impose administrative burden of compliant businesses, especially hitting the SMEs hardest as the relative administrative burden is heavier on them. TIF proposes the following means to make taxation procedures more efficient as well as limiting double taxation and disputes. Some of the means are already progressing: - Digitalisation and automation of taxation procedures could lead to notable savings both to companies and tax administrations, as well as reduce tax gaps and tax evasion. - Centralised reporting method for corporate income taxation also, for example similar type as the VAT MOSS or the CbC-reporting. - Use of dispute preventive tools, such as Pre-emptive Discussion and Cross-Border Dialogue also on a multilateral basis to enhance certainty and prevent tax disputes. - Use of ICAP and joint audits also on a multilateral basis. Digitalisation and automation of taxation procedures would also enhance RTE The Finnish Tax Administration is the first country in Europe to combine all taxation software and processes into one system. The savings for the Tax Administration alone is estimated a total of approx. 6,5 % decrease in the total annual costs. Taxation procedures have been digitalised almost fully. Savings to companies due to the decrease in compliance costs, interest expenses and tax disputes cannot be estimated yet. Investments in software robots are estimated to save an additional 1,3 % of total annual costs. Similar savings could be achieved in all European countries with investments in the digitalisation and automation of taxation. Real time economy (RTE) is about digitalisation of the monetary processes and making them interoperable with all the other digital processes. The monetary data is produced and stored in banking, accounting, brokering, taxation and post-trade services. This data should be made accessible and interoperable. Three key drivers are 1) real time accounting and taxation, 2) digital growth and balance and 3) data economy. The first key driver is being processed in Finland, Nordic and Baltic countries with projects on making financial data collected from various data sources in a structured format, making it possible for the authorities to get real-time information and reports (e.g. financial statements and tax returns) automatically and close to real-time. One important element would be to enable use of eReceipt at EU level. The Nordic countries have started the Nordic Smart Government -project, with a vision that of a data driven Nordic region, where data and digitisation enable value creation by sharing data across the Nordic region in an automatic, secure and intelligent manner, e.g. to reduce administrative work and to enhance innovation and growth.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

Technology Industries of Finland proposes that all heating fuels should be included in the ETS and no CO2-taxes should be collected in the heating sector. Energy taxes on heating fuels shall be set by Member States within the frames of Energy Taxation Directive. District heating and cooling are already within the ETS. The enclosed document enlightens our views more in detail.
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Response to Carbon Border Adjustment Mechanism

31 Mar 2020

The enclosed document gives the reactions from the Finnish Technology Industries – which accounts over 50 % of the Finnish exports - to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms. Given the expected potential higher climate ambition for 2030, we recognize that additional and improved carbon leakage provisions may be needed. However, we believe that alternative measures to the proposed CBAM-options in the IIA may have to be investigated and considered by the Commission in its upcoming impact assessment. We give our own list of required features of the possible CBAM.
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Meeting with Anthony Whelan (Cabinet of President Ursula von der Leyen)

3 Mar 2020 · new digital and data strategies, AI white paper, industry strategy

Meeting with Agnieszka Drzewoska (Cabinet of Commissioner Phil Hogan)

3 Mar 2020 · Industrial strategy, digital issues

Meeting with Dara Murphy (Cabinet of Commissioner Mariya Gabriel)

24 Feb 2020 · Discussion on Innovation and Industrial policies and actions plans

Meeting with Ruben Alexander Schuster (Cabinet of Commissioner Virginijus Sinkevičius)

19 Feb 2020 · European Business ecosystem and European environment

Meeting with Gwenole Cozigou (Acting Director-General Internal Market, Industry, Entrepreneurship and SMEs)

18 Feb 2020 · Courtesy meeting to introduce themselves and present their priorities

Response to Climate Law

5 Feb 2020

Technology Industries of Finland supports enshrining the objective of climate neutrality by 2050 in a new Climate Law under the Green Deal. It is important that EU climate policy is determined for a long term with clear targets so that European industries are able to plan their investments in a stable and enabling framework. The Climate Law should be adopted keeping in mind international competition and cost effectiveness. Technology industries are in a key position to foster low carbon innovations, sustainable products and services especially with the help of digitalisation and electrification. However, we need industrial value chains to be competitive and prevent carbon leakage, if other major economies fail to fulfil their commitments of the Paris Agreement and there is no global carbon price. That’s why it is important to continue free allocation of CO2 allowances for industries that are operating under threat of carbon leakage and compensation of higher electricity price due to emission trading to electricity intensive industries. Intermediate targets and review clauses may become necessary to ensure that milestones on the road towards carbon neutrality keep on track with the 2050 target and build in innovation and technological progress. Global stocktaking under the Paris Agreement takes place in 2023 and intermediate target for EU’s greenhouse gas emission reduction for 2040 should be set after that, when we know the contributions that other parties of the Agreement are ready to make. EU targets for 2030 have recently been fixed and it could be hazardous to change them so soon after their adoption. The risk is that revisiting e.g. the burden sharing decision in the non-ETS sector starts a lengthy political dispute between Member States making the legal framework of climate policy uncertain and, in the worst case, private investments in low carbon technologies could be paralysed for years. It would be more beneficial to have the focus on setting the right targets for the year 2040. Climate Law initiative has no added value in EU level monitoring framework as it is already in place to track progress towards greenhouse gas emission reductions. The Governance Regulation of the Energy Union already includes a process based on integrated national energy and climate plans providing upfront information on Member States’ planning. After 2030 the Governance Regulation should include only one binding target for EU’s climate action and that should be set for 2040 for greenhouse gases only. No target for the share of renewable energy and energy efficiency should be set after 2030. The status of the EU emission trading system should be emphasised as the most important mechanism to reduce EU’s greenhouse gas emissions. ETS should be complemented with European funding facilities like Innovation Fund, Horizon Europe, InvestEU and EIB, for investments in low carbon technologies, new innovations, demonstrations and pilot plants. We fully agree with our European sister organisation Orgalim’s comment that technology industries have a key role to play in the transition and has to be at the centre of enabling measures and unlocking innovative technology deployment. Embracing and accelerating electrification and digitalisation in particular is a prerequisite for achieving the climate goals and clean energy transition in a cost-efficient manner. Further details: Mr Martti Kätkä, martti.katka(at)techind.fi
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Meeting with Nele Eichhorn (Cabinet of Executive Vice-President Margrethe Vestager)

20 Jan 2020 · Industry, innovation, digital single market

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

2 Oct 2019 · New Green Deal

Meeting with Marie Frenay (Cabinet of Vice-President Andrus Ansip)

22 May 2019 · AI, Data

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

14 Mar 2019 · Circular economy, Digital Single Market

Meeting with Filomena Chirico (Cabinet of Vice-President Jyrki Katainen), Marika Lautso-Mousnier (Cabinet of Vice-President Jyrki Katainen)

23 Jan 2019 · EU innovation and industrial policies

Response to More efficient law-making in taxation: a move to QMV

18 Jan 2019

Technology Industries of Finland is strictly against transition to qualified majority voting (QMV) in EU taxation policy due to the following reasons: 1) The Commission has claimed, that the veto right has caused a significant “cost” to the EU, due to tax proposals like digital services tax (DST) and common consolidated corporate tax base (CCCTB) being blocked by some Member States. Both of these tax directive proposals would result in more taxation rights to be allocated to the countries of most consumers. The biggest Member States would gain more taxable income at the expense of the smaller export countries. 2) Tax sovereignty allows countries to decide and finance their most critical public services: health care, education, social security, infrastructure, judicial system and rescue department. Member States, whatever their size, must be permitted to be a part of the decision making in taxation matters, effecting their economy and society. Any changes to taxation must meet a goal supported by all Europeans. 3) Making quicker changes to taxation to gain short-term gains for political reasons does not make the EU more united. 4) The business of today is global. Hastily made, globally different EU tax models will not make the EU more competitive, but result in double taxation, costly tax disputes, damage tax certainty and increase administrative work for both companies and authorities. Technology Industries of Finland supports comprehensive, global, long-term tax solutions negotiated through the OECD that also includes Europe’s main trading partners. The goal should be to make the EU’s single market a competitive, appealing and well functioning environment for all businesses, as well as fair and effective for all Member States. This can be achieved by building up on the best practices of all Member States’ such as the Nordic and Baltic states’ enthusiastic and fruitful work with digitalization and automation of taxation as well as real time economy, which could lead to notable savings to both the tax administrations and the companies, as well as minimize the tax gap and tax evasion. In addition, automation of taxation would mean a better functioning Single Market, an appealing location for businesses to locate and grow.
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Meeting with Jyrki Katainen (Vice-President) and Finnish Forest Industries Federation (Metsäteollisuus ry) and Chemical Industry Federation of Finland (Kemianteollisuus ry)

11 Dec 2018 · Finnish EU-presidency and EU innovation policies

Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

4 Dec 2018 · Horizon Europe

Response to Strategy for long-term EU greenhouse gas emissions reductions

10 Aug 2018

A. Context Holistic approach is very important, because we must make sure that the measures implemented in emissions reduction are cost-efficient. “EU action should take place in a changing global framework to ensure unified action on climate change and a stable, rules based global order.” EU cannot act alone. Problem of climate change is global and that’s why the actions must be unified at global level. We also need rules based global order to prevent free-riders and distortions in global trade. This is particularly important for European energy intensive industries that are losing global market shares because of the EU unilateral emission trading system. We should promote global carbon pricing and introduce sanctions against carbon dumping by developing the WTO rules of fair trade. “Actions towards decarbonization will provide opportunities for reindustrializing Europe and strengthening Europe’s global competitiveness.” This is true only, if the other major economies, i.e. G20, fulfil their pledges in accordance with the Paris Agreement. If EU is left alone with ambitious climate actions, then the result for competitiveness of European industries is destructive. Taking into account the small share of EU greenhouse gas emissions of the global emissions, the unilateral action has little significance in preventing climate change. Problem the initiative aims to tackle According to Paris Agreement, the first evaluation of the common efforts to reduce greenhouse gas emission shall take place in 2023. Already now it is clear that further measures are needed for the time after 2030. Next steps should be agreed in the context of necessary reductions by developed countries as a group at the same time with the first evaluation in 2023. The goal for the Climate Agreement revision process should be set towards a global economy that will no longer increase greenhouse gas concentration in the second half of the century. The EU’s new long term strategy should describe pathways with various options for decarbonization and their implications. The EU’s new long term strategy will refer to the transitions across many sectors of the economies and of all Member States. In order to maintain cost-effectiveness, it is obvious that considerations are better performed at EU level. B. What does the initiative aim to achieve and how The most important challenges are: - reindustrializing Europe through digital, circular and low carbon innovation, automation and clean mobility - free, fair and sustainable global competition for markets, trade and investments. Reindustrialisation and global technological low carbon leadership is only possible, when there is a global level playing field for European industries to be competitive. Only rules based global economy can prevent carbon leakage and investment leakage from Europe and this is why the EU should strengthen the status of WTO and support the work done to pursue free trade and fair trade rules. “The starting point for the analysis is the policy measures that form the 2030 Climate and Energy Framework.” The targets of 2030 framework have finally been adopted. By 2030, the EU shall reduce greenhouse gas emissions by at least 40 %, increase the share of renewables to 32 % and improve energy efficiency by 32,5 %. Now it is important to concentrate on implementing this policy according to Energy Union principles. For the sake of credibility, new targets for 2030 must not be considered. The right moment for raising the level of ambition of EU climate policy is in 2023, when progress of the Paris Climate Agreement is evaluated. If the major parties of the Agreement, i.e. G20, have made satisfactory progress in reducing greenhouse gas emissions in accordance with their nationally determined indicative contributions, then it is time for the EU to set the next reduction target for the year 2040. Matti Mannonen - Executive Director Technology Industries of Finland
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Meeting with Risto Artjoki (Cabinet of Vice-President Jyrki Katainen)

10 Apr 2018 · Finnish EU Presidency

Response to Commission Implementing Regulation pursuant Art 16(8) of NIS Directive

11 Oct 2017

Article 2 We would like to emphasize that a DSP needs to have an Information Security Management System to be able to fulfill the requirements laid down in article 2. The harmonized international standard EN/ISO/IEC 27001 is an ISMS standard that is globally accepted by leading DSPs. Significant number of DSPs have certified their operations according to the standard. Furthermore, there exists a market of notified bodies providing certification services for the DSPs. We propose that a certified ISMS could be used as an evidence of NIS compliance by a DSP. The situation could be compared with a similar conformity assessment procedure of the Radio Equipment Directive (RED). The RED directive allows manufacturer to affix a CE marking on its products relying on internal production control, if the manufacturer’s Quality Management System is certified according to EN/ISO 9001 standard. Article 4 General Data Protection Regulation (GDPR) requires data controller to notify the data protection authorities of a data breach. DSPs typically operate as data processors. Significant conflicts and confusion could arise between authorities, data controllers and processors, if the same incident were notified to two authorities by two different entities (data processor and controller). Therefore, we propose a clear statement to be included in the text saying that one incident shall be notified by one entity to only one authority. (d) The DSPs do not have the necessary information to assess material damages on behalf of their customers. We propose point (d) to be deleted. (e) The DSPs are themselves often multinational or their customers are multinational companies. A situation described in point (e) could easily materialize even though the nature of the incident was not serious. Therefore, we propose that a DSP should not be obliged to notify incidents based on number of affected member states, if some other criterion of incident notification is not met simultaneously.
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Meeting with Jyrki Katainen (Vice-President)

29 Sept 2017 · EU trade policy, competitiveness of the EU steel industry, investments

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Aula Europe

27 Sept 2017 · Circular economy

Meeting with Jyrki Katainen (Vice-President) and Confederation of Finnish Industries EK and

11 May 2017 · Future outlook of the Energy Union package

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

10 Feb 2017 · ETS

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Aula Europe

18 Oct 2016 · post-2020 transportation fuel mix and alternative fuels

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

12 Sept 2016 · Trade policy and steel industry

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

8 Sept 2016 · EU ETS directive and the existing state aid guidelines

Response to Commission Regulation amending Annex III to Directive 2008/98/EC

17 Aug 2016

It's important that the testing methology of bioelution and ecotoxity are validated in ECVAM and OECD before the revision is implemented. You can find analysis of proposed test methologies from NordHaz-project: (pages 76-80): http://norden.diva-portal.org/smash/get/diva2:927423/FULLTEXT01.pdf. The result of the report is that there exist no validated test methologies at the moment. Waste metallic materials have specificities that need to be considered when evaluating their toxity, eg. physical form (massive, powder), coatings, crystalline structure, inclusion and/or binding in matrix, thickness of oxide/protective layer/barrier, stoechiometric equilibrium and phase balance, thermal/mechanical history, density. That means the extent of potential metal ion release and consequent bioavailability is dependent on several factors and prevailing environmental conditions. Conserning the solid metal alloys and metal products we want to pay attention to on-going work: Referring to the EU Commission meeting memo CA/56/2016 on the “Applicability and interpretation of Article 12 of Regulation (EC) No 1272/2008 (CLP Regulation) for the classification of mixtures containing substances with a harmonised classification and a specific concentration limit (SCL)” the Finnish industry warmly welcomes the conclusions on the classification of mixtures. As discussed also in the memo, it is a well known and scientifically proven fact that solid metal and products hereof have substantially different hazard properties than their respective individual components (substances). This is why we are truly happy that the memo confirms that there is no legal problem in classifying the hazardous properties of solid metals and metal products based on their bioelution properties, and that bioelution is the only correct way to evaluate their hazardous properties.
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Meeting with Jyrki Katainen (Vice-President) and

15 Apr 2016 · Steel industry and Chinese MES

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

8 Jan 2016 · China and EU steel trade

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

7 Jan 2016 · EU Steel policy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

7 Jan 2016 · Energy and climate

Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)

23 Sept 2015 · investments in sustainable energy

Meeting with Juho Romakkaniemi (Cabinet of Vice-President Jyrki Katainen)

18 Jun 2015 · Energy Union

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

27 May 2015 · Energy Union

Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Mar 2015 · Energy Union

Meeting with Aura Salla (Cabinet of Vice-President Jyrki Katainen)

25 Feb 2015 · Industry Policy

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

3 Dec 2014 · The EU's electricity market

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

2 Dec 2014 · Impact of ETS on electricity price