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The Danish Chamber of Commerce

Dansk Erhverv

Danish Chamber of Commerce represents 18,000 member companies across retail, transport, IT, tourism and knowledge services, advocating for competitive business conditions at local, national and EU level.

Lobbying Activity

Meeting with Henna Virkkunen (Executive Vice-President) and

13 Jan 2026 · State of play of EU’s tech and security policy initiatives

Meeting with Dan Jørgensen (Commissioner) and

13 Jan 2026 · European competitiveness

Meeting with Ekaterina Zaharieva (Commissioner) and

13 Jan 2026 · Investments into innovation

Danish Chamber of Commerce calls for targeted media rule updates

20 Dec 2025
Topic — This consultation evaluates the effectiveness of current EU rules on audiovisual media.
Message — The organization requests targeted adjustments to ensure public interest content is easily found on digital platforms. They also seek clearer legal boundaries between media rules and horizontal regulations like the Digital Services Act.12
Why — Targeted adjustments would ensure rules remain practical and avoid long, outdated legislative processes.3
Impact — Large global platforms would lose total control over content curation due to new prominence requirements.4
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Danish Chamber of Commerce urges faster EU quantum industrialization

15 Dec 2025
Topic — Initiative to accelerate research and industrial deployment of quantum technologies in Europe.
Message — The organization calls for fast-tracking the Quantum Act to reduce regulatory friction and fragmented approvals across Member States. They recommend designating quantum as a strategic priority within the EU Competitiveness Fund to support startups.12
Why — Streamlined rules and dedicated funding tracks would reduce costs for European startups.3
Impact — Foreign competitors face restricted access to European markets through stricter procurement rules.4
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Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall) and Confederation of Danish Industry and

8 Dec 2025 · Address to the cleantech MFF roundtable: An EU Budget for a Stronger, Cleaner and More Sovereign Europe – Recommendations from Danish Investors, Business Community & Civil Society

Danish Chamber of Commerce Demands Simplified EU Taxonomy Rules

5 Dec 2025
Topic — A review of technical screening criteria for the EU environmental and climate taxonomy.
Message — They call for significant simplification and sector-specific guidance to lower reporting burdens. The organization requests standardized templates and the use of industry averages when specific data is unavailable. They also advocate for alignment with existing frameworks to avoid duplicating requirements.123
Why — These reforms would reduce high administrative costs and make compliance more realistic for businesses.45
Impact — Investors receive distorted data while rigid rules stifle innovation for unmet medical needs.67
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Meeting with Felicia Stoica (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs)

3 Dec 2025 · European Product Act (EPA) and possible solutions to the influx of non-compliant products into the Single Market

Meeting with Hubert Gambs (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs)

19 Nov 2025 · Exchange of views on the Single Market and on the proposal for the European Competitiveness Fund

Meeting with Dan Jørgensen (Commissioner)

19 Nov 2025 · State of play on European energy conditions

Meeting with Marlene Rosemarie Madsen (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

18 Nov 2025 · Exchange of views on the Danish Chamber of Commerce’s recommendations for the forthcoming Quantum Act.

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

18 Nov 2025 · State of play in clean transition, and European businesses’ role in a greener and more competitive Europe

Meeting with Denis Redonnet (Deputy Director-General Trade)

18 Nov 2025 · EU-US economic relations

Danish Chamber of Commerce calls for streamlined EU competitiveness fund

12 Nov 2025
Topic — EU's next long-term budget funding for innovation, technology, and industrial competitiveness.
Message — The organization requests that at least 25% of EU expenditure under the ECF be directed toward strategic technologies and digitalisation. They call for simplified administrative procedures with a 'Founder Fast Track' for SMEs and scale-ups, and demand that funding mechanisms prioritize ease of access over bureaucratic requirements.123
Why — This would reduce compliance burdens for their 18,000 member companies and improve access to growth financing.45
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Danish Chamber of Commerce calls for streamlined EU circular economy rules

5 Nov 2025
Topic — New EU regulation to enhance circular economy, competitiveness, and sustainable production.
Message — The organization requests harmonized waste shipment rules, digital systems to replace paper-based procedures, and clear end-of-waste criteria. They want simplified cross-border transport regulations and EU-wide facility approvals to reduce administrative burdens and accelerate recycling.123
Why — This would reduce compliance costs and administrative delays for their member companies.45
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Danish Chamber of Commerce Demands Budget Simplification and Opposes New Corporate Tax

3 Nov 2025
Topic — EU's long-term budget proposal for 2028-2034 covering cohesion, agriculture, and related policies.
Message — The organization requests radical simplification of administrative burdens, prioritization of future growth industries over traditional sectors, and leveraging private capital through tax incentives rather than grants. They strongly oppose new EU-wide corporate taxation measures like the CORE tax.123
Why — This would reduce compliance costs and administrative complexity for their 18,000 member companies.45
Impact — Traditional agricultural sector loses historical funding share as budget shifts toward future industries.6
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Danish Chamber of Commerce urges EU to simplify digital regulations

14 Oct 2025
Topic — EU initiative to streamline digital legislation including data protection, cybersecurity, and AI rules.
Message — The organization requests exemptions for B2B employee data and low-risk personal data from GDPR, higher thresholds for Article 30 records, relaxed breach reporting requirements, and harmonized incident reporting across EU legislation. They seek risk-based approaches to data transfers and simplified cookie consent rules.1234
Why — This would reduce compliance costs and free resources from managing documentation requirements.567
Impact — Consumer privacy advocates lose stronger protections against data misuse and tracking.89
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Danish Chamber of Commerce urges renewables and grid integration for EU energy security

13 Oct 2025
Topic — Revision of EU energy security framework to address geopolitical challenges and energy crisis lessons.
Message — The organization requests the revision focus on removing barriers to renewable deployment and ensuring close coordination with the Electrification Action Plan. They call for mandatory inspection of critical components from systemic rivals and integrated energy security across electricity, hydrogen, and e-fuels.1234
Why — This would reduce security risks and administrative burdens while supporting their members' investments in green infrastructure.567
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Meeting with Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin)

13 Oct 2025 · Next MFF and other priorities

Danish Chamber urges grid expansion and tax incentives for EU electrification

9 Oct 2025
Topic — Action plan to increase electricity's share of EU energy consumption to support decarbonization.
Message — The organization requests alignment between electrification policy and grid development, tax-based incentives to reduce investment costs, faster permitting for critical infrastructure, and support for storage and flexibility solutions. They emphasize grid capacity must keep pace with industrial electrification.1234
Why — This would reduce energy costs for Danish businesses and improve competitiveness against US and Chinese competitors.56
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Danish Chamber of Commerce urges EU innovation reforms and sandbox expansion

3 Oct 2025
Topic — EU framework to strengthen Europe's innovation ecosystem and support company growth.
Message — The organization requests simplified regulatory frameworks through digital processes and regulatory sandboxes, better access to late-stage venture capital with streamlined procedures, and EU-wide training initiatives to address talent shortages.1234
Why — This would reduce regulatory uncertainty and compliance burdens while improving capital access for Danish startups.56
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Meeting with Kitti Nyitrai (Head of Unit Energy) and Brintbranchen / Hydrogen Denmark

29 Sept 2025 · Exchange of views on the EU Hydrogen policy and business environment

Meeting with Alexandre Paquot (Director Climate Action) and Brintbranchen / Hydrogen Denmark

29 Sept 2025 · Developments in the hydrogen market

Meeting with Christel Schaldemose (Member of the European Parliament)

22 Sept 2025 · consumer politics

Meeting with Marianne Vind (Member of the European Parliament)

18 Sept 2025 · Transport

Meeting with Eva Maydell (Member of the European Parliament)

16 Sept 2025 · EU Tech Agenda

Danish Chamber of Commerce Urges More Flexible EU Merger Rules

3 Sept 2025
Topic — The European Commission is reviewing merger guidelines to ensure they support economic competitiveness.
Message — The Danish Chamber of Commerce requests a holistic approach that prioritizes innovation and resilience. They propose extending the evaluation period for merger efficiencies to seven years in capital-intensive sectors.12
Why — Member companies would find it easier to consolidate and justify large-scale infrastructure investments.3
Impact — Consumers may miss out on larger price drops compared to perfectly competitive markets.4
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Meeting with Tiemo Wölken (Member of the European Parliament, Shadow rapporteur)

26 Aug 2025 · Critical Medicines Act

Danish Chamber of Commerce urges faster grid expansion and private investment

5 Aug 2025
Topic — New EU regulation on electricity grid infrastructure expansion, digitalization and interconnection.
Message — The organization requests fast-track permitting for critical infrastructure, faster approval of new tariff models, and stronger incentives for private investment in grid expansion. They emphasize that grid development must keep pace with industrial electrification and integrate flexibility solutions like storage.1234
Why — This would reduce regulatory delays and create clearer returns for their members investing in grid infrastructure.56
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Response to Revision of the Standardisation Regulation

16 Jul 2025

Dansk Erhverv hilser Kommissionens initiativ om at revidere standardiseringsforordningen velkommen. Bedre adgang til standarder, åbenhed og at standarder hurtigere gøres tilgængeligt til gavn for virksomheder, er afgørende. Ligeledes er det centralt, at harmoniserede standarder udvikles i tæt samarbejde med SMVer, NGOer og forskningsmiljøer for at sikre adgangen til standarder. En stærk og moderne ramme for standardisering er en forudsætning for et velfungerende indre marked og for Europas grønne og digitale omstilling. Det er ligeledes vigtigt, at der er fokus på reduktion af administrative byrder ifm. revisionen. Det er endvidere væsentligt, at der tages stilling til, hvordan man får implementeret og finansieret kravet fra EU-Domstolen om, at der skal være fri adgang til at læse de standarder, som skaber formodning for overensstemmelse med lovgivningen. I forhold til den nye lovgivningsramme (NLF) er det vigtigt at sikre, at NLF-principperne anvendes konsekvent i ny EU-lovgivning. Det er vigtigt, at NLF i højere grad integrerer hensyn til den cirkulære økonomi og den digitale udvikling, så virksomheder fortsat kan anvende standarder som et effektivt redskab til at sikre overholdelse af lovgivningen og fremme innovation. Endvidere er det vigtigt, at NLF tager relevant hensyn til nye forretningsmodeller som f.eks. onlinemarkedspladser og i den forbindelse sikrer, at der altid er en operatør i EU, der har ansvaret for at sikre, at standarderne er overholdt, når et produkt sælges til en forbruger i EU.
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Meeting with Christiane Kirketerp De Viron (Acting Director Communications Networks, Content and Technology)

16 Jul 2025 · EU cybersecurity certification for SMEs

Meeting with Christel Schaldemose (Member of the European Parliament, Shadow rapporteur for opinion)

23 Jun 2025 · Critical Medicines act

Danish Chamber of Commerce urges ambitious EU Biotech Act

11 Jun 2025
Topic — The consultation seeks to accelerate the transition of biotech products to market.
Message — The group calls for a centralized EU one-stop shop to simplify procedures. They want stronger intellectual property protections and streamlined trials to attract investment. Finally, they recommend recognizing biosolutions as a distinct legislative sector.123
Why — Harmonized rules and enhanced data access would reduce administrative costs for companies.45
Impact — Generic drug manufacturers and healthcare systems may face higher costs from extended patents.6
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Meeting with Dirk Gotink (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

10 Jun 2025 · EU customs legislation, e-commerce

Response to A Culture Compass for Europe

30 May 2025

Please find attached the contribution from the Danish Chamber of Commerce.
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Danish Chamber of Commerce urges delay for political advertising labels

28 May 2025
Topic — Rules for labels and transparency notices in political advertising under EU law.
Message — The Chamber urges a postponement to resolve uncertainties before upcoming Danish elections. They request uploading only metadata to databases rather than full creative content.12
Why — Businesses would avoid immediate compliance costs and protect sensitive commercial pricing information.34
Impact — Citizens could face reduced transparency regarding political influence during upcoming election cycles.5
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

28 May 2025 · European Competitiveness

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

28 May 2025 · Paneldebat

Response to European Democracy Shield

26 May 2025

Please find attached Danish Chamber of Commerce (Dansk Erhverv)'s feedback to the initiative European Democracy Shield.
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Meeting with Niels Flemming Hansen (Member of the European Parliament)

26 May 2025 · Single Market Strategy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

23 May 2025 · Debate on the Danish Chairmenship

Meeting with Christel Schaldemose (Member of the European Parliament)

23 May 2025 · CMA

Meeting with Dan Jørgensen (Commissioner)

23 May 2025 · Competitiveness Compass

Meeting with Stine Bosse (Member of the European Parliament)

16 May 2025 · Life science, biotech, water policy

Danish Chamber of Commerce backs simpler deforestation rules

13 May 2025
Topic — The consultation concerns updates to product lists in the EU Deforestation Regulation.
Message — The organization urges the Commission to simplify rules to reduce administrative burdens. They support exempting product samples, waste, and user manuals from the regulation.12
Why — These exemptions would significantly lower compliance costs and simplify business operations.3
Impact — Environmental protections may be slightly weakened by exempting specific wood-derived products.4
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Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

13 May 2025 · Priorities for the upcoming Danish Council Presidency

Response to Evaluation of the European Centre for Disease Prevention and Control

12 May 2025

The Danish Chamber of Commerce/Dansk Erhverv representing appr. 500 Danish and international life science companies located in Denmark, defined by biotech, medtech and pharma companies, welcome the call for evidence on European Centre for Disease Prevention and Control. After the COVID21 pandemic it has become increasingly more important to identify, assess and communicate on current and emerging threats to human health from communicable diseases and related special health issues. The Danish Chamber of Commerce supports the evaluation of the performance on the European Centre for Disease Prevention and Controls objectives, mandates, tasks and procedures with the following considerations.
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Meeting with Michael McGrath (Commissioner) and

12 May 2025 · Consumer policy, Data protection, Insolvency and the 28th company law regime; European Democracy Shield

Response to Communication on the EU Stockpiling Strategy

8 May 2025

The Danish Chamber of Commerce/Dansk Erhverv is one of the largest professional business organisations in Denmark with more than 18.000 member companies and 100 trade associations. The Danish Chamber of Commerce/Dansk Erhverv welcomes the European Commissions initiative on Crisis Preparedness new EU stockpiling strategy. The new geopolitical reality requires forward-looking, coherent and resilient initiatives. The Danish Chamber of Commerce supports the Commissions ambition and wish to contribute constructively to Crisis Preparedness new EU stockpiling strategy.
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Response to EU Strategy on medical countermeasures

5 May 2025

The Danish Chamber of Commerce/Dansk Erhverv representing appr. 500 Danish and international life science companies, defined by biotech, medtech and pharma companies located in Denmark, welcomes the European Commissions initiative Strategy to support medical countermeasures against public health threats. The new geopolitical reality requires a forward- looking, coherent and resilient strategy. The Danish Chamber of Commerce support the Commissions ambition and wish to contribute constructively to Strategy to support medical countermeasures against public health threats. The Danish Chamber of Commerce shares the Commissions goal of building a stronger and more resilient European Health Union. For the strategy to succeed, it is essential that it be co-designed with stakeholders and grounded in the principles of simplification, partnership, and innovation. We remain at the Commissions disposal for further dialogue and cooperation.
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Response to Critical Medicines Act

5 May 2025

The Danish Chamber of Commerce/Dansk Erhverv representing appr. 500 Danish and international life science companies located in Denmark, defined by biotech, medtech and pharma companies, welcomes the European Commissions initiative on Critical Medicines Act. The new geopolitical reality requires forward-looking, coherent and resilient health initiatives. The Danish Chamber of Commerce support the Commissions ambition and wish to contribute constructively to Critical Medicines Act with the following considerations. The Danish Chamber of Commerce recognizes that the causes of medicine supply disruptions are complex and primarily global in nature. In recent decades, production has been increasingly consolidated into fewer and larger manufacturing sites worldwide, to achieve economies of scale. While this has helped reduce costs and improve efficiency, it has also increased supply chain vulnerability. The issue is thus global and rooted in the framework conditions under which the pharmaceutical industry operates. The Danish Chamber of Commerce welcomes the overall objectives of the proposal and agrees with the Commissions assessment of the need to future-proof the security of supply for critical medicines in the EU. However, we wish to highlight several key considerations and recommendations to help ensure that the legislative framework is effective, sustainable, and innovation-friendly, while also facilitating faster patient access to medicines across the EU.
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Meeting with Stine Bosse (Member of the European Parliament, Shadow rapporteur for opinion) and FSR - danske revisorer

30 Apr 2025 · Omnibus I proposal

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and BUSINESSEUROPE and FSR - danske revisorer

30 Apr 2025 · Sustainability omnibus

Response to EU Life sciences strategy

14 Apr 2025

Dansk Erhverv takker for muligheden for at bidrage med erhvervslivets perspektiver i forbindelse med den kommende europæiske life sciences strategi. Life Science-sektoren spiller en afgørende rolle for europæisk økonomi og er et enormt aktiv som eksporterhverv for Europa og Danmark (og stod i 2023 for 19 pct. af dansk vareeksport). Tal fra EFPIA viser, at biotek-industrien alene bidrager med 35 mia. euro til EUs økonomi, og at lægemiddelindustrien i 2023 bidrog med mere end 100 mia. euro. Men det er ikke givet, at EU kan beholde den styrkeposition uden den rette handling. Nye analyser påpeger, at EU, også på life science-området, sakker bagud i forhold til især USA og Kina. For 20 år siden var forskellen på life science-investeringer i USA og EU blot 2 mia. USD. I dag er den forskel steget til 25 mia. USD. EUs forringede konkurrenceevne og det nuværende geopolitiske landskab understreger vigtigheden af, at vi i EU skal sikre forsyning, udvikling og produktion af lægemidler og medicinsk og diagnostisk udstyr, så EU er bedre rustet til nuværende og fremtidige geopolitiske udfordringer. Klinisk forskning og udvikling af nye innovative teknologier indenfor life science er altafgørende for at skabe et stærkere Europa. Store investeringer i forskning i EU resulterer ikke i nok innovation og nye produkter, fordi det er for vanskeligt at skaffe kapital og investeringer til iværksættervirksomheder. En afgørende del af en europæisk life science-strategi bør være at sikre kvalificeret arbejdskraft til branchen. Strategien bør adressere mulighederne for både at tiltrække udenlandske talenter samt investeringer i uddannelse og opkvalificering. Dansk Erhverv er en del af det Danske Life Science Råd, der har udarbejdet en række anbefalinger til life sciences strategien - der også er vedhæftet. Dansk Erhverv har bidraget væsentligt til anbefalingerne og bakker op om disse.
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Meeting with Dan Jørgensen (Commissioner) and Meta Platforms Ireland Limited and its various subsidiaries and

10 Apr 2025 · European competitiveness and Affordable Energy Action Plan

Meeting with Per Haugaard (Head of Representation Communication)

9 Apr 2025 · The Draghi Report and preparation of DK EU Presidency

Meeting with Stine Bosse (Member of the European Parliament)

7 Apr 2025 · European health policy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

7 Apr 2025 · Life science

Meeting with Henrik Dahl (Member of the European Parliament, Shadow rapporteur)

1 Apr 2025 · Simplification

Meeting with Dan Jørgensen (Commissioner)

21 Mar 2025 · European competitiveness and Clean Industrial Deal

Meeting with Henrik Dahl (Member of the European Parliament)

19 Mar 2025 · IMCO files

Meeting with Christel Schaldemose (Member of the European Parliament)

19 Mar 2025 · Public procurement

Danish Chamber of Commerce warns against agricultural supply chain overregulation

10 Mar 2025
Topic — The consultation addresses proposed amendments to strengthen farmers' positions within the food supply chain.
Message — The Danish Chamber of Commerce calls for preserving market orientation and avoiding interference with freedom of contract. They urge the Commission to reconsider mandatory written contracts and registries to reduce administrative burdens.12
Why — Maintaining current market dynamics prevents increased administrative costs and preserves competitive pricing flexibility.3
Impact — Consumers may face higher prices and reduced choice if competition rules are weakened.4
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Danish Chamber of Commerce urges limiting food trading rule enforcement

10 Mar 2025
Topic — This regulation concerns cooperation between authorities enforcing unfair trading practices in food supply.
Message — The Danish Chamber of Commerce requests that cooperation remains limited to practices that are unlawful across all Member States. They urge co-legislators to ensure the proposal adds no new burdens for companies.12
Why — They would avoid costs from a patchwork of conflicting national regulations.3
Impact — Consumers lose affordability and choice if cross-border sourcing is restricted.4
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Meeting with Piotr Müller (Member of the European Parliament, Rapporteur) and DIGITALEUROPE and

10 Mar 2025 · Evaluation of the Public Procurement Directives

Danish Chamber of Commerce Urges Simpler Public Procurement Rules

6 Mar 2025
Topic — The EU is evaluating rules governing how public authorities buy goods and services.
Message — They want simple rules focused on how goods are bought rather than what is purchased. The group requests more flexible bidding processes to encourage broader business participation.12
Why — Businesses would benefit from lower administrative costs and easier access to cross-border contracts.3
Impact — Advocates for mandatory social or green standards would see their policy influence diminished.4
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Meeting with Zaneta Vegnere (Cabinet of Commissioner Valdis Dombrovskis)

4 Mar 2025 · Competitiveness compass, simplification omnibus

Meeting with Christiane Kirketerp De Viron (Acting Director Communications Networks, Content and Technology)

4 Mar 2025 · cybersecurity and business simplification

Meeting with Annemiek Wilpshaar (Head of Unit Competition)

20 Feb 2025 · The future of the telecom industry in Denmark and the role of Competition Policy.

Meeting with Vanesa Hernandez Guerrero (Head of Unit Taxation and Customs Union) and Finland Chamber of Commerce (Keskuskauppakamari) and

19 Feb 2025 · Online meeting - Feedback for a previous meeting on 28 January 2025, and exchange of view on the Customs Reform and the e-commerce communication

Meeting with Kamila Kloc (Director Communications Networks, Content and Technology) and

19 Feb 2025 · Digital and regulatory affairs

Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

5 Feb 2025 · European competitiveness and the Clean Industrial deal

Meeting with Piotr Serafin (Commissioner) and

3 Feb 2025 · Discussion on the future Multiannual Financial Framework

Meeting with Christel Schaldemose (Member of the European Parliament)

29 Jan 2025 · e commerce

Meeting with Niels Flemming Hansen (Member of the European Parliament)

29 Jan 2025 · Danish competitiveness

Meeting with Isabelle Perignon (Director Justice and Consumers) and Kaupan liitto ry - Finnish Commerce Federation and Swedish Commerce

29 Jan 2025 · presentation of their vision re responsibilities of 3rd country online marketplaces and support for Consumer Protection Cooperation review; Commission briefly mentioned e-commerce communication and updates re product safety - Safety Gate website.

Meeting with Isabelle Perignon (Director Justice and Consumers) and Kaupan liitto ry - Finnish Commerce Federation and Swedish Commerce

17 Jan 2025 · Exchange of views with the Nordic Commerce Coalition on the responsibilities of third-country origin online marketplaces

Meeting with Henrik Dahl (Member of the European Parliament)

9 Jan 2025 · exchange of views

Meeting with Henrik Dahl (Member of the European Parliament)

8 Nov 2024 · exchange of views

Meeting with Stine Bosse (Member of the European Parliament)

6 Nov 2024 · European procurement policy

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

30 Oct 2024 · Digital topics

Meeting with Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

30 Oct 2024 · Exchange of views on digital competitiveness.

Meeting with Daniel Braun (Cabinet of Vice-President Věra Jourová)

29 Oct 2024 · AI, media, democracy

Meeting with Stine Bosse (Member of the European Parliament) and Confederation of Danish Industry

24 Oct 2024 · European industrial policy

Meeting with Sigrid Friis (Member of the European Parliament)

24 Oct 2024 · Ecodesign, REACH, PFAS, PPWR

Danish Chamber of Commerce urges telecom consolidation to boost investment

30 Jun 2024
Topic — This consultation examines scenarios for mastering Europe’s digital infrastructure needs and investment gaps.
Message — They advocate for telecom market consolidation and an overhaul of EU competition rules. The group also calls for repealing the ePrivacy Directive to facilitate data sharing. They suggest promoting collaboration on best practices for efficient data traffic distribution.12
Why — Increased scale would provide firms with the financial resources needed for critical infrastructure.3
Impact — Consumers could face less competition as merger rules shift focus away from prices.4
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Meeting with Kira Marie Peter-Hansen (Member of the European Parliament)

28 Jun 2024 · Public Procurement directive

Meeting with Nikolaj Villumsen (Member of the European Parliament)

2 Apr 2024 · Udbudsdirektivet

Meeting with Niels Fuglsang (Member of the European Parliament) and Green Power Denmark

7 Mar 2024 · Elektrificeringskonference - Sæt grøn strøm til Europa

Danish Chamber of Commerce warns against over-regulating food supply chains

29 Nov 2023
Topic — EU evaluation of rules protecting small farmers and suppliers from unfair practices.
Message — They advocate for a light touch approach to avoid over-regulation and unintended consequences. The Commission should distinguish between illegal late payments and negotiated long payment terms. They also demand an end to rules that protect large multinational firms.123
Why — Retailers and small buyers would regain bargaining power currently restricted by rigid rules.4
Impact — Large multinational suppliers would lose legal protections they exploited from national implementation rules.5
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Meeting with Christel Schaldemose (Member of the European Parliament)

29 Nov 2023 · digital regulation

Danish Chamber of Commerce opposes mandatory 30-day payment cap

9 Nov 2023
Topic — The European Commission proposes new regulations to reduce late payments in commercial transactions.
Message — The organization opposes the mandatory 30-day payment period to protect contractual freedom. They suggest focusing on enforcing existing rules in public sector transactions. They also warn that the proposal ignores the liquidity needs of small buyers.123
Why — This allows businesses to maintain cheap supplier financing and avoid administrative costs.45
Impact — Small suppliers may face continued delays without the proposed mandatory payment limits.6
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Meeting with Christel Schaldemose (Member of the European Parliament)

12 Oct 2023 · public procurement

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

6 Oct 2023 · Energy Transition

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur)

15 Sept 2023 · Ongoing EU energy policy

Danish Chamber of Commerce seeks flexibility in sustainability reporting

6 Jul 2023
Topic — The European Commission is establishing new sustainability reporting standards for large companies.
Message — The Danish Chamber of Commerce calls for longer phase-in periods for complex disclosures like supply chain emissions and financial effects. They request that reporting should generally only include material information rather than mandatory lists. Additionally, they suggest authorities prioritize providing guidance over strict enforcement and sanctions.123
Why — These proposals would reduce the immediate cost and technical difficulty of corporate compliance.45
Impact — Financial institutions may lack the specific data needed for their own regulatory reporting.6
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Danish Chamber of Commerce urges market-based 2040 climate target

22 Jun 2023
Topic — The consultation seeks input on setting the EU's 2040 greenhouse gas reduction target.
Message — The Danish Chamber of Commerce urges a market-based transition where price signals drive climate action. They recommend extending the carbon market to agriculture to incentivize emission reductions. Regulations must be simple and transparent to help businesses navigate the transition.123
Why — Simplified regulations and clear price signals would reduce administrative burdens for companies.4
Impact — The agricultural sector would lose its current carbon-pricing exemption and face higher costs.5
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Response to Ecodesign for Sustainable Products - Product priorities

10 May 2023

Please see the attached file.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

8 May 2023 · Waste Shipment Regulation

Danish Chamber of Commerce defends enzymes in sustainable plastics

3 May 2023
Topic — Consultation on establishing investment criteria for environmentally sustainable economic activities.
Message — The group urges the Commission to align taxonomy criteria with pending packaging and ecodesign regulations. They want enzymes in biodegradable plastics exempt from bans on respiratory sensitizers.12
Why — This would allow Danish firms to market enzyme-enhanced packaging as officially sustainable investments.3
Impact — Health advocates may see the inclusion of respiratory sensitisers as a safety standard dilution.4
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Danish Chamber of Commerce urges removal of aircraft decommissioning rules

3 May 2023
Topic — The consultation defines criteria for environmentally sustainable investments in aircraft manufacturing and leasing.
Message — They request removing the rule that new planes must not increase the global fleet. This would allow aviation growth while supporting the development of more efficient aircraft.12
Why — This would protect European aviation competitiveness by allowing operators to expand their fleets affordably.34
Impact — Environmental groups lose a policy tool designed to prevent the total number of aircraft from increasing.5
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Meeting with Daniel Braun (Cabinet of Vice-President Věra Jourová), Marie Frenay (Cabinet of Vice-President Věra Jourová)

26 Apr 2023 · Digital and democracy agenda

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Despina Spanou (Cabinet of Vice-President Margaritis Schinas)

26 Apr 2023 · EU Cybersecurity Policy Agenda

Meeting with Morten Petersen (Member of the European Parliament, Shadow rapporteur)

24 Mar 2023 · Energy Market Directive

Danish Chamber Warns Against Mandatory EU Payment Rules

17 Mar 2023
Topic — This consultation evaluates revisions to EU legislation regarding late payments in business transactions.
Message — The Chamber requests that the Commission protects the freedom of contract as the basis for competition. They urge officials not to introduce mandatory maximum payment terms or complex regulatory schemes.12
Why — Companies would retain the flexibility to negotiate credit terms essential for managing liquidity crises.34
Impact — Small firms lose regulatory protection against being forced into long payment wait times.5
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Meeting with Mette Dyrskjot (Cabinet of Executive Vice-President Margrethe Vestager)

6 Feb 2023 · Industrial policy

Meeting with Florian Denis (Cabinet of Commissioner Mairead Mcguinness) and FSR - danske revisorer

13 Dec 2022 · reporting standards under the CSRD

Danish Chamber of Commerce urges common EU tax consolidation

14 Oct 2022
Topic — A proposal for a unified corporate tax system across the European Union.
Message — The organization supports a common set of rules for calculating the tax base. They argue a consolidated tax base is essential for the single market. Rules should prevent individual countries from introducing their own protective measures.123
Why — This would reduce administrative costs by making transfer pricing documentation redundant.4
Impact — European companies lose competitiveness if the rules add an extra administrative layer.5
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

6 Oct 2022 · Strategy for Sustainable and Circular Textiles

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

2 Sept 2022 · Waste Shipment Regulation

Meeting with Morten Petersen (Member of the European Parliament)

24 Jun 2022 · Ongoing parliamentarian work

Danish Chamber of Commerce favors existing due diligence rules

20 Jun 2022
Topic — The consultation concerns an initiative to ban products made using forced labor.
Message — The Chamber finds that forced labor has already been addressed in the CSDD-proposal. They recommend that an adequate impact assessment is of utmost importance. They also cannot support a marketing ban.123
Why — This would avoid new administrative burdens and shield retailers from legal liability.45
Impact — Forced labor victims lose immediate protection if impact assessments delay new enforcement rules.6
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Danish Chamber of Commerce seeks clarity on waste-based fuels

17 Jun 2022
Topic — Defining the methodology for assessing greenhouse gas emission savings for recycled carbon fuels.
Message — They request that CO2 from waste-to-energy plants be classified as a sustainable source after 2035. The organization also calls for aligning definitions between different regulations to avoid market confusion.123
Why — Clearer rules would provide investment certainty for companies using municipal waste installations.4
Impact — Environmental advocates lose if flexible electricity definitions undermine strict renewable energy standards.5
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Response to A New European Innovation Agenda

10 May 2022

Please see contribution attached
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

23 Mar 2022

The Danish Chamber of Commerce welcomes the revision of the Energy Performance of Building Directive (EPBD) as energy efficiency can result in reduced greenhouse gas (GHG) emissions. The Danish Chamber of Commerce strongly supports the Paris Agreement targets and the EU climate goal of 55 % GHG reduction by 2030, as referred to in the proposal for a directive – COM (2021)802 (hereafter “EPBD”), recital 2 in the preamble. Moreover, energy efficiency can help reduce energy dependence on Russia and other third countries. Consequently, the Danish Chamber of Commerce acknowledges the importance of energy efficiency measures in general and EPBD especially. A market-driven green transition leads to cost optimization, whereas bureaucratic measures and detailed regulation – in general – leads to increased costs for businesses, taxpayers and society in general. Therefore, energy efficiency should primarily be market-driven, e.g., via the expanded Emission Trading System to buildings, as proposed by the Commission. Consequently, the EPBD must be closely aligned with the proposed ETS to buildings, the EED, the ESR, and other legislative measures. For specific remarks, see the attached document.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

The Danish Chamber of Commerce welcomes the initiative to review the EU waste framework Directive. The revision is an opportunity to support regulation that contribute to the transition towards a circular economy. This includes but is not limited to regulation that supports circular business models, harmonization of implementation in Member States and creating a marked for secondary raw materials. The roadmap lacks a detailed description on the policy options to reach the objectives. To provide further feedback more information is needed. In general, the Danish Chamber of Commerce supports the reinforcement of the polluter pays principle in existing and coming EPR schemes in particular for products sold online. Furthermore, we support enhanced cooperation with Member States and better enforcement. During the revision coherence to related regulations is important such as the Sustainable Products Initiative, the Waste Shipment Regulation, the Packaging and Packaging Waste Directive and the forthcoming textiles strategy with which it will be crucial to ensure consistency. Waste should increasingly be seen as a valuable resource and the revision of the Waste Framework Directive should bear this in mind, in order to properly complement the abovementioned revisions and further promote the principles of circularity within the union. The Danish Chamber of Commerce is ready to further engage with the Commission on the revision of the EU waste framework.
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Response to EU Competition law – revision of the market definition notice

15 Feb 2022

The Danish Chamber of Commerce’s consultation response regarding the Commissions call for evidence on the updating of the Market Definition Notice The current Commission’s Market Definition Notice used in EU competition law (the “Notice”) is from 1997 and the world has changed significantly in those 25 years. The Danish Chamber of Com-merce therefore supports the Commissions initiative to update the Notice and generally refers to our previous contribution to the public consultation on the Market Definition Notice used in EU competition law dated 9 October 2020. Specific remarks are within the attached file.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

3 Feb 2022 · Artificial Intelligence Act and Data Act

Meeting with Axel Voss (Member of the European Parliament)

2 Feb 2022 · Artificial Intelligence

Response to Transparency of political advertising

31 Jan 2022

Please see the attached.
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Response to Instrument to deter and counteract coercive actions by third countries

19 Jan 2022

See attached document for the Danish Chamber of Commerce's consultation response.
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Response to Revision of EU rules on Anti-Money Laundering (recast of a former instrument)

29 Nov 2021

Dansk Erhverv støtter op om ønsket, om en mere ensartet retstilling på tværs af medlemslandene, i overensstemmelse med udviklingen inden for hvidvask og terrorfinansiering. Selvom kryptohvidvask fortsat udgør en mindre del af den samlede mængde af hvidvaskede penge, er problemet langt fra ubetydeligt. Dansk Erhverv støtter derfor op om det øgede fokus der er på virtuelle valutaer. Se vedhæftede dokument med specifikke bemærkninger.
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Response to EU Anti-money laundering supervisor

29 Nov 2021

Dansk Erhverv er positivt stemte overfor etableringen af en fælles EU-tilsynsmyndighed, der skal medvirke til at sikre effektive tilsyn og ensartede behandlinger på tværs af medlemsstaterne. Dansk Erhverv håber på, at dette kan medvirke til en at øget beskyttelse af EU's finansielle system og for unionsborgerne, ved at fastsætte højere standarder, der afspejler den bedste praksis der anvendes af EU's finansielle institutioner. Dansk Erhverv håber på at der offentliggøres en klar vejledning til/af de omfattede virksomheder med hensyn til, hvilket lokale tilsynsorgan der skal rettes henvendelse til, samt yderligere information om samspillet mellem de forskellige tilsynsniveauer. Se vedhæftede dokument med specifikke bemærkninger.
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Response to Revision of EU rules on Anti-Money Laundering (recast)

18 Nov 2021

The Danish Chamber of Commerce supports the objective of the directive: strengthening the coordination between national financial intelligence units. The Danish Chamber of Commerce supports a deeper harmonization of anti-money laundering standards across the Union as well as greater coherence of the supervision undertaken by the national financial intelligence units. The Danish Chamber of Commerce assesses that the changes to the directive will help to ensure transparency across Member States, so that companies with cross-border activities can expect uniform treatment across Member States. National authorities must not be able to differ in the supervision to which companies are subject in across the Member States. It is precisely this problem that should be eliminated. Increased exchange of information across financial intelligence units: The Danish Chamber of Commerce supports an increased exchange of information across financial intelligence units, to the extent that it can contribute to a more effective fight against money laundering. However, the increased requirements and obligations for companies must be proportionate and with a clear connection between goals and means – in other words it must follow the principle of proportionality. Likewise, the Danish Chamber of Commerce would underline the necessity of that the exchange of information must be complaint with GDPR and professional secrecy.
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Response to Revision of EU rules on Anti-Money Laundering (new instrument)

17 Nov 2021

Dansk Erhverv støtter op om hvidvaskforordningen, der skal være med til at sikre en mere ensartet retstilling på tværs af medlemslandene, i overensstemmelse med udviklingen inden for hvidvask og terrorfinansiering. Dansk Erhverv håber på, at forordningen bidrager til en øget beskyttelse af unionsborgerne og særligt EU’s finansielle system, ved at fastsætte højere standarder, der afspejler den bedste praksis der anvendes af EU's finansielle institutioner. Dansk Erhverv håber endvidere på at forordningen vil sikre en øget transparens på tværs af medlemsstaterne, således at virksomheder med grænseoverskridende aktiviteter, kan forvente ensartet behandling på tværs af medlemsstaterne. I det vedhæftede dokument fremføres Dansk Erhvervs specifikke bemærkninger til forordningen.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

In order to achieve stable and business friendly framework conditions, which are the bases for long-term competitiveness and solid business development, the business community needs a bal-anced nature and ecosystem. An environmental and climate policy that fails to adequately protect nature and biodiversity, in its efforts to shift away from the use of fossil raw materials, can there-fore be detrimental and short-term to business development and investment. Forests and green areas such as biological ecosystems with the biodiversity in a sustainable bal-ance are particularly effective at removing CO2, as long as the biomass is extracted gently and in a controlled manner. However, industrial sectors are increasingly looking for biological raw materi-als, leading to increasing pressure on ecosystems. Efforts to protect biodiversity are therefore needed to curb CO2 emissions from land use, by building up carbon and organic materials in the soil and ensuring sustainable biodiversity in nature. Therefore, the Danish Chamber of Commerce supports a regulatory framework on biobased, bio-degradable and compostable plastics, which will contribute effectively to the EU’s Biodiversity strategy and goal of 55 percent CO2 emissions reduction target by 2030. The position of The Danish Chamber of Commerce on the use of biobased, biodegradable and compostable plastics is based on the following principles: - It is important to ensure the transition away from the use of fossil raw materials for plas-tics. Bio-based plastics should help reduce unnecessary consumption of fossil-based plas-tics. - The environmental and climate policy of the future must ensure framework conditions that also protect nature by reducing overdrafts on the planet's biological resources and de-terioration of biodiversity. - Biological indicators must be developed, which will make it possible to measure and moni-tor biodiversity in connection with the extraction of the biological raw materials and con-tribute to maintain the biodiversity at a sustainable level. - The sourcing of biomasses must be based on independent 3rd party documentation. - Biomaterials should in general be recognized as a scarce resource. It is therefore im-portant that the use of bio-based plastics is prioritized so that the use entails the greatest possible utilization for the society. - A definition on biowaste should be developed. Ideally with the right technological ap-proach, product development and demand, no biological raw material needs to be de-scribed as waste. - As a principle, green areas suitable for food production should not be used to produce bi-omass for plastics. - The use of biomass for biodegradable plastics must not burden national waste systems re-garding sorting and recycling opportunities.
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Response to Review of the general product safety directive

4 Oct 2021

Danish Chamber of Commerce welcomes the revision of the general product safety directive, including in particular the fact that the proposal aims to create compliance with the principles and definitions contained in the harmonised part of the product safety legislation and the market sur-veillance regulation. However, there are several issues that require further clarification, as well as parts of the proposal that appear to be inappropriate or undermining the functioning of the internal market, equal competition and or consumer security. Below is the Danish Chamber of Commerce's response to the special committee consultation in relation to the General Product Safety Regulation (GPSR).
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Response to Contingency plan for transport

28 Sept 2021

Dansk Erhverv (Danish Chamber of Commerce) bakker op om Kommissionens arbejde med at udarbejde en beredskabsplan for transport. Den europæiske transportsektor blev meget hårdt ramt af medlemslandenes nedlukninger som følge af covid-19. En beredskabsplan for transport, der trækker på erfaringerne med krisen, er derfor et godt initiativ, der kan forberede og fremtidssikre Unionen mod eventuelt kommende kri-ser. Dansk Erhverv er åben overfor, at det undersøges, om der er behov for at ændre lovgivning for at forbedre Unionen på den næste krise. I en krisesituation er det afgørende, at varernes og arbejdskraftens frie bevægelighed opretholdes. Det viste covid-19-krisen med alt tydelighed, da mobiliteten i det indre marked fra den ene dag til den anden blev lammet. På europæiske plan blev der vedtage retningslinjer, som fx ”Green Lane” der var et vigtigt instrument til at genoprette forsyningslinjerne. I en krisesituation, hvor de al-mindelige samfundsstrukturer kommer under pres, er det afgørende, at der et fælleseuropæisk ”fall back”-setup, der sikrer konnektiviteten på tværs af landene. Under covid-19-krisen blev der suspenderet fra diverse licenser og certifikater, og der udarbejdet fælleseuropæiske blanketter og formularer mv., som myndighederne forpligtes til at anerkende. På det område vil øget digitalisering være hensigtsmæssig fremover. På køre- og hviletidsområdet var der udfordringer og usikkerhed omkring håndhævelsen og sank-tioneringen af de mange forskellige indførte force majeure-undtagelser, når chaufførerne opere-rede i mange lande. Det var et kludetæppe af regler og undtagelser, som i en fremtidig krisesitua-tion bør undgås. Covid-19-krisen viste også, at transportsektorens modstandsdygtighed påvirkes af regler, regule-ring og restriktioner inden for andre område. Forskellige sundhedsmæssige restriktioner og rejse-restriktioner havde fx stor betydning for arbejdskraftens fri bevægelighed over grænserne. En be-redskabsplan for transport bør derfor også kortlægge krisers påvirkning af transportsektoren i bredere forstand. Visse transportsektorers overlevelse på den længere bane har hvilet på muligheden for at modtage diverse hjælpepakker, som er muliggjort inden for statsstøttereglerne. I en eventuel fremtidig kri-sesituation, der medfører negative konsekvenser i samme omfang, er det afgørende, at der kan etableres lignende fleksibilitet med hensyn til medlemsstaternes mulighed for at yde økonomisk støtte – fx til kritisk infrastruktur som eksempelvis lufthavne. Klar og hurtig kommunikation og tæt koordineringen omkring den politiske reaktion på en krise er afgørende for at forberede EU's transportsektor bedre på kriser og bevare det indre marked.
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Response to Updating the EU Emissions Trading System

28 Sept 2021

The Danish Chamber of Commerce’s consultation response regarding the revision of the EU Emissions Trading System (ETS). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU emissions trading system (ETS).
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Response to Strengthing the Market Stability Reserve linked to the review of the EU Emissions Trading System

28 Sept 2021

The Danish Chamber of Commerce’s consultation response regarding the Communication on the Fit for 55-package from The European Commission. The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the Communication on EU Emission Trading System.
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Response to Carbon Border Adjustment Mechanism

28 Sept 2021

The Danish Chamber of Commerce’s consultation response regarding a Carbon Border Adjustment Mechanism (CBAM). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Carbon Border Adjustment Mechanism (CBAM).
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Response to Review of Directive 2012/27/EU on energy efficiency

28 Sept 2021

The Danish Chamber of Commerce’s consultation response regarding the revision and update of the Energy Efficiency Directive (EED). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Energy Efficiency Directive (EED).
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

28 Sept 2021

The Danish Chamber of Commerce’s consultation response regarding the Renevable Energy Directive (RED). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU emissions trading system (ETS).
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

28 Sept 2021

The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Effort Sharing Directive (ESR). The Danish Chamber of Commerce supports an extension of the ETS to more sectors such as the transportation and building sectors (cf. the Danish Chamber of Commerce's consultation response on ETS). Extending the ETS to new sectors means that reductions in these sectors are made according to market-based principles, guided by cost-effectiveness. Therefore, extending the ETS to new sectors should go hand in hand with phasing out the effort sharing agreement for these sectors. In other words, buildings, transportation, etc. should not be covered by the ESR when they are covered by the ETS.
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Response to Land use, land use change and forestry – review of EU rules

28 Sept 2021

The Danish Chamber of Commerce is positive about a green progressive line from the EU Commission. We support the higher ambitions of the LULUCF Regulation. As a starting point, common EU rules are unequivocally good for Danish companies, as they provide more equal conditions of competition in the EU's internal market. The business community needs a balanced nature in order to achieve the framework conditions that are the basis for good long-term competitiveness and solid business development. A climate policy that does not adequately manage protection and biodiversity in efforts to shift away from the use of fossil raw materials can be detrimental and short-term to business development and investment. A company that invests in conversion to the use of biological raw materials may be in that situation in a few years, that a new environmental regulation prohibits the use and investments may be lost.
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Response to Revision of Combined Transport Directive

16 Sept 2021

Dansk Erhverv (Danish Chamber of Commerce) bakker op om visionerne i European Green deal og Sustainable and Smart Mobility Strategy. Klima- og miljøudfordringer er denne generations helt store opgave, og der er behov for klare fælleseuropæiske løsninger, instrumenter og regulering, hvis EU skal i mål med en reduktion af drivhusgasemissionerne på mindst 55 pct. inden 2030 og om klimaneutralitet inden 2050. Det europæiske samarbejde skal sikre grundlaget for en effektiv og klimavenlig mobilitet for gods inden for alle transportformer. Den multimodale transport trænger til et kraftigt løft, der skal øge effektiviteten i transportsystemet, og på den baggrund er Dansk Erhverv åben over for hensigten bag en revision af direktivet om kombineret transport om at fremme multimodal transport. Dansk Erhverv ser positiv på initiativer, der effektiviserer og optimerer multimodal transport via jernbane og vandvejen, og som forbedrer og højner kapaciteten i systemet og den dertilhørende infrastruktur. Det er afgørende, at incitamentet til at benytte multimodal transport ikke alene fremmes via en udvidelse af de økonomiske incitamenter (afgiftsrefusioner mv.), der allerede ligger i direktivet, men også ved hjælp af større sammenhæng og integration mellem de forskellige transportformer, der indgår i multimodal transport. Den grønne omstilling af transportsektoren bør i høj grad være markedsdrevet og ske på den mest omkostningseffektive måde. Både i forhold til virksomheder og medlemslandes budgetter. Dansk Erhverv bakker op om øget brug af multimodal transport. Dog er det vigtigt, at incitamentsstrukturen, der sættes op for at fremme visse transportformer, ikke sker på bekostning af og pålægger andre transportformer byrder, der skævvrider konkurrencevilkår mellem transportformerne. Derudover bør revisionen af direktivet på den lange bane ses i lyset af, at alle transportformer går mod lav- og nulemission. Det vil sige, at de negative eksternaliteter, fx i form af CO2-udledninger, udlignes mellem transportformerne over tid, hvorfor økonomiske incitamenter og subsidiering, der kun tilgodeser visse transportformer, bør udfases over tid. Dette synspunkt bør indgå og afdækkes i Kommissionens videre arbejde med konsekvensanalysen. Det bemærkes desuden, at en revision af direktivet om kombineret transport kan ikke ses isoleret, men må tage højde de varslede ændringer i ”Fit for 55”, som både kan have positive og negative konsekvenser for de enkelte transportformer.
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Response to Liability rules for Artificial Intelligence – The Artificial Intelligence Liability Directive (AILD)

26 Jul 2021

We thank the Commission for the opportunity to reply to this important Inception Impact Assessment. The regulation on product safety and product liability is one of the key stones in protecting the European Consumers and creating and uphold a level playing field for operators in EU. The regulation secures the access for European consumers to choose products from all over the world while still having the possibility to be compensated (for potential damages from the product being defect) by an operator in EU who resumes the liability as producer if the product is produced outside Europe. This has been the situation until the rise of the business model “online marketplaces”. As the Commission seems to be very much aware, this new business model has jeopardized the safety of consumers, cf. 1,a),ii) of the impact assessment, and we welcome and agree on the identification of the problem: “Under the Directive, importers are treated as producers for product liability purposes. However, the digital age has brought changes to value chains too. The rise of online marketplaces has enabled consumers to buy products from outside the EU without there being an importer, leaving consumers with no liable person from whom to seek compensation under the Directive in the event of damage.” Online marketplaces are specialized in connecting products and manufactures in 3rd countries with European consumers. Just the way physical importers are specialized in connecting European Consumers with products and manufactures from 3rd countries. The two types of economic operators should therefore also bear the same risk in course of their business. This will encourage the prevention of damage and ensure that European Consumers are protected the same way, no matter if the consumer (or her/his neighbor, sister, brother, parent etc.) chose to buy a product from a third country through a physical import or a “digital import”. In both cases the operator is the essential reason that the European consumer gets access to the product from a 3rd country. On this basis we welcome the option described by the Commission under 1.a. (iii) to “extend strict liability to online marketplaces where they fail to identify the producer”. In this regard it is, however, very important that the current definition of “producer” in the product liability directive is left untouched and that the only way the online marketplace can avoid strict liability is to point at another strict liable operator in EU, cf. the definitions and hierarchy of “producers” in the current directive. It would be damaging and undermining for the European economy, the internal market and the consumer safety if, by organizing ones business as an online marketplace with “digital import” instead of physical import with traditional retail, one would be able to avoid liability by directing the consumers to get compensation in a 3rd country even if the product is bought by the consumer in Europe and the sale and delivery is directed and made to Europe. As it appears from the impact assessment, the Commission is with good reason considering how to tackle the rising of new technologies (AI) in relation to product safety requirements and liability for damages in this regard. However, while doing so it is of most importance that the level playing field is not undermined by only obligating a part of the businesses in the value chains to bear the economic burden of being responsible and liable. Failing to protect the level playing field for the market of products from 3rd countries to European consumers will risk to encourage companies to choose the type of business model that provides them with the lowest costs and risks.
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Response to Requirements for Artificial Intelligence

22 Jul 2021

The proposal uses a vague definition of artificial intelligence (AI) and it should be clearer how AI is used in different respects. In addition, the proposal relies to a great extent on the use of delegat-ed acts, which increases the uncertainty for the companies affected by the legislation, e.g. the def-inition of what AI is can be changed. In addition, the scope of the proposal is also too vague - a large part of the problems that the regu-lation is meant to resolve are already (or should be) covered under other regulation. Thus, better enforcement of existing rules is a solution to address some of the risks that the Commission seeks to address in the proposal. This also means that there are some actions where the legality should not be determined by whether it is a machine or a human that is behind. Some of the problems the proposal seeks to address are already clearly illegal. The EU Commis-sion has used a few examples in presenting the proposal. As an example of AI that exploits vulner-able groups (Title II, art. 5b), a puppet is used that, with an integrated voice assistant, encourages children to perform dangerous actions. Whether this voice assistant has an AI component or is simply an "unintelligent" recording, which at regular intervals plays a call to embark on actions with a high risk of harming themselves or others, we have a clear presumption , that this is al-ready covered by the Product Safety Directive and / or special rules for toys - otherwise it should be in any case. The examples emphasize the point that the Commission is either in the process of regulating areas already covered by other legislation, or that the Commission itself is a little un-clear on, what the purpose of the regulation is. Therefore, the Danish Chamber of Commerce be-lieves that it is beneficial to work on creating greater clarity about the regulation's intention and purpose. Specific remarks Preamble (44) It is noted that data sets for training, validation and testing of AI systems are required to be "er-ror-free", which seems unlikely and impossible. The Danish Chamber of Commerce supports the intention of high data quality, which is free of bias and is representative, but with the very big data sets required to train algorithms, it will be enormously time-consuming and resource-intensive to ensure that there is not even a single error in the dataset. Article 53 The Danish Chamber of Commerce welcomes the potential within this article, and the idea of us-ing regulatory sandboxes to provide better conditions for innovation. However, we believe that this should be followed by co-financing from the EU budget and other incentives to ensure that enough sandboxes are set up across Member States. Article 55 It’s positive, that the Commission is aiming to support the SME’s and their use and work within AI. Paragraph 2 should set a limit (e.g. measured by number of employees or turnover), so that the smallest companies and entrepreneurs are completely exempt from paying fees and the like in connection with the regulation's requirements for conformity assessments, etc.
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Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the roadmap regarding protecting marine environment. We support the Marine Strategy Framework Directive (MSFD) and its complementary policies like the European Green Deal. We believe the protection of marine life, mitigating the negative impacts of the climate crisis, and ensuring healthy, sufficient, and resilient marine life are crucial aspects of the green transition. However, this protection should go hand in hand with the green transition and increased renewable energy utilization. Since offshore wind is a critical component in the green transition, the EU’s Offshore Renewable Energy Strategy should not receive lower priority than marine protection. Protection of mankind against climate change requires all necessary solutions and offshore wind is crucial to the EU’s goal of climate neutrality in 2050. Wind energy is currently the only renewable offshore technology which functions on a commercial basis. Therefore, there is area for improvement in the MSFD’s prioritization of renewable energy sources, specifically offshore wind. There is a need for a master plan that will include all sea basins and the development of onshore infrastructure too – Southern countries included. Landlocked countries can benefit from both, the industrial activity and increase electricity trade of clean electricity. Of course, it is crucial to have exclusion areas for fishing, nature protection and defence, but if all these exclusions remain up until 2050, it will not be possible to build wind farms in the least costly areas. Climate neutrality will still be doable, but way more expensive. Thus, Maritime Spatial Planners (MSP) need to think longer term and factor in climate mitigation in their approach. The environment must be protected through Habitats and Birds Directives, Natura 2000 and national protections. The wind industry is establishing its own fora to support environmentally acceptable development – e.g. Offshore Energy and Nature Coalition. The EU can also use funds for research into co-location – e.g. fisheries, tourism, O&G – and environmental and cumulative impacts. As more cross border projects come forward, a shared environmental impact methodology will become increasingly important. It is crucial that the Commission specifies designated areas in MSP for offshore wind production in Europe. This should be a high priority for the Commission in both MSP and MSFD. Best regards, Ulrich Bang Head of climate and energy
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Response to Update of the Reform Recommendations for regulation in professional services

29 Mar 2021

The Danish Chamber of Commerce supports the Commission’s focus on improving the Single Market in the area of regulated professions. The Danish Chamber of Commerce is deeply concerned about the lack of progress in regulatory reforms across the EU. We agree with the recent report on practical obstacles and barriers in the Single Market which highlights the access to regulated professions as one of the most significant obstacles for businesses in the Single Market. The Danish Chamber of Commerce does not believe that an update of the reform recommendations will be enough to ensure the necessary reforms. Therefore, the Danish Chamber of Commerce suggests that the Commission evaluates the possibilities of extending the Proportionality Test Directive to cover existing regulation of professions. An extension of the Proportionality Test Directive should force Member States to assess existing regulation of professions based on the proportionality principles and remove legislation that is not in line with EU law. The potential for growth by improving the Single market in the EU is massive. The Danish Chamber of Commerce have recently published a report with both an assessment of the potential and concrete proposals about how to realise this potential. The proposal mentioned above is one of these. The Danish Chamber of Commerce assesses that the potential is in fully implementing and improving the single market is at least 7% of GDP in sustained growth – about the same as the economic loss overall for the pandemic in the EU due to the pandemic. Link to study: https://www.danskerhverv.dk/siteassets/mediafolder/dokumenter/01-analyser/det-indre-marked-noglen-til-eus-genopretning---dansk-erhverv-analyse.pdf (In Danish)
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Response to Modification of the General Block Exemption Regulation for the Green Deal and the Industrial and Digital Strategies

26 Mar 2021

The Danish Chamber of Commerce (Dansk Erhverv) welcomes the opportunity to provide input on the European Commission’s roadmap on the modification of the General Block Exemption Regulation (“GBER”) for the Green Deal and the Industrial and Digital Strategies. The Danish Chamber of Commerce strongly supports the Commission’s objectives and the aims of both the European Green Deal, and the Industrial and Digital Strategies. The Danish Chamber of Commerce further supports the Commission’s initiative to assess whether certain targeted adjustments of the existing state aid GBER are necessary in light of the Commission priorities with respect to the European Green Deal as well as the Industrial and Digital Strategies. While we acknowledge that special care must be taken to ensure that goals the European Green Deal as well as the Industrial and Digital Strategies are supported by regulatory measures, we are concerned by the apparent notion, that specific amendments are needed to accommodate the Priorities. It is the general position of the Danish Chamber of Commerce, that the current state aid rules are flexible enough to support both the European Green Deal as well as the Industrial and Digital Strategies, while at the same time limiting the negative and distortive effects of state aid. The Danish Chamber of Commerce is consequently very sceptical of any initiative which extends the current reach or criteria of what may constitute legal state aid. To single out or define specific projects or initiatives as specially environmentally, industrially or digitally beneficial or worthy of state aid and allowing for easier assess or reduced criteria to such projects or initiatives, is a slippery slope which we do not support. Similarly, we are very concerned by any amendments or changes to the current state aid rules, which may widen the scope for what member states may legally provide to national companies in state aid. Any state aid given within the scope of the Green Deal as well as the Industrial and Digital Strategies, must fulfil the general requirements for legal state aid, and be decided by EU-organisation on fair and equal terms, to ensure that the state aid rules are not misused or exploited for national goals and protectionist purposes. The Danish Chamber of Commerce do however firmly support a simplification and clarification of both the text and the State aid Guidelines, as it is our experience that many small- and medium sized enterprises avoid applying for state aid schemes due to high administrative costs. Consequently, the EU should strive to ease bureaucracy and make it as easy as possible for SMEs to apply for and administer state aid. The Danish Chamber of Commerce will of course be available for further consultations as the need may arise and will also be happy to elaborate on the points made in the contribution, as well as engage in further discussion if needed.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The revision of the EPBD is part of the “Fit for 55 package” included in the Commission Work Programme 2021. This revision will focus on provisions that are central to delivering a Renovation Wave and that contribute to emission reduction. The Danish Chamber of Commerce fully supports the EU Green Deal, Climate Target Plan 2030, and Fit for 55 package and their complementary policies. The revision of the EPBD is an opportunity to secure not only energy efficiency but also more sustainable buildings. The Danish Chamber of Commerce support a more holistic view on the built environment and suggest sustainability criteria are included in the EPBD in order to ensure the uptake and usage of low carbon building materials. Furthermore, by including non-energy benefit like the impact of buildings on learning abilities, human health and productivity most likely will increase the renovation rate. For specific remarks se attached fil.
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Response to Instrument to deter and counteract coercive actions by third countries

17 Mar 2021

The Danish Chamber of Commerce supports the Commission’s ambition of shielding individual Member States and their businesses from arbitrary coercive measures from third countries. However, the Danish Chamber of Commerce stresses that it must not be used as a protectionist measure and that it is essential that the EU remains open to international trade and investments. The Danish Chamber of Commerce stresses that a new instrument has to be WTO compliant and that the Commission should avoid any overlap with existing instruments such as the Blocking Statute. Furthermore, there must be clarity as to the potential use of the instrument as uncertainty is detrimental to trade. When designing the instrument, the interests of the European business community must be kept in mind including the very difficult dilemmas that businesses with global production may encounter when sanctions are imposed from third countries. Therefore, the Danish Chamber of Commerce encourages the Commission to find solutions among international trading partners before resorting to the use of anti-coercion measures. The Danish Chamber of Commerce encourages the Commission to consult stakeholders when more details on the measure is available. Furthermore, the basic principles of better regulation should be kept in mind. The Commission must ensure that the instrument actually targets the identified problems with coercion from third countries and that it is proportionate with the aim.
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Response to Business taxation for the 21st century

10 Mar 2021

Communication on business taxation for the 21st century The Danish Chamber of Commerce is of the opinion that Commission in their communication is creating an artificial link between future structural challenges in the member states and the corporate tax system. Though it’s true that the aging European population, the cost of the green transition and new business models may put a strain on public finances - it is not true that the problem and the solution should be found within the business taxation system. The commission highlights the so called ‘race to the bottom’ of CIT rates as a problem but neglects to mention that the revenue generated from the corporate income tax has risen in all European countries in the same period. The revenue has both grown in terms of real revenue and as a percentage of the taxes collected and as a percentage of GDP. The Commission also neglects to mention that the CIT is only responsible for a very small portion of the tax revenues in the member states. It’s therefor a false premise that the solution for the future structural problems in the world overall should be found via an overhaul of the CIT system and the Commission has failed to show that the CIT of today is not in general fit for tomorrow. A more balanced approach from Commission would have been to look at the various tax bases and asses which could be raised with the fewest costs for the real economy. In Denmark the CIT has been deemed to be the most detrimental tax and therefor a tax that should be lowered instead of raised. The Commission should instead focus on the VAT which is less detrimental to the economy, a much bigger revenue maker and more robust to different business models. The European VAT system seems in a lot of ways outdated since it only covers some areas of the economy. The financial sector and the public sector should be integrated in the VAT and the number of national exemptions and reduced rates should be minimized further. Business taxation for the 21st century should be more about taxing in the right ways and thus ensuring revenue with the least costs for business and consumers instead of focusing on the existing taxes and trying to mend them. The Commission does however have a valid point then it comes to CIT. The fragmented CIT landscape in Europe and the different tax systems makes it difficult to make business across borders and it hampers the function of the single market in Europe. Especially SME’s experience that CIT systems can be a barrier. CCCTB should therefor be promoted and taken more seriously by the member states. A common consolidated tax base would make the overall European tax system more robust and reduce the number of loopholes.
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Response to Driving and rest times for bus and coach drivers

16 Feb 2021

Dansk Erhverv hilser Kommissionens initiativ om særlige køre- og hviletidsregler for buschauffører ved lejlighedsvis kørsel velkommen. På nuværende tidspunkt gælder der ens regler for chauffører af godstransport og buspassagertransport. De to sektorer adskiller sig på en række punkter væsentligt fra hinanden, hvilket afspejler sig i chaufførens kørselsbehov- og mønster. Reglerne tager i mindre grad hensyn til bussektorens særlige karakteristika, der er kendetegnet ved en høj grad af sæsonbestemt kørsel, turerens længde varierer meget, og de er ikke begrænset til hverdage, men foregår også i weekenden og om natten kørslerne, samt høje krav fra passagererne til transportydelsen (pauser, ruteplanlægning og meget andet), der nødvendiggør øget fleksibilitet til chaufførernes kørsel. På den baggrund er der god grund til at se nærmere på reglerne og tilpasse dem i overensstemmelse med bussektorens karakteristika. Reglerne for hhv. gods- og buschauffører er ikke one-size-fits-all. Kommissionen har i forslaget til ændring af forordning 1073/2009 (Mobility package II) formuleret en række positive gevinster ved øget brug af bustransport (fx at den er billig og klimavenlig), som kan fremmes yderligere ved at justere og tilpasse køre- og hviletidsreglerne til bussektoren. Hensynet bag køre- og hviletidsreglerne om gode arbejdsvilkår for chauffører og trafiksikkerhed er fortsat vigtige ved en fremtidig ændring af reglerne. Konkurrenceforholdet mellem operatører, der kører lejlighedsvis kørsel internationalt og indenrigs, bør ved en ændring af reglerne udjævnes. I dag er der mere fleksible regler for afholdelse af ugentlige hvil for chauffører, der kører international lejlighedsvis kørsel. Der kan peges på tre mulige ændringer, der i højere grad vil tilpasse reglerne til bussektorens karakteristika, og som samtidig vil forbedre operatørernes grundlag for at tilbyde passagerne høj kvalitet i transportydelsen og dermed øge bustransportens konkurrenceevne og attraktivitet. 1. Forbedret 12-dages undtagelsen. Reglen skal udbredes til også at omfatte national lejlighedsvis kørsel, og kravet om en enkeltstående personbefordringstjeneste skal afskaffes. 2. Mulighed for chauffører at forlænge - to gange om ugen - deres daglige arbejdstid til 16 timer (i øjeblikket 15 timer) - uden at overskride køretiden og uden at reducere den daglige hviletid. Dette vil i højere grad gøre det muligt at imødekomme passagerens behov. 3. Indførelse af en referenceperiode på 13 uger for at adressere sæsonudsving i turisterhvervet. Den manglende mulighed for at reducere chaufførernes ugentlige hviletid til 24 timer på kontinuerlig basis begrænser turistbusselskabers fleksibilitet, især under sæsonbetonede spidsbelastninger. Som et resultat mister erhvervet markedsandele. Da turistbuserhvervet er meget hårdt ramt af covid-19-pandemien, kan tilpasninger på køre- og hviletidsområdet hjælpe til sektorens økonomiske genopretning ved at gøre denne transportform mere attraktiv.
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Meeting with Margrethe Vestager (Executive Vice-President)

29 Jan 2021 · COVID19 recovery plan

Response to State aid rules on risk finance for SMEs

12 Jan 2021

The Danish Chamber of Commerce welcomes the opportunity to provide input on the European Commission’s roadmap on the State aid rules on risk finance for SMEs. The Danish Chamber of Commerce supports the Commission’s initiative to conduct a Fitness Check of the State aid rules, including the State aid rules on risk finance for SMEs. It is the general position of the Danish Chamber of Commerce, that the current state aid rules are sufficiently flexible to allow for risk finance for SME, while at the same time limiting the negative and distortive effects of state aid. The Danish Chamber of Commerce is therefore very sceptical of any initiative which extends the current reach or criteria of what may constitute legal state aid, and would caution against singling out or defining specific projects, initiatives or company categories as especially worthy of state aid, as this may result in a slippery slope which we do not support. Similarly, we are very concerned by any amendments or changes to the current state aid rules, which may widen the scope for what member states may legally provide to national companies in state aid. State aid must be granted based on fair and equal terms, to ensure that the state aid rules are not misused or exploited for national goals and protectionist purposes. The Danish Chamber of Commerce do however firmly support a simplification of both the text and the application process of the current state aid rules, as it is our experience that many smalland medium sized enterprises avoid applying for state aid schemes, including risk finance opportunities, due to high administrative costs. Consequently, the EU should strive to ease bureaucracy and make it as easy as possible for SMEs to apply for and administer state aid. The Danish Chamber of Commerce will of course be available for further consultations as the need may arise and will also be happy to elaborate on the points made in the contribution, as well as engage in further discussion if needed.
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Response to State aid rules for Research, Development and Innovation

12 Jan 2021

The Danish Chamber of Commerce welcomes the opportunity to provide input on the European Commission’s roadmap on the Review of the Framework for State aid for research and development and innovation. The Danish Chamber of Commerce supports the Commission’s initiative to conduct a Fitness Check of the State aid rules, including a review the existing Framework for State aid for research and development and innovation. It is the general position of the Danish Chamber of Commerce, that the current state aid rules are flexible enough to support and facilitate European research, development and innovation, while at the same time limiting the negative and distortive effects of state aid. The Danish Chamber of Commerce is therefore very sceptical of any initiative which extends the current reach or criteria of what may constitute legal state aid. To single out or define specific projects or initiatives as especially beneficial or worthy of state aid, thereby allowing for easier assess or reduced criteria to such projects or initiatives, is a slippery slope which we do not support. Similarly, we are very concerned by any amendments or changes to the current state aid rules, which may widen the scope for what member states may legally provide to national companies in state aid. The Danish Chamber of Commerce do however firmly support a simplification of both the text and the application process, as it is our experience that many small- and medium sized enterprises avoid applying for state aid schemes due to high administrative costs. Consequently, the EU should strive to ease bureaucracy and make it as easy as possible for SMEs to apply for and administer state aid. The Danish Chamber of Commerce will of course be available for further consultations as the need may arise and will also be happy to elaborate on the points made in the contribution, as well as engage in further discussion if needed.
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Response to Commission Implementing Decision on standard contractual clauses for the transfer of personal data to third countries

10 Dec 2020

Initially we would like to thank the Commission for taking the initiative to revise the existing SCCs. New standard contracts have long been needed and it is of enormous importance that the Com-mission focuses on creating tools that in practice enable data transfer to the US until we hopefully very soon will have a new EU-US agreement to replace the Privacy Shield agreement. We also appreciate the European Commission’s approach to provide Standard Data Protection Clauses for four different international data transfers scenarios, and to offer certain optional clauses, but we urge the Commission to submit four separate documents, each addressing one specific data transfer situation. This would be significantly easier to work with in practice. The one-year transition period is too short. The Commission has provided organizations with a one-year transition period to implement the New SCCs, after which time the current SCCs can no longer be relied on to legitimize transfers. This proposed transition period is very short, and is likely to pose significant challenges for many businesses, especially multinational companies that may have hundreds or even thousands of con-tracts that incorporate the current SCCs. This is particularly so given that the New SCCs require companies to document their assessments of the data transfers, taking into account the specific circumstances of the transfer, the laws of the third country of destination, and any safeguards adopted in addition to the SCCs (Section II, Clauses 2(b) and (d)), all of which could take a signifi-cant amount of time to document. Accordingly, the Commission should provide a longer transition period to ensure that organiza-tions have sufficient time to implement the New SCCs and take the steps necessary to comply with its obligations. Warranty on local laws Section 2 Clause 2 will off course very difficult to handle in real life. It will not be easy for especial-ly the data importer to live up to this Clause. According to Clause 2 b) (i) the parties have to de-clare, that they have taken the mentioned elements into account. One of the elements is “the na-ture of the personal data”. If this means that the data processor has to take into account any spe-cial legislation that applies to the personal data that are put into the data processor's system, this becomes an impossible task. An example could be a CRM system provider whose customers may belong to different industries and therefore will be subject to different regulatory controls (e.g. food control) Accordingly, the Commission should delete “the nature of the personal data” in Clause 2 b) (i) or clarify what is meant by this term. Liability Rules on liability between parties are negotiated as part of the commercial transaction and relate to multiple aspects of the commercial relationship – including but not limited to compliance with data protection and non-data protection laws. It is of extremely importance, that the parties still have the possibility to negotiate limitations on liability “inter partes”. If this is not the case, it might be very difficult for e.g. the data processor to get his services insured, because most of the insurance companies doesn´t accept unlimited liability clauses. When the GDPR entered into force in Denmark in 2018, the Danish Ministry of Justice wrote in their report, that article 82 in the GDPR did not prevent the parties from entering into liability clauses. Accordingly we therefore suggest, that the Commission clarifies this in Section 1 Clause 1 litra c) or even makes Section 2 Clause 8 optional. Require data importers to comply with decisions only if they are final under EU or Member State law. Section II, Clause 6(d) (in all modules except processor-to-controller) requires the data importer “to abide by a decision binding under applicable EU/Member State law.
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Response to Revision of the Communication on important projects of common European interest

9 Dec 2020

The Danish Chamber of Commerce would like to thank the Commission for inviting input on the roadmap regarding the revision of the IPCEI communication. The Danish Chamber of Commerce believes that the way forward is that Europe needs to excel by competing - on a level playing field – with the rest of the world. Not by closing Europe or by picking winners – but by fostering an internal market that allows business to scale-up and become large organically. Framework conditions is the name of the game – a competitive environment where the best businesses succeed – because they are the best – and not because they are subsidized by state aid or except from competing with competitors. In this view copying the state aid of certain third countries and hollowing out the competition rules will result in a global and possibly European state aid race – which Europe and smaller countries in Europe would eventually loose. It would also stifle innovation and create European near-monopolies with all the unfortunate effects that has. Having said that there are widely recognized challenges stemming from the behavior of certain third countries that needs to be addressed. For us the solution is to use the existing Trade Defensive Instruments, the newly passed rules on Foreign Direct Investments and the instruments proposed in the White paper on foreign subsidies. These instruments should be applied judiciously and with a clear view to avoid protectionism – Europe must remain open for business. As to the IPCEI communication more specifically, the Danish Chamber of Commerce recognizes that IPCEI may be one of the tools to address great market failures such as the climate crisis. However, it is of great importance to adhere to the fundamental principles of the Single Market when revising the IPCEI communication. To ensure effective competition in the Single Market, IPCEI should only be used to address instances of clear market failure. Furthermore, a strict assessment of the distortive effects of the aid by DG Competition should be maintained. Secondly, the use of the IPCEI guidelines should focus on projects of a major innovative nature avoiding a protectionist use of IPCEI state aid to shield uncompetitive industries. When designing the IPCEI guidelines, the aim should be to simulate a competitive situation to the largest possible extent rather than enabling Member States to “pick the winners”. Thirdly, the Danish Chamber of Commerce supports the Commission’s proposal to enhance SME involvement by among other things encouraging SME involvement as partners. We would also welcome the introduction of a principle of proportionate assessment for SME participation, however, the Commission should make sure that it does not result in a circumvention of the guidelines. Furthermore, the possibility of being involved as an indirect partner for SMEs should be maintained and further strengthened. Finally, The Danish Chamber of Commerce underscores the need for a more transparent and inclusive setup allowing all parts of the European business community to take part in the IPCEI processes. We therefore welcome the Commissions emphasis on ensuring open and transparent calls of interest in participating Member States. A further step to ensure transparency could involve an open platform with an overview of the ongoing IPCEI application procedures in all participating Member State.
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Response to Evaluation of the 'New Legislative Framework' for EU legislation on industrial products

2 Dec 2020

The Danish Chamber of Commerce considers it crucial that in an upcoming revision of the NLF, the Commission ensures that all roles and activities in the supply chain are covered by a responsibility that corresponds to the role and activity a given operator performs in relation to placing products on the European market, and that the current gaps in the range of responsibilities, concerning online marketplaces facilitating sale of goods between third country sellers and European consumers, which today jeopardize the functioning of the internal market and the consumer safety, are closed. As the Commission states in the introduction of the roadmap, the crucial purpose of the NLF is to ensure that the products covered by harmonized product safety legislation are safe and in line with harmonized legislation when they are placed on the European market. This includes that the NLF provides that all products commercially placed on the European market are associated with a European operator which is responsible for the safety and compliance of the product.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

The Danish Chamber of Commerce thanks the Commission for the opportunity of responding to the roadmap regarding national emissions reduction targets and effort sharing regulation (ESR). We strongly support EU climate ambitions and complementary policies and want to emphasize the importance of high ambitions and shared goals throughout all the EU. The Danish Chamber of Commerce supports option 1 the EU presents in its proposal to phase out the ERS and extending emissions trading to include additional sectors, which are currently being accounted for in ESR. This is cheaper for EU as an entirety and more effective.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

See attached document for feedback.
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Response to Addressing distortions caused by foreign subsidies

29 Oct 2020

The Danish Chamber of Commerce supports the efforts to avoid distortions in the single market as a result of foreign subsidies. There is a real need to adress these issues. EU member states are subject to very strict regulation, that only as an exception allows state aid for European businesses. Compettion between unsubsidised businesses and businesses subsidies by a state actor will invariably result in an unlevel playing field. Subsidised businesses can for example bid lower on public procurement processes. If European businesses are to be succesful and possibly larger than we are seeing today, we need a large uninhibited and barrierfree internal market - this includes the possibility to address distortive subsidies from third countries. The Danish Chamber of Commerce considers it vital that European businesses, both in general and in specific sectors, are not subject to unfair competition resulting from subsidies from third countries. The Danish Chamber of Commerce considers that the proposed overall solutions are appropriate to ensure good framework conditions, a wellfunctioning internal market and a competitive european economy. The Danish Chamber of Commerce believes that the proposed intruments combined with the FDI-screening rules and the trade defensive instruments presents an alternative to the less than helpfull proposals to artificially create european champions by hollowing out the merger-regulations and start a state aid race - both globally and internally in the EU. A competitive european economy must be ensured by protecting and developing the internal market - not by practising the same protectionism that we are finding problematic when it originates from third countries. The Danish Chamber of Commerce thus supports the initiatives. It is however important to take into account that the proposed solutions are rather farreaching and it is thus vital that the Commission ringfences the use of these instruments in a proportional manner, that adresses unfair competition but cannot be used for protectionism - a clear definitions of "distortive state aid" and the "EU-interest test". It is furthermore a priority that the instruments are not disproportionally burdensome for businesses or authorities responsible for public procurement. The Danish Chamber of Commerce are looking forward to the full impact assesment(s) and the proposal(s) and are happy to engage with the Commission and other interested parties on this issue.
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Response to Sustainable corporate governance

7 Oct 2020

The Danish Chamber of Commerce welcomes the opportunity to provide input to the Commissions roadmap on Sustainable corporate governance. Please find the full response on behalf of the Danish Chamber of Commerce attached. General remarks Under Danish law there is already a requirement in the Danish Financial Statements Act for large companies to supplement the management report with a non-financial report on CSR-related issues such as environment, climate change, social and human rights etc. Among others these requirements entail describing the companies’ due diligence processes, if the company has any. The Danish Chamber of Commerce supports the need for a possible EU-initiative on this matter on the grounds of securing a level playing field across the EU. The Danish Chamber of Commerce agrees with the Commission’s view that issues such as sustainability are global and have cross-border effects since many companies are becoming EU-and global-wide. Specific remarks The initiative should be based on existing UN and OECD guidelines The Danish Chamber of Commerce supports that an EU initiative in this area is based on existing UN and OECD guidelines. It is important for the Danish Chamber of Commerce that there is not introduced new Due Diligence-requirements that goes beyond the existing UN and OECD-guidelines to secure a level playing field globally. SMEs should be given due consideration The Danish Chamber of Commerce supports and fully agrees with the Commission’s view on giving due considerations to SMEs to exempt where possible and limit and alleviate burdens. SMEs will in practice be covered by the initiative being suppliers to the large companies. This should be taken into consideration as to the scope of the EU initiative towards SMEs. In practise, it is possible that large multinationals simply pass on or outsource responsibility and data requests to SMEs further down in the value chain. This scenario must be duly addressed by the Commission, so that Due Diligence requirements do not end up distorting competition. Policy coherence and simple, uniform reporting standards Simple reporting-standards should be available for business to ensure uniform use and comparability of impact, across the EU. Mandatory Due Diligence should be aligned with other regulatory initiatives from the Commission, for instance the review of the Non-Financial Reporting Directive as well as the demands in the EU taxonomy for sustainable activities, both of which will have companies report on environmental and social performance indicators. Concerns as to tiers of value chain-responsibility The scope of the EU initiative to not only involve the company itself but also their (entire) value chain is a matter of concern. The Danish Chamber of Commerce encourages that due consideration is given to the complexity of business models. Many Danish companies do not have the size and bargaining power to affect and impose measures on their suppliers or other contractual relations. Worst case is that these companies end up being liable for matters over which they have no influence. The Danish Chamber of Commerce therefore stresses the need for proportionality with the use of, e.g., exemptions and limitation in liability for non-compliance. Legal certainty The Commission should address the central question of liability: When a company complies with all the formal requirements for Due Diligence, and a violation of human rights for some reason still takes place in its supply chain, where do the company stand in terms of liability? Existing court rulings suggest that having a supplier code of conduct and actively following up on it, place companies in greater risk to be held liable for violations in the supply chain. This must be clarified in the interests of legal certainty and the basic incentives. Due Diligence legislation should incentivize companies to collaborate and share best practice.
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Meeting with Margrethe Vestager (Executive Vice-President) and

28 Sept 2020 · Discussion on economic recovery.

Response to New competition tool

30 Jun 2020

The Danish Chamber of Commerce welcomes the opportunity to provide input on the Inception Impact Assessment (“IIA”) on the possible “New Competition Tool (‘NCT’)”. It is the general position of the Danish Chamber of Commerce, that new legislation, to the furthest extent possible, should be general in nature, so that it may be applicable regardless of sector, technology or business-model. Legislation targeting general issues, but aimed only at specific sectors, technologies or business-models risk becoming obsolete or dated very quickly, thereby creating unintended loopholes and barriers, fragmentation of the Single Market, and a stifling of innovation and development. The focus must be on creating a level playing field. With this IIA, the Commission seeks to explore the need for a possible new competition tool, that will allow the Commission to address structural competition problems present within the internal market, in a timely and effective manner. The Danish Chamber of Commerce supports the Commission’s objective of ensuring fair and contestable markets, and to a certain extent, share the Commissions concern regarding the existence of such structural competition problems. The Danish Chamber of Commerce is however critical of the policy options reflected in the IIA, as they are very extensive and not sufficiently described or justified in the IIA. The Danish Chamber of Commerce therefore requests the Commission to describe the need and justification for this new tool, as well as the structural competition problems which the new tool is intended to address, in the upcoming Impact Assessment (“IA”). Considering the current review of the existing competition tools, the Danish Chamber of Commerce is surprised that Commission choose to introduce this NCT now, without commenting on why the existing competition tools – even post review – will not be enough to address the identified structural competition problems. Furthermore, the Danish Chamber of Commerce is skeptical of any tool or measures which enables authorities – in this case the Commission – to impose behavioral and, where appropriate, structural remedies on private companies without finding infringements. This would be a giant leap from the rules we know today. Consequently, the Danish Chamber of Commerce considers it imperative, that any new tool is subject to strict oversight and is accompanied by appropriate safeguards, rights of defense and due process.
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Response to Digital Services Act: deepening the Internal Market and clarifying responsibilities for digital services

30 Jun 2020

The Danish Chamber of Commerce is the second largest business organisation in Denmark and represents more than 15.000 members in different sectors including retail, wholesale and tele companies. We have the following input and suggestions: We share the European Commission’s concern about the online sale of counterfeit, dangerous or illegal products putting citizens at risk and harming law-abiding legitimate business. The problem is particularly serious in regard to traders from non-EU countries selling via online platforms or market places or from their own webshops – often in one of the EU official languages, which makes it difficult for consumers to see, that they are trading with a non-EU trader and makes it impossible to enforce. This situation undermines the internal market. We also share the concern about the spread of illegal content online such as child sexual abuse material og illegal hate speech. We support the approach in option 2. We agree, that there is a need to modernise and clarify the e-commerce directive in order to harmonise the responsibilities and obligations of online platforms. There is a common misunderstanding that article 14 in the e-commerce directive gives platforms and online marketplaces an automatic exemption from liability just because they are platforms or online marketplaces. This assumption runs counter to the wordings of the recitals and the relevant articles in the directive and to the jurisprudence of the ECJ. It is in our view of utmost importance, that this misunderstanding is put to an end. The revision of the e-commerce directive should clarify what characterise a passive intermediary and which activities and involvement makes the platform or online marketplace active. Therefore, the definition of active and passive is crucial. For your information we attach an assessment from Wiggin law firm in Brussels on the interpretation of the E-commerce directive regarding online marketplaces selling tangible goods. The underlying legislation defining the obligations of economic operators differ from sector to sector. An example is the EU product safety regulation that set very clear criteria for responsibilities for the different economic operators. The EU marketing and consumer legislation is the same. However, addressing the issue of e.g. illegal hate speech is not as clear and it always other pieces of legislation. It would be beneficial to clearly define the responsibilities of platforms and content owners. The wording is currently vague and leads to uncertainty. We are therefore concerned about the “one-size-fits-all”-approach to online platforms. We believe, that online platforms and marketplaces should be regulated after the same rules that apply for other businesses engaging in the same type of activities. We encourage the Commission to set up criteria’s relating to the sector in focus. We strongly support an increased focus on enforcement. Here it is important, that it is possible to enforce even though the trader is located outside the EU. This is another reason why platforms should be held responsible and liable, if they are actively involved in the activities on the platform and act on behalf of non-EU operators.
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Response to Digital Services Act package: ex ante regulatory instrument of very large online platforms acting as gatekeepers

30 Jun 2020

The Danish Chmaber of commerce have the following input and suggestions: To remain competitive, retailers and wholesalers need a regulatory framework that supports strong European retail and wholesale ecosystems in a digital environment and gives them legal certainty and incentives to invest in robust omnichannel strategies. This framework must enable EU authorities to enforce EU rules towards all players on the European market – including non-EU traders who increasingly target European consumers. This is necessary in order to create a level playing field and ensure consumer safety in the internal market. This initiative concerns the large online platforms acting as gatekeepers. However, it is unclear what is understood with this. It is is essential that it is made clear what is understood by a “plat-form acting as a gatekeeper”. It is important that this initiative is coordinated with the initiatives concerning a revision of the market definition and the criteria for dominant position in the competition law. Regarding the policy options the IA mentions a revision of the Platform-to-Business Regulation. This enters into force in July 2020. It therefore seems premature to revise the framework before being able to judge its effectiveness in improving the transparency of business relationships online. We recommend waiting until its effects can be assessed before considering any update or extension of this regulation. We do, however, support efforts to monitor the impact of the Regulation, collecting knowledge and insights. We support more focus on enforcement and agree that it must be coordinated on EU level in or-der to tackle the cross-border platforms. We do, however, believe these should be based on the existing instruments in the competition law and we see no need to develop new competing tools and institutions. We are concerned that e.g. setting up a new regulatory body could create over-laps and inconsistent enforcement. DG COMP are already having market investigation authority and should play a key role in addressing structural failures in existing markets. We cannot support the proposed idea of a blacklist. These have a tendency of either being outdat-ed quickly or allowing all activities not mentioned. Option 3.b mentions adopting tailor made remedies that will allow authorities to set up specific obligations and requirements towards the platforms. The option is not described clearly. It is important to have safeguards ensuring that businesses are not forced to reveal confidential information crucial to their business model, unless it is proportionate and clearly described in the legislation. In general, we find that such tailormade interventions that limits the free market should only be considered towards platforms that have a very dominant position and are considered an “essential facility”.
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Meeting with Kim Jorgensen (Cabinet of Executive Vice-President Margrethe Vestager)

7 Feb 2020 · Digital policy

Response to Climate Law

6 Feb 2020

The Danish Chamber of Commerce supports the climate ambition as set out in the European Green Deal as well as the proposed European Climate Law. Ambitious goals are important in order to set the direction and hence the Danish Chamber of Commerce supports increasing the EU’s 2030 GHG target to at least 55%. At the same time, it is crucial – also for continued popular support – that cli-mate action supports future economic growth and a competitive business life. For an optimal procedure it’s crucial that the legislature continue to have constant sparring with key stakeholders from business and NGO community. Furthermore, it is also crucial for the Danish Chamber of Commerce that the climate policy leads to real reductions in global greenhouse gas emissions, and not simply to relocate emissions outside the Union. The global climate effect of EU initiatives shall be net positive. Relocation of emissions to third countries will also not be in harmony with the goal set forth in the Paris Agreement of keeping the global temperature rise at 1.5 degrees. In order to ensure real global reductions, one should be obliged to consistently calculate the global net effect of climate change measures within EU. This means, that changed greenhouse gas emis-sions outside the EU as a result of climate action within the EU should be considered and offset in the effect of these climate measures. Moreover, many of the climate solutions of the future are found through increased sector integra-tion and through the development of a circular economy. We need to break down silos and think in systems. Both system thinking and sector integration are best supported in a single climate action plan.
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Meeting with Yizhou Ren (Cabinet of Commissioner Margrethe Vestager)

24 Oct 2019 · Meeting to discuss the "Commission's state aid enforcement policy on tax cases"

Response to Enhancing Market transparency in the agri-food chain

18 Jun 2019

The Danish Chamber of Commerce supports all measures which helps document how the food supply chain works in practice. We are however concerned by the Commissions new draft implementation regulation, as the draft in our view will not benefit to a greater understanding of food supply chain, nor fulfill the goals described by the Commission of helping the farmers achieve higher prices and provide the desired information on how prices are determined as agri-food products move along the food supply chain.
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Response to Informative guidance on the Regulation on the Free flow of non-personal data

13 Mar 2019

The Danish Chamber of Commerce welcomes the adoption of the Regulation on the Free flow of non-personal data. This Regulation has the potential to break down barriers to the free flow of data in the EU and ensure a real internal market for data processing. For this Regulation to have an impact, it is essential that it is implemented and enforced uniformly cross the EU. We therefore strongly support this guidance document, which can help both companies and authorities to understand and apply this regulation in combination with the GDPR. With regards to the specific aim of explaining the interplay between the Free flow of non-personal data regulation and the GDPR, we would like to reiterate our understanding of the legislation, that we would like to see reflected in the guidance. In essence, mixed data has to be protected in compliance with the GDPR, but not localized. The broad definition of personal data in the GDPR means that mixed datasets qualify as personal data. Mixed datasets should therefore be handled, collected, used, shared, etc. in compliance with the GDPR. The GDPR underlines that the “free movement of personal data within the Union shall be neither restricted nor prohibited” based on privacy concerns (art.1.3). While the spirit of the legislation of promoting the free flow of personal data is clear, the text is limited to privacy concern and does not address any other grounds, as that is outside of its scope. In practice member states can therefore still legally demand that personal data (and therefore mixed data) is localized in their territory based on non-privacy ground under the GDPR. This is where the Free flow of non-personal data regulation complements the GDPR for mixed data sets, as it bans data localization requirements of any kind, apart from requirements imposed for public security reasons, for non-personal and inextricably linked mixed datasets (art.2). Mixed datasets are hence covered by both regulations. This means that member states shall not impose localization requirements to store mixed data in their territory on either privacy or non-privacy grounds. Furthermore, if they impose or keep a data localization requirement for public security reasons this should be notified to the Commission and the final requirement should be made public (art.4.4). Our understanding is, that this applies to localization requirements for mixed datasets as well. It is very important to underline this in the guidance, along with the fact that the final free flow of non-personal data regulation also applies to public procurement. From a company perspective, it is essential that the guidance makes it clear that the Free flow of non-personal data regulation does not impose an obligation on companies to split mixed datasets and store the different types of data separately (recital 10). There is a good reason for that as such separation may be challenging, technically unfeasible or economically disproportionate. It is therefore up to the company to decide if it wishes to split datasets in case it is faced with a localization requirements, but in any event, the personal part has to be protected in compliance with the GDPR at all times. The roadmap does not specifically touch upon the codes of conduct (art.6). The Danish Chamber of Commerce would nevertheless like to use this opportunity to express our support for improving porting of data through pre-contractual disclosure, transparency regarding conditions and sharing of best practices.
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Response to Urban Mobility in the EU

18 Dec 2018

The Danish Chamber of Commerce has read the initiative on Urban Mobility and choses to refer to the feedback submitted by EuroeCommerce, which we fully support. We thank the Commission for opening this intiativ up for comments.
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Meeting with Friedrich Wenzel Bulst (Cabinet of Commissioner Margrethe Vestager)

28 Nov 2018 · Digital Single Market

Meeting with Stig Joergen Gren (Cabinet of Vice-President Andrus Ansip) and Confederation of Danish Industry and

6 Nov 2018 · DSM general, eCommerce, data, copyright

Meeting with David Boublil (Cabinet of Commissioner Pierre Moscovici)

4 May 2018 · Digital taxation and CCCTB

Response to Legislative proposal for an EU framework on crowd and peer to peer finance

26 Mar 2018

The Danish Chamber of Commerce and the Danish Crowdfunding Association welcomes and supports the initiative to implement a unified European wide regulatory framework for Crowdfunding Services Providers for Businesses. The overall goal of harmonizing crowdfunding regulation across EU member countries and thereby enable cross border activities is to be welcomed by many start-ups and SMEs, investors and platforms to boost access to capital and investment opportunity across Europe. We stress the importance of a uniform implementation of the regulation across the EU. However, there seems to be a lack of principal understanding of the funding eco system and the players in each step in the proposal. The proposal states “This initiative is part of the Commission's priority of establishing a Capital Market Union, which aims to broaden access to finance for innovative companies, start-ups and other unlisted firms”. The financial crowdfunding models (Equity og P2P lending) rarely is for start-ups – these companies are too early stage – especially for P2P lending. Crowdfunding is for growth companies and increasingly appeals also to more established SME´s which are entering series B and C funding rounds. Further it is stated that “Crowdfunding can thus provide an alternative to unsecured bank lending”. Whereas this may be correct for P2P lending then it is incorrect for investment crowdfunding (shares). Here the investor “invests” – and banks do not invest. Banks provide loans to cred-it worthy lenders. There is a general need for a much clearer division between P2P lending and investment crowd-funding in the proposal. The latter will be securities defined as shares, bonds and convertible bonds Therefore, in the case of bonds/convertible bonds there will be similarities to P2P lending as both are debt instruments. While we welcome the proposal, we recommend that a comparison between the existing requirements for an investment firm (execution only) and the proposal for crowdfunding platforms is carried out. Such a comparison may reveal that there are very limited differences between the two schemes, and hence the need for this proposal can be questioned. This proposals interaction with the proposed new regime for investment firms (COM(2017) 790 and COM(2017) 791) must be carefully considered, especially to avoid regulatory arbitrage because the benefits of being regulated as a class 3 investment firm could very well exceed the ones of being regulated as a crowdfunding service provider. It is surprising that there is no reference to the coming implementation of the European Growth Prospectus. This enables passporting of public offers of up to 5 million euro. The whole purpose of this prospectus is to enable cross border fund raising and crowdfunding platforms could play a pivotal role in achieving this. Lastly it is evidenced that the UK is the largest EU crowdfunding market. A major contributing factor is the legal requirement for banks to refer clients to crowdfunding platforms in case that funding applications are rejected. Such a compulsory referral should be implemented across the EU as platforms comes under ESMA supervision. The Danish Crowdfunding Association have been trying to establish a referral scheme locally in Denmark without success due to the lack of interest from the Danish Bankers Association mainly due to their perceived reputational risk. This should not be an issue if platforms come under ESMA supervision. Finally we strongly opposes that the proposal ban crowdfunding service providers from the opportunity to market ongoing and upcoming projects. This prevents potential investors from being alerted to projects that, for example, benefit their workplace, local area, etc. At the same time, there is a risk that projects will not be funded due to lack of knowledge. The marketing of crowdfunding projects is a central part of crowdfunding. Please see your detailed comments in the attached document
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Meeting with Margrethe Vestager (Commissioner)

19 Mar 2018 · EU Current Affairs

Response to Review of the appropriate prudential treatment for investment firms

12 Feb 2018

The Danish Chamber of Commerce feedback on the proposal for a Revised Framework for Investment Firms The Danish Chamber of Commerce welcomes the Commission’s proposal for a revised framework on the prudential requirements for Investment Firms. Investment firms play a vital role in facilitating investment flows across the EU and are an important part of the Capital Markets Union. Their services include investment advice, portfolio management and execution of orders. Investment firms differ from banks as they do not take deposits or provide loans meaning they pose less risk to markets, clients and themselves. The prudential requirements and supervisory arrangements should therefore be adapted to investment firms risk profiles and business models – instead of letting investment firms be subject to prudential rules developed for banks. While we support the idea of establishing an EU scheme to avoid fragmentation of the internal market, the proposals can be improved and clarified in several areas to be more risk sensitive and proportionate. Our key points with regards to the regulation are elaborated below. Class 3 small and non-interconnected investment firms (Regulation article 12): The Danish Chamber of Commerce generally welcomes the proposal to divide investment firms into three classes, each capturing different risk profiles. Class 3 firms - subject to the least complex regulation – are defined by the conditions set out in article 12 of the Regulation, among others that (a) AUM (assets under management) is less than EUR 1.2 billion. While we recognize that AUM is a risk factor to be taken into consideration when classifying investment firms, we generally find the proposed threshold too low and further ill-suited for the Danish low risk bond market. I.e. according to the proposal, bonds count towards the threshold in the same way as much more risky assets such as shares. The proposed threshold is not risk sensitive or proportionate as an investment firm dealing with bonds need much more assets under management to pose the same risks to markets, customers etc. compared to a firm dealing with shares or other high-risk assets. We therefore propose that the AUM-threshold in article 12 (1) (a) is raised and/or that a separate and higher AUM-threshold for bonds is introduced.
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Response to 2nd Data Package

18 Dec 2017

The Danish Chamber of Commerce welcomes the Commissions proposal on a regulation on the free flow of non-personal data in the EU. The regulation sets out a clear principle of freedom of data in the EU by prohibiting data localisation restrictions within the Union. We strongly support this principle and find the proposal from the Commission timely and balanced. Data localisation restrictions lead to suboptimal investments from cloud providers which can result in higher prices and have a negative impact on the environment. Furthermore they constitute barriers to start-ups and SMEs who wish to expand in the internal market. In the recent years the number of data localisation restrictions have been increasing and we therefore see a need for a EU regulation to ensure the internal market for non-personal data. While we appreciate the proposal from the Commission we do see room for clarification and practical improvement in several areas. Definitions In art.3 “data localisation requirements” are defined to cover laws and administrative provisions of the Member States. To avoid fragmentation when the regulation is implemented and enforced it should be clarified that this also includes laws and administrative provisions at regional and local level. This is particularly relevant in relation to public procurement, which we understand to be covered under the term administrative provisions. Exemptions Art.4.1 prohibits datalocalization requirements unless they can be justified on grounds of public security. The term public security has however not been defined in the proposal and risks leaving much room for interpretation to the individual member states. We suggest that this term is either replaced by national security which is narrower, or elaborated in a recital with reference to relevant case law. Furthermore, it is essential that public data is kept in scope. Transparency We welcome the requirement on member states to publish a list of data localisation requirements in force on their territory, and provide the Commission with a link to this list. It would however be more helpful for companies to have one consolidated list available in the official working languages of the EU. This would ensure transparency and alow companies of all sizes to quickly get an overview of the localization requirements in all member states. We recommend that this requirement is added to art.4. Portability Art.6 concerns the development of a code of conduct on porting of data. We agree with the Commission that it is very important, that professional users of cloud services can port their data. We can support the development of a code of conduct, but we do however not see any need for regualtion on this issue, as it is agreed in the contract between cloud providers and professional users. Regulation in this field would be against the contratual freedom and could potentially have negative consequenses for both users and providers in the long run. We therefore urge the co-legislators to keep this provision to the encourgament of an industrydriven Code of Conduct. We would however like to see further details ensuring that providers and users of different sizes are involved in the development of the Code. To ensure wide inclusion of stakeholders and a result of high quality we would furthermore recommend extending the deadline for developing the Code.
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

5 Dec 2017

The Danish Chamber of Commerce welcomes the Commission’s proposal for a new Cybersecurity Act. We support the extension of resources and mandate to ENISA, but our main interest lays within title III of the proposal concerning the EU cybersecurity certification scheme. While we support the idea of establishing a EU scheme to avoid fragmentation of the internal market, the proposals can be improved and clarified in several areas to be more functional also for SMEs. Our key points are elaborated below. Voluntary approach: The Danish Chamber of Commerce welcomes that the Commission has tabled a proposal on voluntary certification. The technological developments in this field are constant and the scheme must be flexible enough to accommodate these developments. A voluntary certification gives companies that invest in cybersecurity a way to signal this to the market and gain a competitive advantage. We urge the co-legislators to retain a voluntary approach to avoid stifling innovation in this fast-moving field. Interplay with existing schemes and regulations: Article 49 is very clear in establishing that national certifications shall cease to produce effects when a European certification has been adopted on the same issue. We do support the idea behind this provision, however it needs to be clarified how existing certificates under national schemes will be transferred to the European scheme. Companies, and especially SMEs, investing in certification need to be certain that their investments will also be recognized under the European scheme. Furthermore, it is essential that it is ensured that the European certification scheme is accessible for SMEs, both in terms of administrative burdens and costs. If the European scheme becomes too heavy there is a risk of placing SMEs at a competitive disadvantage not only at the internal market but also on their national markets, as the national certifications will cease to exist. Today sector and product specific regulation apply to for instance medical devices. These regulations ensure the security and cybersecurity of the products concerned. It has to be clarified how the proposed European cybersecurity certification scheme will interact with the sector specific regulations. This is particularly relevant in connection to the assurance levels in art.46. While we welcome the approach with different assurance levels it needs to be elaborated what the three levels entail. Involvement of businesses: In art.44.2 it is stated that ENISA shall consult all relevant stakeholders. However, it is only the Commission that can request ENISA to establish a scheme and the article is more elaborate on how the European Cybersecurity Certification Group can provide expert advice, than on how stakeholders can do the same. Businesses are at the forefront of the technological developments in cybersecurity and any cybersecurity certification should be business driven. It is therefore necessary to clarify and extend how stakeholders will be involved in the process, both before and after the Commission request ENISA to establish a certification scheme. Clarifying this would also increase the transparency and legitimacy of the certification schemes. Reliance on international and European standards: The proposal briefly mentions that the European certifications should be in line with international and European standards in the field. This point is essential and it should be made clearer in the proposal how this will be ensured in practice. Duplication of efforts between the different regimes shall be avoided, and European certification schemes shall not lead to market access barriers. Clarifying scope: With the current formulation, it is unclear what the scope of the proposal is. In most instances the text refers to ICT products and services, however art.43 seems to be more focused on processes. With an unclear scope, it is difficult to evaluate if the proposed set-up is fit for purpose.
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Response to Legislative proposal for an EU framework on crowd and peer to peer finance

24 Nov 2017

The Danish Chamber of Commerce welcomes the opportunity to provide feedback to the inception impact assessment. We and our member association the Danish Crowdfunding Association have followed the development of the crowdfunding market and crowdfunding regulation in the EU. In Denmark the authorities have developed a guidance on crowdfunding, which very clearly describes how the existing consumer- and financial regulation applies to the different types of crowdfunding. This model is functioning very well and ensures clarity for both businesses and consumers. However, as recognized by the Commission several Member States have in the resent year developed bespoke sector regulation for crowdfunding. This results in a fragmentation of the market, to the detriment for both investors and the companies, especially SMEs and start-ups benefitting from crowdfunding. Furthermore experience shows, that the platforms which operate cross-border are more successful and have a longer life-time than national platforms. Crowdfunding is per definition a global crow-border concept. It is therefore unfortunate, that national legislation create challenges for the cross-border platforms. While the Danish approach shows that crowd-funding can be covered by existing legislation, it is also necessary to safeguard the internal market and avoid fragmentation. The Danish Chamber of Commerce therefore supports option number 3 in the IIA: A comprehensive EU approach – treating crowdfunding platforms like regulated trading venues or payment institutions. Especially we support the idea of a license guaranteeing that crowdfunding platforms can passport their business into all Member States in the EU.
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Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans)

10 Nov 2017 · Unfair Trading practices in the food supply chain

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

30 Oct 2017 · Future of Europe

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

18 Oct 2017 · Unfair Trading Practices

Response to Initiative to improve the Food Supply Chain

22 Aug 2017

The Confederation of Danish Enterprise does not support a common legislative framework for Unfair Trading Practices (UTPs) in the food supply chain. We believe that regulating contractual agreements between the different stakeholders in the chain will not be effective in reaching the Commissions stated goal of the legislation – helping to increase disposable farm income indirectly so as to not include actual subsidies via the CAP. As suggested in the IIA – the main challenge is the bargaining power of the farmers in the supply chain and the banning of specific contractual practices will in no way address or remedy this. Organisation or other such initiatives may help farmers bargaining position, but regulation contractual freedom will not. It will however hamper flexibility and contractual freedom throughout he food supply chain. Furthermore retailers has very few contracts directly with farmers (estimated less than 5%) and instigating specific contractual relationship between these two parties (or elsewhere in the chain) will do next to nothing to enhance the earnings om farmers. A proportional and targeted response to the challenges (if any such initiatives were to be proposed) should focus on the first contract (between farmers and the fist buyer) – since the goal is obviously to ensure a higher disposable income for this group. Including the whole supply chain in legislation on contractual agreements would be disproportionate. It is also worth noting that the countries that already have set in place such legislation does not seem to be particularly successful in reaching their goals - elevating an basically ineffective instrument to the European level is unlikely to achieve better results. We call on the Commission according to the principles of better regulation to thoroughly examine if existing regulation has in fact been effective and by extension if European legislation is likely to be effective.
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Response to Review of ENISA Regulation and laying down a EU ICT security certification and labelling

3 Aug 2017

The Confederation of Danish Enterprise would like to thank the Commission for the opportunity to provide feedback to the IIA on ENISA and ICT certification and labelling. Cybersecurity is an issue of vital importance in our increasingly digitalized economy and society. We therefore welcome the Commissions focus on the topic, and would like to express our support to option 2 in the IIA with regards to ENISA. The agency needs to be enhanced to fulfill its role under the NIS Directive and ensure better cooperation between national cybersecurity authorities to face the increased cyber threat. With regards to a EU certification and labelling scheme the Confederation of Danish Enterprise do understand and share the Commissions desire to foster a higher level of security for ICT products, but we are not convinced that a legislative initiative will be the most effective and proportionate means to achieve this goal. The technological developments in this field are very fast and we fear that a EU legislative certification and labelling scheme could result in false perceptions of security amongst consumers and stifling of innovation. Any security requirements should be proportionate to the risk a connected product constitutes, and a one-size-fits all approach could have significant drawbacks on the uptake of the IoT due to disproportionate increases in prices. The Confederation of Danish Enterprise therefore wish to express our support to option 1 in the IIA where voluntary industry-led initiatives are supported and promoted. We think this is the best way to ensure flexibility for the industry to continuously develop new and safer technologies and products, while at the same time safeguarding transparency for the consumers. Such initiatives should furthermore be fully aligned with international initiatives and standards in the field. Furthermore, we would encourage the Commission to foster mutual recognition of national certification schemes in the EU in order to reduce administrative burdens and improve the functioning of the single marked for ICT product.
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Response to Targeted revision of EU consumer law directives

12 Jul 2017

At the Confederation of Danish Enterprise we are very pleased, that the IIA take the experience and burdens that traders meet into account. This is important to strike a balance that in the end - will yield the best results for both consumers and traders. We have the following remarks: - We confirm that traders face unnecessary administrative burdens due to requirements to provide information at the pre-contractual stage which in some cases overlap requirements from other directives, in some cases are repetitive and in some cases, does not fit with practical reality. We encourage the Commission to pursue to simplify this. - We can confirm, that traders risk financial loss because the CRD require traders to reimburse consumers without first having the possibility to inspect the returned goods. We encourage this to be changed. - We can confirm, that traders face administrative burdens and financial loss because the present wording of the CRD allows consumers to withdraw even when they have used or damaged the good. Traders can calculate the diminished value, but this does not protect traders, since they good have no value for them when it is used, and the administrative burdens of figuring out what to deduct and educate their staff to calculate it will far outweigh any recuperation of money and thus only add to their loss. Thus, the practice has become to simply return the full amount to the consumer, even though that was clearly not the intention of legal text, which apart from being expensive also seems rather unfair and unbalanced. We strongly encourage the Commission to change this rule without further investigation. It makes no sense to give consumers a right to return used and damaged products. It only makes goods more expensive and makes it harder for SME’s. - We support more transparency on sale via platforms – as well as more transparency on free online services. However, it should be done in a practical and simple way. - We don’t agree that a self-reported consumer-right related problems can be taken as documentation of infringements of consumer rights. Questionnaires recounting consumer’s perceptions does not prove that an infringement has occurred. - We encourage the Commission to review the perspective on the effect of penalties. It is fair and balanced that penalties can be applied for breaching the rules and that these are both deterrent and proportionate, but what drives traders in 2017 is not mainly the fear of penalties from public authorities – it is the fear of consumers “voting with their feet”. Today consumers use reviews, social media, online storms of critique etc. etc. to share their experiences and this is a far stronger deterrent than penalties for everyone but the most hardened rogue traders. - We do however encourage a stronger and more uniform enforcement of the present rules and encourage the Commission to follow up, if national enforcement bodies don’t enforce the common consumer protection rules. The CPC-regulation is a good start in this regard. Introducing new legislation before the present rules are enforced seems disproportionate. - We warn against introducing individual remedies for consumers, who have faced unfair commercial practices. This could result in excessive administrative burdens and will be very complicated to regulate. We strongly believe, that a system like the one in the USA serves lawyers more than the consumers. If consumers have been lured into buying something that does not live up to the commercials, they already have the possibility to pursue it due to "lack of conformity". - This consideration also applies for the proposal of regarding green claims. Although we acknowledge the VW case, we warn against legislation based mainly on this example. We don’t see any evidence, that misleading green claims should be a frequent problem for European consumers. In the VW case consumers have remedies to pursue their rights due to lack of conformity.
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Meeting with Kaius Kristian Hedberg (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

31 May 2017 · unfair Trading Practices

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

25 Apr 2017 · Better Regulation and EU internal market policy

Meeting with Margrethe Vestager (Commissioner)

27 Jan 2017 · EU Current Affairs

Meeting with Marlene Madsen (Cabinet of Vice-President Jyrki Katainen)

8 Jun 2016 · CMU

Meeting with Jonathan Hill (Commissioner)

4 Mar 2016 · CMU

Meeting with Friedrich Wenzel Bulst (Cabinet of Commissioner Margrethe Vestager)

27 Jan 2016 · Geoblocking

Meeting with Anna Herold (Digital Economy)

26 Jan 2016 · geoblocking

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

30 Nov 2015 · Geo-blocking

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

17 Sept 2015 · Introductory meeting

Meeting with Margrethe Vestager (Commissioner)

2 Sept 2015 · Discussion on Current EU Affairs

Meeting with Jonathan Faull (Director-General Financial Stability, Financial Services and Capital Markets Union)

3 Jun 2015 · Impact for SME's by the Capital Markets Union

Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager)

28 Apr 2015 · Digital Single Market