The LEGO Group

The LEGO Group is a Danish toy company focused on inspiring children through play while pursuing zero environmental impact.

Lobbying Activity

Meeting with Werner Stengg (Cabinet of Executive Vice-President Henna Virkkunen)

18 Nov 2025 · Protecting minors online

LEGO Group Urges EU to Incentivise Circular Business Models

5 Nov 2025
Message — LEGO Group calls for all EU laws to incentivise circular models, including updates to VAT and product-specific rules. They also seek harmonised waste criteria and a technology-neutral approach to recycling.123
Why — This would eliminate regulatory barriers that make circular toy business models difficult to implement.4
Impact — National regulators would lose the authority to set disparate waste classifications across Member States.5

LEGO Group urges harmonised enforcement over new digital laws

24 Oct 2025
Message — The LEGO Group recommends focusing on ways to harmonise and improve enforcement through guidance. They suggest building upon current guidelines for minors to ensure a safe digital environment. New rules should only be introduced if existing coordination and guidance are demonstrably insufficient.123
Why — This approach reduces the complexity and costs of managing diverging regional digital requirements.4
Impact — Member States lose autonomy to implement stricter national measures, which the company views as fragmentation.5

Meeting with Stephane Mail Fouilleul (Head of Unit Taxation and Customs Union) and AIM - European Brands Association and

17 Oct 2025 · 12th Joint meeting of customs and right holders on customs enforcement of intellectual property rights

Meeting with Jessika Roswall (Commissioner) and

15 Oct 2025 · To discuss REACH revision

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

14 Oct 2025 · Exchange of views on circular economy policy and batteries

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

14 Oct 2025 · attached

LEGO Group Urges Safety by Design in Cyberbullying Plan

29 Sept 2025
Message — The organization calls for industry players to embed safety by design when developing digital services and requests a unified definition of cyberbullying aligned with international standards. They also recommend that the EU recognize and promote digital literacy resources for families.123
Why — The proposal promotes their existing business practices and educational resources as industry-leading standards for digital child safety.45
Impact — Smaller digital service providers may struggle to implement costly human moderation and pre-moderation systems recommended by larger players.6

Meeting with Valdis Dombrovskis (Commissioner) and

22 Sept 2025 · SIMPLIFICATION

LEGO Group backs EU rules for recycled plastic content

19 Aug 2025
Message — LEGO supports the fuel-use excluded approach and strict chemical traceability. They recommend adding clear definitions to prevent overcompensation in complex products. The group urges fast adoption to provide investment certainty for manufacturers.12
Why — A robust standard provides legal clarity to enable investments in sustainable plastic production.34
Impact — Brands using less rigorous accounting would lose the ability to make sustainability claims.5

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

18 Jul 2025 · Batteries

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

3 Jul 2025 · Decarbonisation challenges for Industry

Meeting with Christel Schaldemose (Member of the European Parliament)

24 Jun 2025 · Commerce

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Novo Nordisk A/S and

13 Jun 2025 · Debate on EU competitiveness

Meeting with Nicolo Brignoli (Cabinet of Commissioner Valdis Dombrovskis)

3 Jun 2025 · Simplification

Meeting with Christel Schaldemose (Member of the European Parliament)

12 May 2025 · online markedspladser, børns rettigheder online og grønne omstilling

Meeting with Maroš Šefčovič (Commissioner) and

26 Feb 2025 · Trade policy and customs reform

Response to Single Market Strategy 2025

31 Jan 2025

The LEGO Group welcomes the opportunity to respond to this consultation. A well-functioning and robust European Single Market (SM) is critical for our companys innovation and manufacturing, as well as to our consumers, in Europe. Below are some brief examples of how the SM can be strengthened by removing existing barriers in the areas of product and packaging rules, digital, consumer and intellectual property rights. Further input can be found in the attached PDF. Fragmented national rules on labelling of products and packaging make it difficult to take advantage of the economies of scale within the SM, and dealing with fragmenting legislation is costly and burdensome for companies, ultimately not benefiting EU consumers. Recent legislation such as the Ecodesign for Sustainable Products Regulation and the Packaging and Packaging Waste Regulation take important steps to harmonise such rules within the EU. We encourage the Commission to use all available tools to ensure that Member States respect the common EU rules and remove national obligations that duplicate or contradict EU-level legislation on products and packaging. Similarly, we want to emphasise the importance of the SM dimension in upcoming EU environmental legislation, such as the Circular Economy Act. Greater harmonisation of waste classification would support companies seizing opportunities within the circular economy to the benefit of both the environment and Europes security of supply of (secondary) raw materials. From a digital perspective, the implementation of the ePrivacy Directive has led to significant fragmentation caused by the discretion of each Member State evaluating what is strictly necessary for cookies and trackers. This leads to companies not being able to implement a single approach for unconsented tracking across the EU. As Member States implement the EU Accessibility Act, companies are currently experiencing that different EU countries set different minimum standards for accessibility while also maintaining different definitions of in scope services. As the success of accessibility adaptions in meeting the needs of diverse user groups is dependent on consistency across the EU, having a single rule set with one interpretation of what is in-scope would be a vast improvement. Internal harmonisation is the foundation of a robust SM, but safeguarding its integrity also requires stronger enforcement regarding products that enter the European market from third countries. Non-compliant products as well as illicit counterfeit or pirated goods weaken the trust in EU product legislation, which can lead to Member States seeking to alleviate perceived issues through national legislation. Illegal imported products also put fully compliant European manufacturers at a competitive disadvantage. As such, we recommend further harmonisation of the EUs customs policies through the Union Customs Code. Furthermore, it is critical for the Commission to monitor and support as needed the timely implementation of the EU Digital Services Act, especially regarding the process of designating trusted flaggers in each Member State. This status is critical to tackling illegal content, including illegal products, on online services available to consumers in the EU and should be awarded to organisations based on their application meeting the DSA conditions. See the attached document for more information.
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Meeting with Brando Benifei (Member of the European Parliament, Shadow rapporteur)

28 Nov 2024 · Meeting on the TRS

Meeting with András Tivadar Kulja (Member of the European Parliament, Shadow rapporteur for opinion)

18 Nov 2024 · Toy safety

Meeting with Anna Stürgkh (Member of the European Parliament, Shadow rapporteur)

14 Nov 2024 · Toy Safety

Meeting with Sigrid Friis (Member of the European Parliament)

18 Oct 2024 · Lego's prioritizes for the new EP

LEGO Group advocates for child-centric digital design guidelines

30 Sept 2024
Message — LEGO recommends incentivising a child-centric digital design of technology that promotes childrens well-being. They suggest guidelines include a focus on media literacy and empowerment. Age verification solutions must be proportionate to the risk profile of the service.123
Why — This allows LEGO to minimize compliance burdens by arguing their platforms have lower risk profiles.45

Meeting with Sara Cerdas (Member of the European Parliament, Rapporteur for opinion)

14 Nov 2023 · Reunião Lego

Meeting with Arba Kokalari (Member of the European Parliament) and Toy Industries of Europe

9 Nov 2023 · Safety of toys (staff level)

Response to Revision of the Toy Safety Directive

26 Oct 2023

The LEGO Group welcomes the Commissions proposal to review and modernize the EUs toy safety legislation framework with the new Toy Safety Regulation. As we note in our attached feedback document, we see various opportunities for more efficient enforcement and compliance, as well as various points that will need to be clarified.
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Meeting with Christel Schaldemose (Member of the European Parliament)

18 Sept 2023 · toys' directive

Meeting with Pablo Arias Echeverría (Member of the European Parliament, Rapporteur) and ITI - The Information Technology Industry Council

21 Jun 2023 · Virtual Worlds

Meeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)

4 May 2023 · Discussion and follow up on proposed amendments: fruitful discussion on reuse and repurpose of packaging.

Response to Virtual worlds, such as metaverse

3 May 2023

[read full feedback and links in uploaded document] The LEGO Group welcomes the opportunity to provide feedback to the European Commission's call for evidence. We believe this is a critical initiative to recognise children as a distinct group of users and content creators of virtual worlds and incentivise a child-centric design of the next wave of digital innovation, respecting children's rights and promoting their well-being. Our submission includes the following recommendations: 1. The forthcoming communication must explicitly recognise and consult with children as a distinct group of users and content creators of virtual worlds and in alignment with other EU laws and guidelines; 2. Seize the opportunity of the next wave of digital innovation to stimulate and incentivise child-centric innovation in support of children's rights and promoting their well-being; 3. The future monitoring instruments must include child specific indicators to better understand the impact of virtual worlds on children's well-being; 4. Virtual worlds' risks and opportunities must be communicated to children in a child friendly manner on an on-going basis; 5. A systematic multi-stakeholder global approach and exchange to develop and design virtual worlds is key. At the LEGO Group, whenever we engage with children, we always put their best interests first by respecting and supporting their rights and well-being. We believe that digital technology has tremendous potential to support the development of these skills and children's growth more broadly through quality digital learning through play experiences. That is why digital play has become a cornerstone of our 2032 LEGO® Brand Vision as we aspire to become a world leader in providing quality and joyful responsible digital play to children. Globally, the LEGO Group has a long-standing partnership since 2015 with UNICEF to jointly promote the Children's Rights and Business Principles a 10-point framework that sets out actions companies can take to respect and support children's rights, and to integrate children's rights considerations across our operations. In 2020, we jointly established an international research collaboration entitled Responsible Innovation in Technology for Children (RITEC) supported by the LEGO Foundation, and exploring how businesses and policymakers can create a digital world that prioritises children's well-being. The first phase report prioritised the voices of children and it revealed a newly developed well-being framework with eight child-centric well-being outcomes as informed by the consultations with children around the world. This is a first step towards helping tech developers and policymakers deepen a collective understanding of how digital experiences can positively influence aspect of child well-being, and develop the practical tools to put the well-being of children at the centre of digital design and digital play, as well as the laws that govern them. The LEGO Group also joined forces with Epic Games in a partnership to create a digital play experience for the virtual worlds such as the metaverse, and to ensure that every child can be a celebrated, confident creator through digital play. If the virtual worlds are to fully benefit and empower citizens, and to explicitly recognise children as distinct group of users and content creators, the initiative must lay the foundations to incentivise the design of virtual worlds in a way that benefits children and their well-being in a digital era. This means from the outset ensuring that there is consideration of the benefits of virtual worlds to children's rights and well-being, alongside the mitigation of risk.
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Meeting with Asger Christensen (Member of the European Parliament)

25 Apr 2023 · Kids safety toys

Meeting with Dubravka Šuica (Vice-President)

25 Apr 2023 · The implementation of the EU Strategy on the rights of the child

Meeting with Thierry Breton (Commissioner) and

25 Apr 2023 · Revision of the Toys Safety Directive; chips; supply chains

Meeting with Margrethe Vestager (Executive Vice-President) and

25 Apr 2023 · EU digital and industrial policy

Meeting with Morten Løkkegaard (Member of the European Parliament)

25 Apr 2023 · LEGOS fokus er på at sikre børns interesser og rettigheder bedst muligt, både når det handler om legetøjssikkerhed og ikke mindst sikkerheden i digitale legemiljøer.

LEGO Group Urges Harmonised EU Rules and Digital Labels

24 Apr 2023
Message — The LEGO Group supports replacing national laws with a single EU Regulation to stop market fragmentation. They request material-specific recycling criteria and a shift toward digital labels to streamline global supply chains.12
Why — Harmonisation would eliminate the need for market-specific packaging, reducing production waste and costs.3
Impact — Consumers without digital access might struggle to find sorting instructions if physical labels are simplified.4

Meeting with Christel Schaldemose (Member of the European Parliament)

24 Apr 2023 · toy and online safety for children

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

5 Apr 2023 · Preparatory meeting for meeting between CEO of LEGO and Commissioner Breton: chips act, metaverse, revision of the Toys Safety Directive

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Veolia Environnement and

21 Mar 2023 · Packaging Waste

Meeting with Virginijus Sinkevičius (Commissioner) and

18 Jan 2023 · EU ambitions to tackle plastics waste and International Plastics‘ Agreement

Meeting with Mariya Gabriel (Commissioner)

18 Jan 2023 · Erasmus impact Innovative education

Meeting with Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

10 Jan 2023 · Europe fit for digital age, chips act.

Meeting with Biljana Borzan (Member of the European Parliament, Rapporteur) and Electrolux Home Products Europe

12 Oct 2022 · Empowering consumers for the green transition

Meeting with Bart Groothuis (Member of the European Parliament, Shadow rapporteur)

29 Sept 2022 · APA meeting on Chips Act

Response to Safety requirements to be met by European standards for certain children products (excluding toys)

1 Sept 2022

The title of the initiative is “safety of children (excluding toys) – requirements to be met by European standards”. This seems to make it clear that toys are excluded. However, the recital 5 creates some uncertainty around this: (5) The rules on the safety of toys are laid down in Directive 2009/48/EC of the European Parliament and of the Council . However, Directive 2001/95/EC applies to the aspects and risks or categories of risks not covered by Directive 2009/48/EC. This Decision should therefore include requirements to be met by European standards for children's products and related products insofar as risks or categories of risks are not covered by Directive 2009/48/EC. The way we read and understand it, the recital appears to indicate that ESOs may include requirements for toys in standards that are not for toys, if it is deemed that certain risks are not addressed by 2009/48/EC. This is confusing since the Toy Safety Directive was designed to be an all-encompassing vertical safety legislation. CEN TC 52 and CLC TC 61 are the two committees that under standardisation requests draft standards that support the Toy Safety Directive. The recital does however seem to indicate that other technical committees (for non-toy products) are permitted/encouraged to add extra requirements for toys, beyond what is found in 2009/48/EC and its supporting harmonised standards, in case these non-toy products have a toy feature. If our understanding of the recital is correct, we feel it is important to avoid confusion by ensuring that the scope of the draft Commission decision clearly states that toys are excluded. Furthermore, we believe that Recital 5 should be amended by adding the following text: “Toys covered by Directive 2009/48/EC are out of scope of the standards covered by this Decision.”. Without this important clarification, it could lead to requirements for toys being included in standards outside of the EN 71 series and potentially EN 62115. When such non-toy standards are referenced in the OJEU as supporting the GPSD, these references are likely to cause confusion for toy manufacturers, and for enforcement bodies attempting to assess conformity. Toy manufacturers should be able to trust that the toy-specific, harmonised standards, the references of which have been published in the official journal of the EU, will include the relevant requirements for their products (toys). In the case where a toy safety standard (which has been referenced in the OJEU) is considered to not cover all relevant risks, the relevant technical committee should be requested to update that standard. The potential short-comings of a toy safety standard should not be “compensated” by introducing “extra” requirements in non-toy standards. Additionally, in case the Toy Safety Directive is found to not cover all relevant risks for toys, the solution cannot be that non-toy standards are used to cover such gaps.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

11 May 2022 · CSAM, Digital Decade, Artificial Intelligence Act, Children’s well-being, BIK+

Meeting with Christiane Canenbley (Cabinet of Executive Vice-President Margrethe Vestager), Lucia Caudet (Cabinet of Commissioner Thierry Breton), Pierre-Arnaud Proux (Cabinet of Executive Vice-President Margrethe Vestager)

3 May 2022 · Semiconductors

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

It is our understanding that the European Commission is considering an EU approach to sorting packaging waste and labeling in an upcoming legislation. This is a very positive development which the LEGO Group supports. We also understand that some aspects of a future EU approach might be detailed during the revision of the Waste Framework Directive. We are concerned that this would be too late as the issue of the fragmentation of the internal market for packaging needs to be addressed now. Member States need to pause with national sorting and labeling requirements until a common approach is found at the EU level. The LEGO group operates with a global supply chain and does not design packaging specific to each market. Therefore, we have two iterations of our packaging: one for North America and one for the rest of the world. It is also our experience that adding a logo and some text to meet the obligations of one market raises concerns by enforcement bodies in other countries. In order to mitigate the issue, we deliberately have to translate text in several languages to ensure the free circulation of our packaging across Europe. A common approach will give legal certainty and will benefit the environment and industry.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

To whom it may concern, Please find feedback attached. Kind regards
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Response to Youth Action Plan in EU external action

14 Oct 2021

The UN Convention on the Rights of the Child stresses the importance to empower children to become agents of change on matters that can affect them. The LEGO Group wants to see children at the heart of the agenda to rebuild their countries post-COVID. The LEGO Group is calling on policy makers to ensure the interests of children are a central priority and to give them a voice on some of the biggest challenges that the world is facing. Post COVID 19, we believe that education should be at the core of the build-back-better agenda in order to serve the rights and interests of children. We believe that it is essential that children are equipped with the agency and skills that they need to make positive changes both now and in their future lives and careers. To be able to thrive in today’s society, children need to develop a breadth of skills to be prepared for jobs that have not yet been created, to tackle societal and environmental challenges that we cannot imagine, and use technologies that have not yet been invented. As such we view it as critical that children are given greater access to holistic, high quality climate education, providing them with not only knowledge and skills but also attitudes and values that can guide them towards responsible action, and they need opportunities to develop their creative ingenuity to help deliver a greener future. The LEGO Group recommends that the future strategy should consider how to best engage with children. At the LEGO Group we believe that hands-on playful engagement will be an essential part of this, to not only support essential skill development but to also facilitate a child’s learning of the world around them, and to help them explore topics such as sustainability in ways that are meaningful to them. More information attached.
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Response to Online and distance learning in primary and secondary education

11 May 2021

At the LEGO Group we believe that whilst the COVID-19 pandemic has been a period of significant challenge for children’s education, it is also an opportunity to catalyse the education reform needed to build more equitable and resilient education systems. Such ambition is reflected in the commitments of the Digital Education Action Plan and the EU Strategy on the Rights of the Child and we strongly welcome these initiatives and the actions set out within them. Such reform must take a holistic view. We believe that what children are taught, and by extension, how they are assessed is a critical component of this holistic approach. Curricula should meet the individual needs of learners, including equipping them with the breadth of skills needed to thrive in the 21st century. In addition, consideration of how children are taught and what new approaches to learning might best meet children’s needs is also essential. This was recognized in the 2019 Resolution on High Quality Early Childhood Education and Care Systems, which acknowledged the importance of play to support holistic teaching and learning solutions. Understanding the role different approaches, including play-based learning, can have in facilitating children’s development will help ensure education systems deliver meaningful learning experiences that are appropriate for pupils of different ages, with different learning needs and in different learning environments. Given the need for a broad approach we are strongly supportive of the aim of proposed Council Recommendation as stated in this Roadmap “to support Member States in adapting their school education systems to be more flexible and inclusive of a broad range of learner needs, changing circumstances and pedagogical approaches”. We consider the inclusion of both physical and digital playful learning to be an essential element within this. Playful learning helps children learn about the world around them and deepens their understanding and application of key 21st century skills. Realizing the potential of blended learning models, and more broadly of education systems to be adaptive to the individual needs of learners will require systemic level action. Digital learning requires funding to ensure all have adequate access to internet connections and suitable equipment. Furthermore, it is essential to ensure children are equipped with the skills necessary to benefit from digital learning, particularly in a distance learning environment. Teachers too must be supported in upskilling to ensure they can effectively use digital tools and have confidence in delivering effective blended learning approaches, including in delivering innovative pedagogies. Finally, there is a need for consideration of how innovative pedagogies, blended learning and holistic skill development can broaden traditional definitions of educational success and help deliver on the ambition that all children realise their full potential. In part, this will require ongoing investment in research to expand the evidence base on how children learn best and consideration of assessment approaches that can better gather data on progress around skill development. At the LEGO Group, our mission is to inspire and develop the builders of tomorrow. While fully respecting Member States competence for education and training, we would welcome recognition in the proposed Council Recommendation of the contribution of innovative pedagogies, such as play-based learning, in the development of effective, inclusive and engaging blended learning models. We are supportive of the objective regarding “collaboration between education stakeholders and with the wider community”. The power of partnerships to enhance our collective understanding and develop a European vision for a “blended learning model” is without doubt and we look forward to contributing to this important agenda. Our full submission is attached and we remain available to continue discussions.
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Meeting with Werner Stengg (Cabinet of Executive Vice-President Margrethe Vestager)

14 Apr 2021 · Digital Decade

Meeting with Iris Abraham (Cabinet of Vice-President Dubravka Šuica)

13 Apr 2021 · Meeting on Lego's contribution to the implementation of the EU Strategy on the rights of the Child

Response to Europe’s digital decade: 2030 digital targets

6 Mar 2021

The LEGO Group welcomes Europe’s digital ambition to put citizens, their needs and expectations at the core of its digital transformation. We believe this is a great opportunity to re-imagine and re-build a common digital future that supports the Commission’s objective to include all Europeans and leave no one behind. At the LEGO Group, children are our role models, and they are at the centre of our mission “to inspire and develop the builders of tomorrow”. We strongly recommend that children are actively recognised in the EU’s ambitions here as a distinct group and that their unique role, developmental needs and rights are reflected. Children must be consulted and included in designing and implementing Europe’s vision for a digital future. This approach will showcase EU’s leadership in empowering and enabling the next generation of digital citizens by designing a digital future with children for children, embedding their rights in the foundation of the policy making process. Building on this essential step paired with a multi-stakeholder collaboration in developing “EU’s Digital Decade: 2030 digital targets” and subsequent policy tools, please find below our recommendations. • VISION: Children’s needs, rights and interests must be recognised and sit at the heart of Europe’s digital transformation. Children are a critical and distinct part of society, making one third of all internet users. They have unique developmental needs that differ from adults over the age of 18. We believe that it is necessary to have a dedicated approach in the Communication for children, one that recognises the unique characteristics of childhood and the way that the digital technology can appropriately support children’s rights. Without this there is a possibility that the risks and opportunities that Europe’s digital future presents to children could remain unaddressed. • TARGETS: It is essential that the Communication and relevant targets reflect a rights-based approach, recognizing a breadth of interests and creating a strong link between digital innovation and fundamental rights and values. Having an approach that is child and adult centric also requires us to acknowledge the multi-faceted impact of digital innovation on individuals and wider society. • The “CHARTER of Digital principles” must include children as a distinct group. Only with this can we begin to build a legislative framework that effectively works towards all children’s rights, leveraging innovation to unleash participation and the provision rights alongside those relating to protection of children. The Charter should fully incorporate children’s specific rights, as set out in UNCRC General Comment No. 25. • We call for a dedicated approach to children when developing the MONITORING standards, which would specifically assess the impact of the principles, framework and targets in relation to the developmental needs and rights that children have. We also see this as a great opportunity for Europe to demonstrate leadership by developing a robust and comprehensive DIGITAL CITIZENSHIP STRATEGY that empowers current and future generations to become responsible and resilient European digital citizens. • The AGENDA TO EMPOWER people and to closely involve more citizens and stakeholders in the design and implementation of digital policies is an unmissable opportunity to bring children’s voices to the process, and to encourage a collaborative approach with the private sector and all interested parties. We believe it is also important for the EU to promote transparency and share insights with citizens and all stakeholders involved as progress and impact is monitored. • We also welcome the collaborative approach and international dimension of the upcoming vision, as well as coordination with other EU policy (such as the upcoming EU Strategy on the Rights of the Child which will encompass inter alia child participation to EU policies and children’s rights in digital world).
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Meeting with Anouk Faber (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit)

23 Sept 2020 · Videoconference meeting on skills mismatches, upskilling and reskilling as well ass vocational education and training.