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VTT Technical Research Centre of Finland Ltd

VTT

VTT is Finland's state-owned research and technology organization that supports innovation and economic competitiveness.

Lobbying Activity

VTT Finland Urges EU to Boost Advanced Materials R&I

13 Jan 2026
Topic — The EU aims to strengthen industrial competitiveness through advanced materials innovation.
Message — VTT recommends aligning regulations with long-term research and mission-driven investment. They propose expanding digital infrastructures and pilot lines to accelerate material discovery. They also advocate for a dedicated public-private partnership to bridge commercialization gaps.123
Why — Higher public investment would increase the commercial value of VTT's technical infrastructure.45
Impact — Fossil-based material industries face increased competition from subsidized bio-based alternatives.6
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Meeting with Ville Niinistö (Member of the European Parliament)

3 Dec 2025 · MFF, competitiveness, EU affairs

VTT Urges EU to Prioritize Deep-Tech in Circular Economy Act

6 Nov 2025
Topic — The EU Circular Economy Act aims to promote sustainable production and circular economy business models.
Message — VTT recommends prioritizing reuse and repair rather than simple waste management. They request investment in technology infrastructures to accelerate the market deployment of circular products. Furthermore, they advocate for integrating AI and biotechnology to speed up material development cycles.123
Why — This would secure funding for research institutions and boost their commercial spin-offs.45
Impact — Producers of cheap virgin materials lose market share through new taxes and regulations.67
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VTT Finland urges market-focused research in next EU budget

30 Oct 2025
Topic — The consultation addresses EU funding for competitiveness, research, and innovation post-2027.
Message — VTT requests more funding for projects that develop and bring technology closer to market through business collaboration. They also call for harmonized co-funding rules to simplify project implementation across different countries.12
Why — Focusing on market readiness allows VTT to bridge the financial gap when scaling new technologies.3
Impact — Basic research sectors may face relative budget cuts to prioritize industrial technology development.4
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Meeting with Eero Heinäluoma (Member of the European Parliament)

15 Oct 2025 · Horisontti Eurooppa ja EU:n tutkimuspolitiikka

Meeting with Aura Salla (Member of the European Parliament)

15 Oct 2025 · European Competitiveness Fund and Horizon Europe 2.0

Response to European Innovation Act

3 Oct 2025

VTT welcomes the ambition of the Innovation Act to put research and innovation at the heart of our economy, to create an innovation friendly environment, and ensure that European startups can access the capital and technology infrastructures they need for their scaling up in Europe rather than having to relocate abroad. Europe has a strong research base, but transforming breakthrough technologies into successful businesses remains a challenge. This is where Research and Technology Organizations (RTOs) like VTT play a crucial role, bridging the gap between research, commercialisation and industrial scale-up. RTOs provide deep-tech expertise, technology infrastructures, and long-term innovation partnerships with companies. VTT broadly supports the recommendations made by EARTO, attached and we particularly wish to highlight six areas of action: 1 Strengthening Technology Infrastructures (TIs) and develop targeted policy measures and funding tailor made for TIs. Research Infrastructures (RIs) and Technology Infrastructures (TIs) are both essential and complementary elements for functional and efficient R&I ecosystems in Europe. However, RIs and TIs differ because their purpose, function and business operations, so it is essential that policymakers recognise the development of policies targeted to TIs to support investment planning for Technology Infrastructures, and to enhance the integration and visibility of both RIs and TIs. If RIs and TIs are always considered interchangeably like in the accompanying consultation on the European Innovation Act, the resulting measures will be a compromise which would not leverage either fully. A coherent European investment framework for Technology Infrastructures should act as both enabler and catalyst, complementing national strategies and investment plans. Strategically designed, it can deliver value greater than the sum of individual investments. EU Project RITIFI https://ritifi.eu/ has elaborated recommendations for evidence-based investment planning for TIs and better integration and visibility of RIs and Tis from concrete thematic cases. It is also important to highlight that the regulatory sandboxes are not infrastructures themselves. Regulatory sandboxes do not provide market-ready solutions or fast-track technological advancement. 2 RTOs play a pivotal role in nurturing early-stage ventures, generating Intellectual Property (IP), and transferring knowledge to industry, see the recent study JRC Publications Repository - Deep tech entrepreneurship in Europe and the crucial role of RTOs fostering impactful industrial spin-offs. This is also a great example to learn from: https://www.businessfinland.fi/en/for-finnish-customers/services/funding/niy-companies 3 Procurement is a Driver of Innovation. The European Innovation Act could foresee further exemptions and simplification for RDI. One important element that has been under-addressed in the current debate is the critical role of cities in driving innovation through public procurement, as funders, buyers, testbeds and ecosystem aggregators. The Innovation Act should establish a mechanism for direct collaboration with cities, promote city-led RDI demonstration projects supported by EU and national funding, and ensure an open, continuous dialogue with cities on RDI. 4 Facilitating Policy Coordination Across the EU: The Innovation Act should link clearly to HE2.0 and ECF to ensure coherent and aligned actions. 5 Balance the innovation and precautionary principles for innovation friendly regulation. Regulatory framework strongly shapes the innovation activities in companies and innovation fundamentally challenges the way governments regulate. Legislators must keep pace with technology and create flexible frameworks across sectors and boundaries. In addition, existing EU regulations are primarily designed for fully commercialised products which do not consider the specific needs of R&D activities, including prototyping activities.
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Meeting with Bart Groothuis (Member of the European Parliament)

25 Sept 2025 · Quantum and Chips

VTT urges including mineralisation in carbon removal rules

22 Sept 2025
Topic — The European Commission is setting quality criteria for certifying permanent carbon removal activities.
Message — VTT calls for including permanent CO2 mineralisation in the certification scope. They also advocate for simplified energy emission definitions and removing biochar feedstock criteria.12
Why — Broadening the scope and simplifying rules would reduce monitoring costs and encourage investment.3
Impact — Innovative biochar producers using slow pyrolysis face unequal treatment under current feedstock restrictions.4
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Response to European Research Area (ERA) Act

10 Sept 2025

VTT welcomes the ambition of the ERA Act to address persistent structural weaknesses that undermine the efficiency and impact of Europes R&I ecosystem. The proposed measures have the potential to strengthen European competitiveness and resilience, but their effectiveness will depend on addressing some practical gaps. VTT supports the recommendations made by EARTO in its reply attached and particularly wish to highlight four areas: 1. Technology Infrastructures Europe must invest strategically in world-class technology infrastructures that bridge the gap between research and market uptake. These include pilot and demonstration facilities, testbeds, and advanced digital infrastructures. They are essential not only to prove the functionality and economic feasibility of new technologies, but also to expand European industrial capabilities and resilience. A dedicated funding line in the next MFF would help close capability gaps and reinforce technological leadership and build upon the pilot initiative of the Horizon Europe 2025 Cluster 4 call. 2. Researcher Mobility The ERA Act should go further in enabling research careers beyond academia and across RTOs, industry, and public institutions. Current EU mobility schemes still mainly address academic careers, leaving barriers for RTO researchers. Researchers are still not recognised as a specific group with mobility taking place in EU or national publicly funded or industrial RD&I projects. Thus, in some EU countries, a Posted Worker Notification is required even for short mobility/business trips, even though the RD&I activities performed are not the equivalent of a service provision requiring such notification. Administrative hurdles such as posted worker notifications for short research visits reduce collaboration. A broader framework for intersectoral and international mobility is needed to reflect the reality of RDI projects. 3. Co-Funding Mechanisms While synergies between EU and national programmes are desirable, the lack of harmonisation in rules and timings leads to delays, administrative burden, and missed opportunties. To fix this, the ERA Act should: Promote harmonised rules so that national or regional funding used as co-funding of a EU RDI project can adopt EU Framework Programme rules. Allow EU FP rules to apply in other programmes (e.g. cohesion funds) when calls are designed for synergies. Require earlier guidance and flexible, transparent procedures for national funding agencies to align with EU timelines. Without simplification, co-funded projects will remain underused and continue to exclude capable actors. 4. Dual Use and Research Security The growing geopolitical and geoeconomic risks call for clear EU-level guidance on dual-use and research security. Current requirements are fragmented, sometimes contradictory, and rely heavily on external evaluators without sufficient guidance. We recommend: Adopting a secure-by-design approach in all large EU consortia, ensuring that all partners share the same understanding of risks and risk management best practices. Establishing a voluntary EU-level certification in research security, similar to the HRS4R certification for research excellence, to promote adoption of best practices. Improving proposal checks through at least automatic screening to avoid human error. Clarifying how consortia should act when partners disagree on security-related issues: when research partners have different levels of research security, the project consortium must stand behind decisions taken by one consortium member, e.g. denying research access or exchange to its facilities which is considered violating research security. Conclusion Excellence and technological leadership must remain the guiding principles across all EU RDI instruments from frontier research, industrial collaborations, or innovation funding. Only by sustaining RDI at the best-in-class standard can the EU ensure its long-term technological sovereignty.
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VTT urges EU to prioritize deep-tech in climate resilience

4 Sept 2025
Topic — European initiative establishing a legislative framework for climate resilience and risk management across states.
Message — VTT recommends funding for emerging technologies like AI and digital twins to manage disasters. They suggest combining nature-based solutions with traditional infrastructure to improve urban resilience. They also propose relaxing project rules for end-user participation to increase administrative flexibility.123
Why — Enhanced technology infrastructure funding would allow VTT to accelerate market deployment of innovations.45
Impact — Security practitioners lose guaranteed involvement in projects if mandatory eligibility rules are removed.6
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VTT urges EU powerhouse for scaling bio-based innovation

19 Jun 2025
Topic — The initiative aims to create a circular, climate-neutral economy through sustainable biomass use.
Message — VTT recommends that Europe becomes a powerhouse for scaling up bio-based innovation. They urge the EU to remove regulatory hurdles and improve access to finance. Policies should focus on end-products and remain technology neutral across production methods.12
Why — Proposed funding and infrastructure support would accelerate the commercialization of VTT's deep-tech innovations.3
Impact — Producers of fossil-based materials lose market share due to new mandates and increased competition.4
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VTT urges EU to boost biotech funding and streamline regulation

11 Jun 2025
Topic — The consultation explores measures to accelerate the EU's biotechnology and biomanufacturing sectors.
Message — The organization calls for a cohesive framework aligning regulation, innovation, and industrial policies. They request increased funding for biomanufacturing infrastructure and faster market approval processes.12
Why — Enhanced funding and infrastructure would help VTT translate research into viable commercial startups.3
Impact — Fossil-based plastic manufacturers face increased competition from bio-based materials reaching the market faster.4
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Response to European Affordable Housing Plan

4 Jun 2025

Unlocking Affordable Housing through Strategic Investment in RD&I. Joint Response of Fraunhofer, SINTEF, TNO and VTT: Innovation in the construction and housing sectors is not an auxiliary concern, but a core enabler of productivity in the construction sector and housing affordability. Without sustained and strategic investment along the whole R&D&I system, affordability goals will remain out of reach. A growing portfolio of promising housing innovations is already available ranging from advanced digital tools and circular construction methods to practical, low-tech approaches grounded in local knowledge and traditions. These are not abstract concepts. Many are being tested and applied across Europe in pilot projects and local initiatives. Yet, these efforts remain isolated, fragmented and insufficiently scaled. Promising innovations often fail to gain traction beyond pilots because they are not adapted to diverse local housing needs or lack validation in real-world conditions. Integration combining different technologies, systems, and actors to create more holistic, cost-effective housing solutions should be created along the following critical dimensions: 1) Localized but replicable and scalable Innovation Pilots & Demonstrators 2) Establishment of innovation hubs that bring together SMEs, research organizations, local authorities, and industry actors to co-create housing solutions 3) Stronger SME Participation in Innovation. SMEs possess deep knowledge of local areas and can serve as powerful multipliers, especially in identifying and converting underused local spaces into productive assets 4) Performance-Based Definitions of Affordability and; 5) Increased, stable and Dedicated R&D&I Funding.
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Meeting with Aura Salla (Member of the European Parliament)

27 May 2025 · Current EU RDI matters

Response to European strategy on research and technology infrastructures

21 May 2025

VTT Technical Research Centre of Finland Ltd fully supports the development of the future European strategy on research and technology infrastructures. Technology Infrastructures (TIs) and the continuum between RI-TIs is essential for increasing Europes competitiveness, strategic autonomy, and acceleration of industrial R&I for growth and well-being for our society. Continuous development of research and technology infrastructures is crucial for VTT, which has a specific task and public mission to combine its multidisciplinary advanced research expertise with cutting-edge technologies and accelerate technological innovations towards societal/market adoption, fostering industrial competitiveness.. However, funding opportunities for TIs are currently fragmented, scattered, and uncoordinated at both EU and national levels. Responsibilities of providing R&I services to industry are scattered among many different departments in the national ministries, as well as in the European Commission. 1) The first step is to adopt the new definition of technology infrastructures as proposed by the European Commission Expert Group in their final report Towards a European policy for technology infrastructures to acknowledge their specific features and role in the innovation ecosystems. Research infrastructures (RIs) and technology infrastructures (TIs) complement each other. They share many similarities but are serve different purposes and need different policies and different stakeholders in the decisions making. 2) a governance at EU level should be established with a well defined mandate, incorporating perspectives of industry, TI operators, and EU and national public funders. The TI strategy should address sustainability and financial viability by pooling resources from public funds (regional, national, and EU) and the private sector to secure the level of investments needed. In addition, it should allow the seamless combination of different funds, particularly EU and national funding, without uncertainties related to funding rules or state aid matters. 3)Light mechanisms as a joint-forum or key event should be established for the interaction of RIs and TIs governances at EU level, as well as for their networking and global positioning (e.g. through OECD). 4) A TI funding programme and instruments need to be created aligned with industrial needs and EU policy priorities. Due to the nature of rapid change in industrial needs, the TI calls addressing TI-like functions must maintain an open competitive approach where collaboration is incentivized and consortia are built on existing assets and competences and complemented with strategic funding that is as fast as possible for the specific sector and goals. 5) The funding should address access to TIs for users to whom funding can be a barrier, for example, SMEs, start-ups, and scale-ups and collaboration of relevant RI or TI to increase impact. 6) It should also provide support for the development of TI services and skills of experts, engineers, and technicians who work in these infrastructures to strengthen the delivery and uptake. 7) A part of the funding should be allocated to foster collaboration and networking among TIs, between TIs and RIs, and accelerate co-development of services needed by users to support the uptake of new technologies. As active member, VTT has contributed to EARTO position on technology infrastructures and fully supports EARTO reply to the call for evidence and the key aspects to consider. Finally, concerning RI and TI collaboration, we strongly recommend consulting the work of the Horizon Europe project RITIFI (GA 101095267). RITIFI is developing policy advice on Technology Infrastructures and RITI collaboration based on five concrete thematic case studies in the areas of: Circular Materials, Microelectronics and semiconductors, Clean Hydrogen, Biomedical and Particle accelerators and superconducting magnets. https://ritifi.eu
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Meeting with Mika Aaltola (Member of the European Parliament) and Atlantic Council of the United States, Inc and Wärtsilä Corporation

20 May 2025 · EU affairs

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

6 May 2025 · Discussion on Quantum

Meeting with Maive Rute (Deputy Director-General Internal Market, Industry, Entrepreneurship and SMEs) and

6 May 2025 · Exchange of views on the future Multiannual Financial Framework (MFF) and the European Competitiveness Fund (ECF)

VTT Urges Faster Biotech Approvals and More Infrastructure Funding

16 Apr 2025
Topic — New multi-disciplinary strategy to boost Europe's competitiveness in life sciences and biomanufacturing.
Message — VTT requests long-term funding for biotechnology and biomanufacturing to diversify food and health sectors. They urge the EU to accelerate slow regulatory approvals for novel foods and plant protection products. They also call for increased investment in infrastructure to scale up bio-based innovations.123
Why — This would increase demand for VTT's specialized research services and pilot facility usage.4
Impact — Global competitors would lose their market advantage if the EU streamlines its regulatory processes.5
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Meeting with Katharina Knapton-Vierlich (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and European Construction and sustainable built environment Technology Platform

28 Mar 2025 · To exchange on the future of Horizon Europe (also referred to as Framework Program 10 (FP 10)) and of the EU Partnerships under Horizon Europe, to get an update on the work towards the next MFF.

Meeting with Vincent Berrutto (Head of Unit Energy)

20 Mar 2025 · Digitalisation and R&I Impact on EU Energy Policies

Response to EU Start-up and Scale-up Strategy

14 Mar 2025

VTT Technology Research Centre of Finland fully supports the development of a EU start-ups and scale-ups strategy. If Europe wants to turn research excellence into increased competitiveness, it must strengthen the support structures that creates excellent deep-tech startups and helps them grow and stay in Europe. Research and Technology Organisations like VTT play an important role in Europes startup ecosystem. Not only as incubators, but as long-term partners, for funders and companies alike, in deep-tech development, validation, and scale-up. VTT welcomes the opportunity to present the following recommendations: 1. Create New Agile Funding Instruments for Deep-Tech Incubators 2. Strengthen the EIC Transition as a key Research-to-Business Instrument 3. Develop Larger Investment Opportunities in Europe 4. Improve Access to Technology Infrastructures Further feedback in the attached file.
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Meeting with Merja Kyllönen (Member of the European Parliament)

6 Mar 2025 · Puolustus- ja kaksikäyttöteknologiat

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen), Silvia Bartolini (Cabinet of Executive Vice-President Henna Virkkunen)

5 Mar 2025 · Exchange of views on semiconductors, quantum, and the innovation gap in Europe

Meeting with Maria Cristina Russo (Director Research and Innovation) and

5 Mar 2025 · Dual-use research; civil-defence synergies

Meeting with Ekaterina Zaharieva (Commissioner) and

21 Feb 2025 · Exchange of views on EU research and innovation funding.

Meeting with Jussi Saramo (Member of the European Parliament)

18 Feb 2025 · MFF, FP10

Meeting with Aura Salla (Member of the European Parliament)

18 Feb 2025 · VTT's views on the clean industrial deal and regulation of this term

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

18 Feb 2025 · Exchange of views on EU research and innovation funding

VTT calls for researcher mobility and shared tech infrastructure

30 Jan 2025
Topic — The consultation aims to develop the single market by removing regulatory and administrative barriers.
Message — VTT asks to remove barriers like Posted Worker notifications for researchers to foster innovation. They propose common rules for access to technology infrastructures to help SMEs scale prototypes. Finally, they suggest adding specific researcher articles to tax treaties to simplify expert mobility.123
Why — This would allow VTT to more easily offer testing and scaling services across Europe.4
Impact — National administrations lose oversight if notification requirements for researchers and experts are abolished.5
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Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

14 Jan 2025 · Research policy

Meeting with Aura Salla (Member of the European Parliament)

8 Oct 2024 · Innovation and Research in the EU

Meeting with Eero Heinäluoma (Member of the European Parliament)

8 Oct 2024 · Current Affairs

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

8 Oct 2024 · Innovation policy

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

8 Oct 2024 · EU research policy

Meeting with Jussi Saramo (Member of the European Parliament)

8 Oct 2024 · Teollisuuspolitiikka ja tutkimus

Meeting with Merja Kyllönen (Member of the European Parliament)

8 Oct 2024 · EU:n tulevan kauden prioriteetit, erityisesti EU:n kilpailukyky ja turvallisuus, TKI-toiminta sekä teknologia- ja teollisuuspolitiikka

Meeting with Aura Salla (Member of the European Parliament)

3 Oct 2024 · Innovation and Research

Meeting with Katri Kulmuni (Member of the European Parliament)

26 Sept 2024 · EU:n sirusäädös

Meeting with Jussi Saramo (Member of the European Parliament)

25 Sept 2024 · Osaamiskeskukset

Response to Interim evaluation of the Euratom Research and Training Programme 2021-2025

30 Apr 2024

The continuation of the current programme 2021-25 is very much needed. For defining the constents of the continuation, Euratom should consider taking the learnings from the Euratom Scientific and Technical Committee legacy document that raises the most important questions recognised. The programme should not compile too many topics together as was done in the call 2023. SMRs have been well raised already now so the main outcome should be in the GEN II and III reactors. The big partnerships are running and it would be extremely important that the nuclear materials partnership (CONNECT NM) would be further emphasised. Also the continuation of the current OFFERR project for better utilisation of European research infra, should be taken into consideration. The target of that project is good but in practice the financing regulation prevents the maximal usage of the infras.
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Response to Options for support for R&D of dual-use technologies

30 Apr 2024

Please find here in the file attached the comments of VTT Technical Research Centre of Finland on the European Commissions White Paper "On options for enhancing support for research and development involving technologies with dual-use potential". In general, VTT supports the overall objective of the white paper for increasing cross-fertilization and enhancing synergies between civil and defense R&D. EU security and resilience requires a whole of society approach and can not only depend on military capabilities.
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Meeting with Christian Ehler (Member of the European Parliament) and IQM Finland Oy and Forschungszentrum Jülich GmbH

11 Apr 2024 · Co-host breakfast event on quantum and semiconductor technology ecosystems

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

28 Feb 2024 · European research and innovation policy

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

16 Feb 2024 · Research and new technologies in Finland and the EU

Response to Enhancing research security in Europe

22 Dec 2023

VTT supports the guiding principles mentioned in the call for evidence, in particular: Self-governance and proportionality based on risk assessment. The balance between openness and confidentiality should be determined in each research project individually (either it is at national or international level). The principle as open as possible and as closed as necessary should be preserved without exceptions in national and European public funding. Fundamental research should not be less overwatched. EU and national calls should refer to importance of compliance with research security also in fundamental research e.g. when it comes to open research infrastructure and research exchanges. It is extremely important to safeguard Ethics in research to avoid undue pressures and foreign interference, more than focusing on academic freedom. Academic freedom (i.e. the ability to choose your own topics of research) does not apply to many researchers working outside academia and still performing fundamental research. For this, good scientific practices must be the guiding principle (ref. the The European Code of Conduct for Research Integrity - ALLEA). Recognise the security needs of research done in RTOs and companies and dont impose solutions tailor made for universities. Taking a country agnostic approach avoiding all forms of discrimination. Facilitate open discussions on security at national level and at EU level. Reaching a common European approach is very important. Concerning national funding agencies, we believe they should take a more proactive approach than incentivising Raise awareness to reach a common understanding on research security, having clear definitions, examples, tools for risk assessments and practical support for researchers and institutes on the grey areas Support an EU-wide pro-active approach Lead and stimulate open discussions on security at national level and at EU level. Clear guidelines for dual use calls voluntary certification at EU level in research security practices Comprehensively review practices in Horizon Europe projects. Specific EU coordinated efforts on standards Balance the extra administrative burden. Further details in the file attached.
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Meeting with Henna Virkkunen (Member of the European Parliament)

1 Nov 2023 · New technologies and research in Europe

Response to European Critical Raw Materials Act

9 Jun 2023

VTT, the Technical Research Centre of Finland, recognises the tremendous significance of critical raw materials in the electronics, defense, aerospace, mobility, chemicals, and health industries, amongst others, and especially for digital applications and the energy sector and we welcome EU pulling together to act on the topic. VTT main messages: 1- Accelerate research and innovation to reduce demand and increase the supply mix covering mining, refining, re-use, recycling, side stream valorisation and substitutions´. Technological solutions are crucial to reduce strategic dependencies, and we need new technologies to ensure both short-term but also long-term competitiveness of the investments. 2- Create stable and transparent regulatory environment for sustainable mining practices with recovery and valorization of all side streams and waste, and carbon neutral mines including robotization and electrification of heavy working machinery and heavy-duty vehicles. 3- Co-develop the research and innovation agenda with all the related established European networks that bring together all actors along the relevant critical raw materials value chains, which includes materials circularity and substitution, sustainable mining certification, as well as increased use of low emission machinery and heavy-duty vehicles and non-invasive data-driven solutions. Environmental impact must be minimised holistically while valorisation of all side streams and waste is maximized over the whole material value chain. 2) Taking into account the needed time schedule, special focus should be put on piloting and scale-up (TRL 5-7) in order to get the technologies to the market very soon. This needs a strategic development investment plan for technology infrastructures at EU level that would leverage the national investments and make join forces the various European centres of excellence. 3) It is critical to reduce demand by resource efficiency, product design and substitutions. This is not sufficiently considered in the proposed regulation. With the expected exponential increase in demand, the available critical raw materials should be directed to key strategic applications that really need it. 4) We also need to get strong and good standards that can support European circular economy and green deal goals. So, there is a need for standardisation also in the use of CRM in applications and for product design for recycling which is currently not mentioned. 5) Establishing of targets for the Union recycling capacity are welcome. However, for some materials, the proposed targets might be too ambitious considering the demand growth rate and the life-time of the equipment. In the case of permanent magnets high growth rate is forecasted (some sources refer to 5x in 10 years). In 2030 there might not be enough end-of-life magnets to recycle to meet the proposed 15% recycling target. 6) Decreased demand and emphasizing circularity should be included in the strategic projects criteria. It is important to include valorisation of mining waste, sustainability, recycling, circularity and fair certification schemes. 7) Finally, a note on funding. Much is expected by Member States. Concerning the research agenda, it is mentioned that Cluster 4 Digital, Industry and Space aims to make concrete contributions to three overarching EU policies. VTT supports Cluster 4 taking a lead on this-- however the cluster already has a very large scope and many new priorities are proposed or agreed to be added (Critical Raw Material Act, Chips Act, new partnerships). We must ensure that cluster 4 is well funded to comprehensively tackle the innovation gap. In the planning of the next MFF it should be considered if it would be better to have a separate pillar on industrial technologies development, maturation and scale-up like in Horizon2020.
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VTT urges research and innovation focus in Net-Zero Act

9 Jun 2023
Topic — The consultation addresses the proposed Net Zero Industry Act to boost clean technology manufacturing.
Message — VTT calls for a dedicated research and innovation pillar to ensure long-term industrial competitiveness. The organization demands including circularity, carbon usage, and nuclear technologies in the strategic scope. They also suggest linking regulatory sandboxes with existing technology infrastructures like test beds.12
Why — Broadening the act would drive more funding toward research institutes and pilot facilities.3
Impact — Carbon storage projects could lose their current preferential treatment if more technologies are included.4
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Meeting with Mauri Pekkarinen (Member of the European Parliament, Shadow rapporteur for opinion)

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

Meeting with Ville Niinistö (Member of the European Parliament)

4 Apr 2023 · CRCF (staff level)

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

28 Feb 2023 · IRA package and GD Industrial Plan, EU Green Deal

Meeting with Thomas Woolfson (Cabinet of Executive Vice-President Margrethe Vestager) and Wärtsilä Corporation and

28 Feb 2023 · European competitiveness and the Green Deal Industrial Plan

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

30 Sept 2022 · meeting VTT board of directors on how Research and Technology Organisations (RTOs) can help in the implementation of the EU industrial strategy, especially taking in consideration the new geopolitical situation

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

29 Sept 2022 · Meeting on EU Industrial Policy

Response to Climate change mitigation and adaptation taxonomy

16 Dec 2020

VTT Feedback to the Annex II Ares(2020)6979284 - 20/11/2020 VTT strongly supports the overall goal to establish such technical screening criteria for economic activities that make it possible to speed up investments and business decisions which contribute to the EU’s green transition. To achieve this directionality, we need a balanced approach for the EU taxonomy and its technical screening criteria and impact assessment. Investments for green transition, supported by digitalization, will only be effective if they are backed up by knowledge and know-how and a predictable, level playing field. Therefore, investments in RDI and development of innovation-friendly regulatory environment are necessary. For the taxonomy to be deployed successfully in practice, we would like to point out some critical development needs: In general, the sector classification should take into account the evolution of dynamic industrial value chains and supply chains. Links with EU policy targets should be strengthened, more specifically i. the coherence, consistency and compatibility with the common industry strategy; ii. cross-sectoral and cross-technological innovation, which is already mainstream in EU’s industrial ecosystems; In Chapter 9 (Professional, Scientific and Technical Activities), the technical screening criteria should give room for forward-looking thinking and innovation, taking into account i. the nature of the industrial RDI process, which goes beyond immediate economic activities or “consultancy” and where scientific and technological quality, public-private collaboration, risk-sharing, long time-spans, and responsibility, are key features; ii. the enabling role of RDI, whereby transitional activities, including piloting and demonstrating of new sustainable solutions (from low to medium to high TRLs as well as market uptake), are crucial to all sectors.
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Meeting with Jyrki Katainen (Vice-President) and

11 Jan 2016 · EU Innovation policy