46 submissions from 45 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 107 submissions on this file. Shown here: the 46 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
7 submissions from industry — companies and their trade associations — against 36 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Industry 7Civil society 36Public authorities, academia, other 3
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
10 of 45
in the EU Register
37
full-time lobbying staff
€1.6M+
declared costs a year
21
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 31 Dec 2020 — it ran from 5 Nov 2020.
Our organization, the Socialdemokraterna Värmdö's union committee, wants to give the following views of the proposal for a directive on the minimum wage: We are strongly critical of the Commission's proposal for a directive on the minimum wage. In Sweden, the social partners are completely independent of wage formation through collective bargaining.
Following the European Commission's proposal for a Directive on adequate minimum wages in the European Union the Commission has requested an opinion of the proposal, COM (2020) 682 final. The Swedish Municipal Workers´ Union (Kommunal) has, together with 13 affiliates within the Swedish Trade Union Confederation (LO), analysed the proposed Directive on adequate minimum wages in the EU.
The National Food Workers’ Association, Region Mitt, would like to make the following comments on the proposal for a directive on minimum wage: We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining. It is well known that the Swedish model delivers real wage development, high employment rates, few days of conflict, flexibility, strong transition capacity and legitimacy.
Filed in Swedish · English published by the European Commission
Our organisation, trade club 471 of the Association of Commercial Employees in Stockholm, wishes to make the following comments on the proposal for a directive on minimum wage: We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
Trade Section 20 Opinion on the European Commission’s proposal for a directive on adequate minimum wages in the EU The Commission’s proposal constitutes a very serious attack on the Swedish model of collective bargaining. In the long term, the collective self-regulation model — which gives the parties the primary responsibility to regulate conditions in the labour market autonomously — is at stake.
Filed in Swedish · English published by the European Commission
Our organisation, Sandviks Metallgruppen, represents over 6000 collective industrial workers organised in IF Metall. We would like to make the following comments on the Minimum Wage Directive: — The Commission’s proposal damages Svenska Modellen. The Swedish Modell means that the social partners are fully responsible for wage formation. This is done through responsible collective bargaining.
Filed in Swedish · English published by the European Commission
We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining. Undermining the Swedish model through legislation on minimum wages will destroy our welfare system. The EU does not have the right under the Treaty to legislate on remuneration.
Filed in Swedish · English published by the European Commission
2020.12.28 IF Metall ASSA ABLOY Mölnlycke, Sweden The proposal for a directive about minimum wages in the EU We would like to comment on the proposal for a directive on the minimum wage: We are strongly critical of the Commission's proposal for a directive on the minimum wage. In Sweden, the social partners are fully responsible for wage formation through collective bargaining.
H&M Group welcomes the opportunity to comment on the proposal for a directive on adequate minimum wages. We do support the concept for a Directive on adequate minimum wages in the European Union, by implementing a minimum wage methodology which is built on and does consider national context, because of the yet different circumstances in the European countries.
In response to the European Commission’s proposal on a Directive on adequate Minimum Wages in the European Union, the Lithuanian Free Market Institute is pleased to submit its position paper on the EC’s proposed policy options. The Position Paper argues that the application of different criteria should be considered in a restrictive manner.
On behalf of the PTK, the (Swedish) council for negotiation and cooperation, Unionen would like to provide feedback in the form of the attached joint legal analysis of the Commission’s proposal for a directive on adequate minimum wages in the European Union. Our main concerns and conclusions can be summarised in three points: 1.
The Spanish Confederation of Transport by Bus and Coach (CONFEBUS) welcomes the opportunity to share views on the proposal for an EU Directive on adequate minimum wages. CONFEBUS shares the overall objectives of achieving adequate wages across the EU.
The LO trade union Eskilstuna-Strängnäs would like to make the following comments on the proposal for a directive on minimum wage: We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
Hello! Introducing minimum wages in Sweden would have been devastating for the Swedish model where trade unions and employers’ organisations negotiate and agree which wages should apply in each sector. In this way, does both employers and workers have a say and what are the most familiar with the sector? It is the employers and workers of this kind. No one in Sweden wants to receive mini-wages.
Filed in Swedish · English published by the European Commission
Analysis by DIK of the draft directive on adequate minimum wages Summary of conclusions On October 28, the European Commission presented its draft directive on adequate minimum wages. The main purpose of the draft directive is to ensure adequate minimum wages and minimum wage protection through law or collective agreement. DIK:s main conclusions are the following.
On October 28, the European Commission presented its draft directive on adequate minimum wages. The main purpose of the draft directive is to ensure adequate minimum wages and minimum wage protection through law or collective agreement.
St’s and main conclusions are the following. • The draft directive falls outside the competence delegated to the EU in accordance with Article 153.5 of the Treaty on the Functioning of the European Union (TFEU).
Filed in Swedish · English published by the European Commission
Further to the proposal for a Directive on minimum rates of pay The Stockholm-Gotland Building is a trade union representing more than 16 000 construction workers in the Stockholm region and in Gotland. We are strongly critical of the Commission’s proposal for a directive on minimum wages. In Sweden, the social partners take full responsibility for wage setting through collective bargaining.
Filed in Swedish · English published by the European Commission
This feedback has been written and endorsed by members and allies of the Clean Clothes Campaign in 21 European countries (see list of endorsements in the attachment). The Clean Clothes Campaign (CCC) is a global network composed of trade unions and civil society organisations dedicated to improving working conditions and empowering workers in the global apparel and sportswear industries.
Following the European Commission’s proposal for a Directive on minimum wage adequacy in the European Union, the European Commission, through a public consultation process, has asked organisations and individuals to express their views on the proposal for adequate minimum wages in the EU, COM (2020) 682 final.
Filed in Swedish · English published by the European Commission
Opinion on the European Commission’s proposal for a directive on adequate minimum wages in the EU The Commission’s proposal constitutes a very serious attack on the Swedish model of collective bargaining. In the long term, the collective self-regulation model — which gives the parties the primary responsibility to regulate conditions in the labour market autonomously — is at stake.
Filed in Swedish · English published by the European Commission
Handels’ conclusions on the draft directive on adequate minimum wages in the EU: - The Commission's proposal constitutes a very serious attack on the Swedish collective agreement model. In the long term, the collective self-regulation model - in which the social partners have the primary responsibility of independently regulating conditions on the labor market - is at stake.
Sagsnr. 19-2878 Vores ref. HERO 22nd December 2020 Consultation about the proposal for a directive on minimum wages The Commission has launched a public consultation on the proposal for a directive on appropriate minimum wages in the European Union EU has no authority to legislate on wages The proposal is based on Art. 153 (1) (b) about working conditions.
My organisation, section 9 Gävle-Dala, wishes to make the following comments on the proposal for a directive on minimum wage: We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
SACO’s conclusions on the draft directive on adequate minimum wages in the EU: • The draft directive falls outside the competence delegated to the EU in accordance with Article 153.5 of the Treaty on the Functioning of the European Union (TFEU).
My organisation Kommunal Västerbotten, with more than 19 000 members, would like to make the following comments on the proposal for a directive on minimum wage: We are strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
Swedish Trade Union Confederation (LO) • LO considers that the Commission's proposal constitutes a very serious attack on the Swedish collective agreement model. In the long term, the collective self-regulation model - in which the social partiners have the primary responsibility of independently regulating conditions on the labour market - is at stake.
Opinion on the European Commission’s proposal for a directive on adequate minimum wages in the EU The Commission’s proposal constitutes a very serious attack on the Swedish model of collective bargaining. In the long term, the collective self-regulation model — which gives the parties the primary responsibility to regulate conditions in the labour market autonomously — is at stake.
Filed in Swedish · English published by the European Commission
Following the Commission’s proposal for a Directive on adequate minimum wages in the European Union. The Food Workers’ Federation (Livs) is a Swedish trade union organisation within the LO, which currently organises about 27.000 members of the food industry. In response to this request, we would like to send you the following comments and comments.
Filed in Swedish · English published by the European Commission
The Commission’s proposal constitutes a very serious attack on the Swedish model of collective bargaining. In the long term, the collective self-regulation model — which gives the parties the primary responsibility to regulate conditions in the labour market autonomously — is at stake.
Filed in Swedish · English published by the European Commission
My LO district in Dalarna and Gävleborg would like to comment on the minimum wage proposal: We find the Commission’s proposal for a directive on minimum wages poor. In Sweden, the social partners are independently responsible for wage formation through collective bargaining. An EU directive on minimum wages is detrimental to this system. We would like to make the following comments: 1.
Filed in Swedish · English published by the European Commission
I would like to make the following comments on the proposal for a Directive on minimum rates of pay: I am strongly critical of the Commission’s proposal for a Directive on minimum wages. In Sweden, the social partners are fully independently responsible for wage formation through collective bargaining.
Filed in Swedish · English published by the European Commission
Following the Commission’s proposal for a Directive on adequate minimum wages in the European Union. The Food Workers’ Federation (Livs) is a trade union of the LO, which currently organises about 27.000 members. In response to this request, we would like to send you the following comments and comments.
Filed in Swedish · English published by the European Commission
To whom it concern, The Swedish Industrial workers union, in the region of Blekinge has taken notice of the proposal to a new Directive regarding minimum wages. In Sweden the minimum wages are set in negotiations between the labour partners. This is the model of collective agreement and we believe that this is the best way to do it.
The Swedish Industrial Workers Union, representing 313 000 members, would like to give the following feedback: First and foremost: The proposal creates completely unacceptable legal uncertainty for key elements of our Swedish collective agreement model. Putting forward a proposal like this one goes against the principles that have been laid down in the treaty.
Our organization, the LO unions in Vetlanda, believes that the proposal for minimum wages in the EU should be rejected as we believe that the social partners should own this issue in Sweden. Minimum wages would greatly undermine our opportunities to influence wage formation and not give us real wage increases.
SGI Europe – response to open consultation on minimum wage directive proposal December 2020 SGI Europe agrees with the overall objectives of achieving adequate wages across the EU, making work pay, fighting poverty, and strengthening the role of social partners and social dialogue, in line with national industrial relations systems. A lot of work is done, in particular in the European semester.
Adequate minimum wages are of great importance in improving the living and working conditions of people in the EU and in contributing to minimum labour standards below which no employment relationship should be considered socially acceptable. Minimum wages are important tools to guarantee and realise social and labour rights. They also help to reduce the gender pay and pension gap.
Seko is the Swedish trade union for service- and communication employees. Seko represents the interests of our members who work in essential sectors of society. The attached document summarizes Seko´s remarks on the European Commission´s proposal for a directive on adequate minimum wages in the European Union.
The European Furniture Industries Confederation (EFIC) welcomes the opportunity to share views on the proposal for an EU Directive on adequate minimum wages in the EU launched under Art. 154 TFEU. EFIC reiterates that EU actions addressing minimum wages at EU level are not appropriate and that the EU, according to article 153(5) of the TFEU, explicitly and for good reasons lacks competence in the field of…
In the course of both previous consultations, the CDB already took the view that there was no need to introduce pan-European minimum wages. In Germany, there are two functioning systems with the statutory minimum wage and the collective minimum wages, in particular for the construction sector. A third would put the existing balance out of balance and put at risk.
Filed in German · English published by the European Commission
Legislation on minimum wages would be a catastrophic event and would have an impact on the Swedish collective agreement model, as well as the subsequent effects of the Swedish wage formation in the future, so we strongly criticise this proposal for this proposal to cause far-reaching problems for both collective agreements and individual workplaces for employees and workers.
Filed in Swedish · English published by the European Commission
ERGO Network welcomes the Directive on adequate minimum wages in the EU as a much-needed & long-awaited step to guarantee quality of work & employment + to ensure that jobs are an actual route out of poverty. Lack of support & early intervention means that many Roma, coming from a background of poverty & low skills, are only able to access precarious, low-paid jobs.
See attached document. In summary, the Swedish Association of Local Authorities and Regions (SALAR) considers the following. The proposal for a directive is in conflict with the principles of subsidiarity and proportionality. The EU lacks the prerequisites to introduce a minimum directive on sufficient minimum wages. SALAR considers that wage formation is national matter and not an EU competence.
Minimum wage for the entire EU will require enormous funds, especially for the newcommer member states, which have no resources needed for providing such extra funds. If you need more money, you need to produce MORE.
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.