Amending certain Regulations as regards the extension of certain mitigating measures available for small and medium sized enterprises to small mid-cap enterprises and further simplification measures (Omnibus IV)

Feedback on Omnibus IV proposals concerning the EU Batteries Regulation due diligence chapter The EU Batteries Regulations (EUBR) due-diligence chapter is an impactful set of rules serving as lex specialis for battery supply chains. It establishes product-specific obligations and ensures a level playing field between EU and imported batteries.

ACT | The App Association (hereafter App Association) hereby submits comments to the European Commission in response to the public consultation on Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Regulation. The App Association is a policy trade association for the small business technology developer community.

BEUC welcomes the opportunity to contribute to this consultation. We would like to express caution about the proposal to extend the derogation for keeping documentation to companies and organisations of up to 750 employees and to limit the exceptions of the derogation to data processing activities that are likely to result in a high risk to data subjects rights and freedoms.

Wikimedia Germany is the non-profit organization that supports the german-language Wikipedia and other collaborative, multilingual knowledge projects, with a mission to empower people worldwide to collect, develop, and share educational content under a free license.

The Bulgarian Chamber of Commerce and Industry (BCCI) and the Data Protection Association, Bulgaria welcome the European Commissions efforts to simplify GDPR under the Fourth Omnibus Package. We supports reducing unnecessary administrative burdens on businesses, especially SMEs. However, we are concerned the current proposal wont have real impact.

Ladies and gentlemen, the Polish Chamber of Commerce, as an organisation representing water and wastewater companies in Poland, would like to express your views in the context of the consultation on the draft Omnibus IV Regulation.

Filed in Polish · English published by the European Commission

We are definitely in favor of such a proposal that welcomes the European Commissions initiative to reduce administrative burdens and simplify reporting for small and mid-enterprises (SMCs). These objectives align directly with GLEIFs mission of enabling trusted and efficient identification via its valuable and trusted LEI Symbology and shall bring together different methods round the European Union to one standard…

VÖWG welcomes the European Commission's initiative to reduce administrative burdens and enhance regulatory clarity. At the same time, VÖWG stresses the importance of ensuring that these simplification measures also apply to publicly owned enterprises. To create a level playing field, public and municipal companies must be included in the Commission's recommendation on the definition of Small Mid-caps.

The Wikimedia Foundation, the non-profit host of Wikipedia and other educational online projects, endorses the Commission's initiative for simplification of regulatory burdens, and is pleased to offer the attached suggestion for a minor but potentially important Recital clarification relating to the GDPR recirdkeeping simplifications (see attachment).

Regulation (EU) 2024/573 on fluorinated greenhouse gases16 (F-gas Regulation) with its numerous implementing regulations (EU) has imposed heavy administrative costs on many companies since its introduction. This applies not only to the obligation to register, which is to be facilitated in the proposal for OMNIBUS IV.

Filed in German · English published by the European Commission

The Bundesverband Deutscher Pflanzenzucht e.V. (BDP) brings together the interests of its 130 German members, which are agricultural and horticultural breeding and trading companies. For more than 75 years, the BDP has been the professional representative of German plant breeding companies in a highly small and medium-sized sector.

Filed in German · English published by the European Commission

Ecommerce Europe welcomes the Commissions proposal for a IV Simplification Omnibus package, as well as the overall objective of this Commissions mandate to reduce unnecessary bureaucracy and foster a regulatory environment that promotes innovation and growth.

Independent Retail Europe welcomes the measures proposed in the 4th Omnibus simplification package concerning a new definition of small mid-cap companies (SMCs) and the introduction of targeted regulatory exemptions for SMCs even though, overall, we consider the impact of these measures on the retail sector to be limited.

AIIP welcomes the Commissions proposal to streamline regulatory obligations for small and mid-sized enterprises as part of the Omnibus IV initiative. As Italys first and historic association of independent Internet and cloud providers, we represent over 60 companies operating across connectivity, fibre, data centre and cloud services with more than 250,000 business customers and 1 million residential clients.

We, Japanese 4 electric and electronic industry associations-JEMA, JEITA, CIAJ and JBMIA (hereinafter JP4EE) welcome the opportunity to provide our comments and proposals on the draft Commission Regulations under the Omnibus IV Simplification Package.

While we support the goal of making EU regulation more navigable for smaller organisations, we strongly oppose the framing of fundamental rights safeguards as administrative burdens and reject the proposals redefinition of core accountability obligations.

SGI Europe welcomes the European Commissions initiative to revise key EU legislative acts to reduce administrative burden, improve clarity, and enhance proportionality under the Omnibus IV package. However, we would like to raise a horizontal issue that cuts across several of the targeted regulations: the way in which public and non-profit enterprises are excluded from simplified or proportionate regimes due to the…

With regard more specifically to Regulation (EU) 2024/573 on fluorinated greenhouse gases (F-gas Regulation), we would like to take advantage of this consultation to draw attention to what we consider to be a flaw in the system: the impossibility, as the regulation currently stands, of placing HFCs on the market beyond 2050, although this would be necessary to meet safety requirements at operating nuclear sites.

UFC-Que Choisir is the main consumer organisation in France. We would like to express serious concern about the proposal to exempt companies with less than 750 employees from the documentation requirements of Article 30 GDPR and to limit the exceptions to processing that is “likely to result in a high risk” to the rights and freedoms of data subjects. We make the following observations: 1.

Filed in French · English published by the European Commission

The Global Legal Entity Identifier Foundation (GLEIF) welcomes the European Commissions initiative to reduce administrative burden and simplify identification and reporting requirements for companies, including small mid-cap enterprises (SMCs). We believe that the Legal Entity Identifier (LEI) can play a key role in achieving these objectives.

On the occasion of the consultation launched on 23 May 2025 on 'Burden reduction and simplification for competitiveness of small mid-cap enterprises - Omnibus Regulation IV' the Bundesverband Deutscher Leasing-Unternehmen e. V. (BDL) is submitting some comments.

Ladies and gentlemen, the Omnibus package (Omnibus IV) is part of the European Commission’s current efforts to step up efforts to reduce red tape. Omnibus IV focuses on various proposals aimed, inter alia, at reducing the red tape of existing EU legislation. In the context of Omnibus IV, targeted amendments to specific legal acts are expected to bring about tangible reductions in red tape.

Filed in German · English published by the European Commission

The document provides feedback to the European Commission on the 2025 Omnibus Package (COM(2025) 501), advocating for proportional regulation tailored to small mid-cap enterprises (SMCs). It highlights the need to extend SME-friendly simplificationssuch as reduced administrative burdens in GDPR, Prospectus Regulation, Batteries Regulation, and F-gas Regulationto SMCs, which face similar challenges but are often…

Homo Digitalis appreciates the Commissions resolve to help smaller organisations navigate EU law. Nevertheless, we have serious reservations: the proposed change to Article 30(5) GDPR would stray from the Regulations core aims and could erode the coherence of the EUs data-protection regime.

Miljøcert AS Husvikholmen 10 1443 DRØBAK Norway Feedback from Miljøcert AS on COM(2025) 501 Final 1. Introduction and Background Miljøcert AS is a Norwegian AI-based platform for environmental management and certification of small and medium-sized enterprises (SMEs).

As Bavarian Chambers of Commerce and Industry, we, as Bavarian Chambers of Commerce and Industry, expressly welcome the introduction of an additional category of SMEs (Small Mid-Cap, SMC), as provided for in Omnibus IV.

Filed in German · English published by the European Commission

Nucleareurope welcomes the European Commission's proposal for simplification, particularly in the chemicals sector through this omnibus. With regard more specifically to Regulation 2024/573 FGAS published in 2024, we would like to take advantage of this consultation to draw attention to what we consider to be a flaw in the system: the impossibility, as the regulation currently stands, of placing HFCs on the market…

SIX Group in general and its Spanish subsidiary BME in particular (thereafter SIX/BME), welcomes the European Commission proposal to reduce regulatory burdens for small mid-cap enterprises (SMCs) and ensure they benefit from the same legal framework as small and medium sized enterprises (SMEs).

The Verbraucherzentrale Bundesverband (vzbv) is critical of the European Commission’s proposal to amend Article 30(5) GDPR. In the view of the Vzbv, documentation of processing activities is far more than a bureaucratic obligation: It is a key component of effective data protection and lived accountability. It allows companies to identify and minimise risks in a contextual and dynamic manner.

Filed in German · English published by the European Commission

We welcome the European Commissions proposal to extend selected SME relief measures to small mid-cap enterprises (SMCs) through the Omnibus IV Regulation. This initiative is a long-overdue and necessary step toward a more proportionate regulatory framework that reflects the operational realities of mid-sized companies in Europe.

By introducing a category of small mid-caps, the European Commission aims to relieve the burden on larger small and medium-sized companies which, according to the previous EU definition, are already considered to be large companies.

Filed in German · English published by the European Commission

The European Confederation of Pharmaceutical Entrepreneurs (EUCOPE), representing predominantly small to mid-sized innovative pharmaceutical companies, backs the European Commissions initiative to create a small mid-caps (SMC) category, as established by its Recommendation on the definition of small mid-caps.

In response to the Commission proposal for a Regulation on Simplification Measures for Small Mid-Cap Enterprises2 , we seek further improvements to the Due Diligence rules for batteries in order to create fair level playing field for our members, and other battery manufacturers.

European Digital Rights (EDRi) strongly opposes the proposed amendment to Article 30(5) GDPR included in the Fourth Omnibus Regulation. This change could undermine key accountability obligations, erode transparency and security safeguards, and weaken individuals ability to exercise their rights.

In its response, Finnwatch is focusing only on the proposed changes to the battery due diligence obligations. Finnwatch does not support the Commission's proposal to reduce the scope of the application of certain due diligence obligations in the batteries regulation by extending the exclusion clause that currently applies to companies with less than 40 million euros turnover to companies with less than 150 million…

The IVSH represents the interests of manufacturers of cutlery, household, kitchenware and bodycare products in Germany and the Austria and Switzerland, with a strong focus on consumer safety, regulatory compliance, and innovation.

Synetam (Union of Dequipment Manufacturers and Dutensils for Restoration and Food Arts) brings together and represents in France the professional dequipment manufacturers and dustles for catering, culinary arts and smoke ducts, with 87 companies, 1.5 billion CA and 7000 employees. Synetam is a member of EFCEM (European Federation of Catering Equipment Manufacturers).

Filed in French · English published by the European Commission

It appears that the current formulation places sole emphasis on the size of the company when determining the scope of obligations. However, it is important to clarify whether this was the intended approach. It seems disproportionate that a large company, placing only a limited number of primary batteries in one of its products, would be required to comply with the full range of obligations.

Our consortium DigitalTrade4.EU input to the European Commissions Omnibus 2025 proposals focuses on digital trade reforms to enhance the competitiveness of SMEs and Small Mid-Cap enterprises through interoperable infrastructure and reduced administrative burdens.