1) PEN-CP suggestions for direct edits and additions to the draft directive 1.1 Given all the background explained below (2), we consider customs as a “critical entity” that is responsible for providing “essential services” for society. We therefore propose that Customs would play a role in the Critical Entities Resilience Groups. (Directive draft page 23).
2020/0365(COD) · In Force
Resilience of critical entities
43 submissions from 38 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 61 submissions on this file. Shown here: the 43 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
28 submissions from industry — companies and their trade associations — against 1 from civil society: NGOs, consumer organizations, environmental groups and trade unions. That is 28 industry submissions for every one from civil society.
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
- 18 of 38
- in the EU Register
- 124
- full-time lobbying staff
- €25.9M+
- declared costs a year
- 99
- 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 8 Apr 2021 — it ran from 16 Dec 2020.
- Where it stands
- Awaiting adoption
- Legislative stage
- In Force
- Procedure
- 2020/0365(COD)
- Commission reference
- COM(2020)829
How it got here
- Impact assess incep7 Aug 2020
- Prop dir8 Apr 2021
Showing 25 of 43 submissions.
The changing nature of the threat landscape requires better protection and more investment in the EU’s resilience capacities to secure our critical infrastructure. DIGITALEUROPE welcomes the Commission’s effort to strengthen the resilience of critical entities across the EU by developing and updating relevant legislation.
Enagás, S.A.
· · filed 8 Apr 2021 · source
As regards the Directive, Enagás would like to send the following messages: • “In order to verify compliance with the Directive, control mechanisms (inspections, monitoring, audits, request for information...) shall be put in place” — > Certification in certain international regulations related to resilience should be taken into account as evidence of such compliance in order to reduce the administrative burden on…
Filed in Spanish · English published by the European Commission
The RIPE NCC has contributed to the development of the Internet in Europe for nearly thirty years and provides a number of technical services that support the functioning of the global Internet, including operating one of the world’s 13 global DNS root servers (K-root) and acting as the Regional Internet Registry for Europe.
MOL Group’s draft input to critical infrastructures roadmap consultation: Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach.
Euroheat & Power
· · filed 8 Apr 2021 · source
Euroheat & Power welcomes the European Commission’s proposal to improve the protection of ‘critical entities’ in the EU and is grateful for the opportunity to provide feedback. The Directive 2008/114/EC on critical infrastructure is providing a focus which is too narrow and some provisions/definitions which are too general to address in an effective manner the rapidly changing picture of systemic risks faced by…
Enedis, the main electricity DSO in France, operating 95% of the French territory, warmly welcomes the European Commission’s proposal. The current ECI Directive is no longer adapted to new threats and increased interdependencies between different sectors.
Proposal for a Directive of the European Parliament and the Council on the resilience of critical entities FEDENE’s contribution FEDENE is a French professional association representing 500 energy and environmental service companies.
GIRP - European Healthcare Distribution Association
· · filed 8 Apr 2021 · source
GIRP welcomes the Proposal for a directive of the European Parliament and of the Council on the resilience of critical entities and the harmonisation purpose it serves to apply a uniform approach in identifying critical entities, while also accounting for specificities at national level, including varying levels of risk exposure and interdependencies between sectors and over borders.
ENGIE Group’s response to the public consultation on the proposal for a directive on the resilience of critical entities ENGIE welcomes the proposal of the European Commission for a directive on the resilience of critical entities, as ENGIE is particularly involved in the subject as member of the ad hoc steering committee of OECD.
The European Organisation for Security (EOS), as the representative of the European Industrial and Research Security Community, welcomes the Commission initiative of renewing an EU approach to Critical Infrastructure protection.
McKesson Europe
· · filed 7 Apr 2021 · source
McKesson Europe welcomes the Proposal for a directive of the European Parliament and of the Council on the resilience of critical entities. The ongoing COVID-19 crisis has demonstrated the need for a strong and coordinated critical infrastructure at national level to ensure rapid and effective intervention in the event of cross-border health threats and future pandemics.
Bitkom agrees that the existing framework for protecting critical infrastructures is inadequate in the light of increasing interdependencies and evolving risks. The changing nature of the threat landscape requires both better protection and more investment in resilience capacities to secure our critical infrastructure.
European Organisation for the Safety of Air Navigation (EUROCONTROL)
· · filed 7 Apr 2021 · source
EUROCONTROL Corporate Security Service welcomes the initiative from DG HOME to provide feedback on the proposal for a new directive on the resilience of critical entities. EUROCONTROL Corporate Security Service supports the scope enlargement in terms of sectors, risks and mitigation measures foreseen in this proposal compared to the 2008/114/EC directive.
As the voice of German industry, BDI highly appreciates the opportunity to provide feedback on the European Commission’s proposal for a Directive on the Resilience of Critical Entities (COM(2020) 829). German industry welcomes the European Commission’s aim to strengthen the resilience of critical entities in the Member States and to further level the playing field for critical entities across the European Union.
Microsoft welcomes the 2020 CER Directive proposal and kindly uses this consultation to share its views on the proposal with the European Commission. We are currently witnessing and experiencing an increase in attacks against digital critical infrastructures.
UP KRITIS is a private-public partnership of operators of essential services (OES) and public authorities. This statement is the result of the business representatives (OES) in UP KRITIS , who welcome the EU project but give some points to consider. 1.
ÖBB-Holding AG
· · filed 20 Jan 2021 · source
- Protection of critical infrastructure is a sovereign task. - To ensure the international continuity/usability of critical infrastructure in the event of a crisis, an overarching European concept is needed to protect it. Europe-wide cooperation is indispensable in the implementation of this concept.
Bombardier Transportation welcomes the European Commission’s determination to improve the protection of critical infrastructure in the EU and is grateful for the opportunity to provide feedback on this roadmap, towards new legislative proposals for measures to enhance the protection and resilience of critical infrastructure.
H2020 project IN-PREP (GA number 740627)
· · filed 7 Aug 2020 · source
This feedback is provided as coordinator of the H2020 project IN-PREP (GA number 740627). More info about the project can be found here: https://www.in-prep.eu/ Transboundary crises pose a specific set of complex challenges for which Europe is – despite recent policy initiatives (e.g. Decision No 1313/2013/EU) – still ill prepared.
H2020 project Ingenious (GA number 833435)
· · filed 7 Aug 2020 · source
This feedback is provided as coordinator of the H2020 project Ingenious (GA number 833435). More info about the project can be found here: https://ingenious-first-responders.eu/ Europe remains vulnerable to a wide range of natural and manmade hazards (such as flood, earthquake, industrial accidents, terrorism, critical infrastructure losses, etc.), with disasters causing tremendous repercussions in human life and…
H2020 project Cyber-MAR (GA number 833389)
· · filed 7 Aug 2020 · source
This feedback is provided as coordinator of the H2020 project Cyber-MAR (GA number 833389) - www.cyber-mar.eu/ Protection of Critical infrastructure becomes today a complex issue with an urgent need to cover physical, cyber and hybrid threats as well.
Secrétariat général de la défense et de la sécurité nationale (SGDSN)
· · filed 7 Aug 2020 · source
This opinion on the Inception Impact Assessment is issued by the Secretariat-General for Defence and National Security (SGDSN) in its capacity as Critical Infrastructure Protection Point of Contact (CIP POC) and does not commit the official position of France, which will be the subject of in-depth interministerial consultations in the coming months.
Filed in French · English published by the European Commission
MOL Group’s input to critical infrastructures roadmap consultation Critical infrastructures and their special management to avoid risks related to economy and all citizens is an important area, where there is a need for harmonized EU approach.
H2020 FINSEC project consortium
· · filed 7 Aug 2020 · source
H2020 FINSEC Comments on the CIP Directive Following paragraphs provide the H2020 FINSEC project’s feedback on the DG HOME’s Recent CIP Directive titled: “Proposal for measures to enhance the protection and resilience of critical infrastructure”. FINSEC is developing and validating a platform for Cyber-Physical Threat Intelligence (CPTI) that targets the protection of critical infrastructures of the finance sector.
The response to the public consultation on the ‘proposal for measures to enhance the protection and resilience of critical infrastructure’ initiative is on behalf of the EU Horizon 2020 project ‘SAFECARE: SAFEguard of Critical heAlth infrastructuRE’ (grant agreement number 787002).
As the voice of the German digital economy, Bitkom highly appreciates the opportunity to provide feedback on the European Commission’s consultation on the possible review of the existing European Critical Infrastructure Directive. Please take our extensive feedback from the attached file.
European Organisation for the Safety of Air Navigation (EUROCONTROL)
· · filed 6 Aug 2020 · source
EUROCONTROL Corporate Security Service welcomes the initiative of DG HOME D2 to provide recommendations in the context of protection and resilience of European Critical Infrastructures (ECI). As the 2008/114/EC Directive focused on the identification and designation of ECI, the text gives very little guidance on how to effectively protect ECI, apart the designation of a Security Liaison Officer (SLO) and the…
DIGITALEUROPE welcomes the opportunity to provide a response to the Commission’s consultation on the possible review of the existing Critical Infrastructure Directive (hereinafter “ECI Directive”) and the subsequent inception impact assessment.
öljypooli c/o Kemianteollisuus ry
· · filed 6 Aug 2020 · source
My feedback is based on the experience of the oil pool and the natural gas section of the Finnish security of supply organisation, as well as my own work in international companies and projects. The aim is good and acceptable – of course. The exchange of information is always needed between countries and the relevant owners.
Filed in Finnish · English published by the European Commission
DEFENDER H0202 Project (GA number 740898)
· · filed 5 Aug 2020 · source
This feedback is provided as coordinator of the H2020 project DEFENDER (GA number 740898) - www.defender.eu. DEFENDER welcome and fully support processes of the Commission’s initiative to review the European Critical Infrastructure Directive and also harmonize with the other Regulations already focused on securitize European physical and cyber landscape, such as NIS Directive, General Data Protection Regulation…
SecureGas H2020 Project
· · filed 5 Aug 2020 · source
This feedback is provided as coordinator of the H2020 project SecureGas (GA number 833017). More info about the project can be found here: www.securegas-project.eu. SecureGas welcomes the initiative since this is fully in line with the project view and outcomes that looks for emerging and complex risks, considers interdependence among critical infrastructure as a key impact factor and put "resilience" at the heart…
InfoCert S.p.A. is leading eIDAS qualified certification authorities in Europe and it's part of a Group that is the first pan-European QTSP (Qualified Trust Services Provider): the digital benchmark in the market for trusted services.
Enel Group welcomes the Commission’s initiative and the intent to intensify the pace of the measures to enhance the protection and resilience of critical infrastructure through the establishment of a more comprehensive legislative framework.
FORATOM response Nuclear energy as an essential element of Europe’s critical infrastructure The COVID-19 pandemic has shown the importance of a robust and resilient energy system. Amid the pandemic, access to electricity has been essential for citizens, businesses, and hospitals.
EurEau - European Federation of Water Services
· · filed 3 Aug 2020 · source
EurEau welcomes the opportunity to share its feedback to the roadmap on the proposal for measures to enhance the protection and resilience of critical infrastructure and welcomes the intention of the Commission to carry out an impact assessment on all the options under consideration. EurEau’s members have a preference for Option 2.
Water Europe highlights that the European Directive 2008/114/EC on protection of critical infrastructures has not included the water supply sector as a critical infrastructure, although Member States recognise that the water industry is vital to the overall EU and national security, essential to any other economic sector and social functions.
Enedis, the main electricity Distribution System Operator in France, which operates 95% of the French territory fully supports the need for an evolution of European Critical Infrastructure identification framework in Europe. Enedis also welcomes that additional measures on cybersecurity issues have been included to the European Commission’s 2020 work programme.
Verband der Chemischen Industrie (VCI)
· · filed 29 Jul 2020 · source
Association of the Chemical Industry (VCI) – Opinion (24 July 2020) Ö 1. Mixing of Critical Infrastructure Protection (CIP) and Essential Services is rejected The CIP Directive 2008/114/EC prioritises terrorist risks. The measures are primarily designed to counter external attacks targeting individual institutions. Essential Services focus on the availability of complex supply chains and services.
Filed in German · English published by the European Commission
This feedback is provided on behalf of the H2020 STOP-IT Project (Grant agreement n. 740610) (https://stop-it-project.eu/) (2017-2021) by the Coordinator. The European Directive on protection of critical infrastructures do not yet include the Water sector, although member States recognise water supply as vital to national security and its vulnerability to threats (cyber and/or physical) is increasing along with the…
Under the provisions of the Defence code, the French legislative framework for critical infrastructure protection is one of the most robust at the European level. As a critical infrastructure operator (CIO), RTE bears all the expenses for the protection of electricity transmission network infrastructures on the French national territory.
VALENCIAPORT FOUNDATION
· · filed 9 Jul 2020 · source
In recent years, the digital transformation has changed the security vision. In this regard, Critical infrastructures, like ports, find growing physical and cyber threats. Obviously, the increasing digitization, as well as the ever-growing interconnection with hinterland carriers and other supply chain partners, are bringing up various new security challenges to ports and their infrastructures, the cyber threats…
SOS - Save Our Spectrum
· · filed 8 Jul 2020 · source
Quoting "potential threats associated with new and emerging technologies (such as drones, 5G, artificial intelligence)": It is of great importance that frequencies for terrestrial transmission remain secured (terrestrial television). Terrestric transmission is secure and cannot be switched off by third countries like satellites. Nor can it be interrupted like the Internet.
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.