AeroSpace and Defence Industries Association of Europe

ASD is the voice of the European aerospace, security and defence Industries the industry that connects and protects. With 28 major European companies and 24 national associations, the overall representation adds up to more than 4,000 companies across 22 European countries.

ASD represents the interests of the European Aerospace, Security and Defence Industries. With 26 major European companies and 23 National Associations members, the overall representation adds up to more than 4,000 companies across 21 European countries. We are actively supporting the competitive development of the sector in Europe and worldwide.

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

ASD welcomes the European Commissions legislative proposal for a Regulation aimed at securing the supply of critical and strategic raw materials. Given the EUs aerospace and defence sectors almost exclusive reliance on raw materials imports, we strongly support attempts by EU decision-makers to build more resilience in the supply of CRMs.

Feedback ASD Position on the Multiannual Financial Framework (MFF) 2028-2034 Note from the ASD Secretary General: This paper was developed by the ASD Civil Aviation community and reflects its views. The perspective from the Defence and Security industry community is under development and will be reflected in a subsequent paper, particularly on the link between the Horizon Europe and the European Competitiveness…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ASD is the voice of European Aerospace, Security and Defence Industries. With 26 major European companies and 23 National Associations as our members, the overall representation adds up to more than 4,000 companies across 21 European countries. We are actively supporting the competitive development of the sector in Europe and worldwide.

The Cybersecurity Act (the CSA) set a permanent mandate for the European Union Agency for Cybersecurity (ENISA) and established a European Cybersecurity Certification Framework (ECCF) for voluntary European cybersecurity certification schemes for ICT products, services and processes.

Revision of the Regulation on classification, labelling and packaging of chemicals (CLP) Contact: [name removed] ASD views on the European Commission’s proposal to revise the Regulation on classification, labelling and packaging of chemicals (CLP) ASD is the voice of the European Aerospace, Security and Defence Industries, representing directly or indirectly (through our national association members) over 3,000…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

ASD welcomes formal inclusion of the aviation sector within the EU Taxonomy framework and the opportunity to provide feedback on the proposed amendments to the EU Taxonomy Climate Delegated Act. We appreciate the European Commissions continued efforts and the visible changes introduced since the previous stakeholder consultation.

To be successful, the NZIA must be fully consistent with the Green Deals objectives and the Fit for 55 package and ensure that no technology that is crucial to reach the EUs climate objectives is left behind, especially where the US IRA targets this technology. Consistency should also be ensured with other transversal regulatory initiatives, such as the Temporary Crisis and Transition Framework.

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

ASD welcomes the EU Commissions initiative to update the EUs Aviation Strategy and to formally include the aeronautics sector in the strategy. Civil aeronautics is currently one of the EUs few remaining globally leading industries and a strategic asset for competitiveness, technological leadership, strategic autonomy, exports, defence spillovers, and decarbonisation.

Aerospace and Defence Industries Associations of Europe (ASD) thanks the European Commission for this opportunity to comment on the proposal. ASD welcomes the EU’s Refuel EU Aviation initiative; we support the intent of the initiative to boost the production and uptake of sustainable aviation fuels (SAF) to ensure their large-scale availability at low costs in the medium and long term.

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for the possibility to comment on their inception impact assessment on ReFuelEU Aviation - Sustainable Aviation Fuels. ASD fully supports the intent of the initiative to boost the production and uptake of sustainable aviation fuels (SAF) to ensure their large-scale availability at low costs in the medium and long term.

ASD welcomes the Commission's initiative to develop an Advanced Materials Act and shares the ambition for increasing the efficiency, sustainability and competitiveness of European industry. The Commission rightly highlights that advanced materials play a key role in areas such as space and defence - but also civil aeronautics.

The European Aerospace, Security and Defence Industries Association (ASD) wishes to express concern on two regulatory obstacles that are limiting the ability of European banks to finance the defence industry, especially SMEs in the defence supply chain, at the moment when Europe needs this financing most.

Here attached is the feedback provided on behalf of the Aerospace, Security and Defence Industries Association of Europe (ASD) . We welcome the Commission's white paper on EU support to R&D for technologies with dual-use potential. It is a complex but important issue, which is of particular relevance to our industries given the inherently dual civil-military nature of a lot of our technologies.

ASD is the voice of the European aerospace, security and defence industries. With 28 major European companies and 24 national associations, the overall representation adds up to more than 4,000 companies across 22 European countries.

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to provide comments to the call for evidence on the “European Chemicals Agency – proposal for a basic regulation”.

ASD welcomes the opportunity to provide feedback to this consultation on the development of ecodesign requirements for iron and steel products. In the following, we would like to share our considerations pertaining to the A&D sector to help ensure that the requirements are workable for our industry, taking into account its specific characteristics, including long product lifecycles, complex global supply chains, and…

Review of certain POPs limits in waste ASD comments on Hazardous waste - updated concentration limits for chemical pollutants Aerospace & Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on the update of concentration limit values of persistent organic pollutants in waste.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on their proposals to amend the EU ETS with regards to aviation and the overall system. ASD is committed to the ultimate objective to reach a net-zero emissions aviation ecosystem in Europe by 2050, and to strongly contribute to the EU’s 2030 ambition.

AeroSpace and Defence Industries Association of Europe (ASD) thanks the European Commission for this opportunity to comment on its plans for the revision of the EU Emission Trading System Directive 2003/87/EC concerning aviation.

ASD would like to use this opportunity to share some concerns regarding the amendment of Annex I to Regulation (EU) 2019/1021 to include medium-chain chlorinated paraffins (MCCP) as substances subject to certain restrictions.

ASD welcomes the proposed European Chips Act, which has the potential to strengthen Europe’s position in the global semiconductor value chain and its security of supply. This can enhance the EU’s resilience, strategic autonomy, technological sovereignty, and industrial competitiveness.

ASD welcomes all initiatives that aim at creating the conditions that support the competitive development and resilience of the Union's defence industry. A strong EDTIB is vital for Europe's defence readiness, especially in today's geopolitical and security environment.

Attached is the feedback provided on behalf of the Aerospace, Security and Defence Industries Association of Europe (ASD). It presents the European defence industrys preliminary considerations on the Programme for Agile and Rapid Defence Innovation (AGILE).

ASD would like to thank the European Commission for giving the opportunity to stakeholders to provide feedback on this proposal, as part of implementing the Commission's Better Regulation Agenda. ASD would like to outline the key specificities of the aerospace and defence sectors and propose improvement areas in order to enhance the functioning of the POP regulation within the various EU chemicals legislation.