Bundesarbeitskammer

Europäische Kommission Datum GZ: COM(2025) 836 final Unser Zeichen Bearbeiter/in Tel GEBU/BAK/2025/0859 [name removed] E-Mail 29.01.2026 [phone removed] [email removed] REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU) 2022/2557 as regards the simplification of the digital…

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

Europäische Kommission Datum GZ: COM(2025) 836 final Unser Zeichen Bearbeiter/in Tel GEBU/BAK/2025/0859 [name removed] E-Mail 29.01.2026 [phone removed] [email removed] REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EU) 2016/679, (EU) 2018/1724, (EU) 2018/1725, (EU) 2023/2854 and Directives 2002/58/EC, (EU) 2022/2555 and (EU) 2022/2557 as regards the simplification of the digital…

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

The Federal Chamber of Labour (Bundesarbeitskammer, BAK) welcomes the Commission’s announcement that it will present an EU Circular Economy Act. This is an opportunity to reconcile Europe’s over-consumption of resources with the EU’s sustainability and economic objectives, and is thus primarily covered by Article 192 TFEU (maintaining a high level of environmental protection).

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The Federal Chamber of Labour (Bundesarbeitskammer – BAK) recognises the need for a massive increase in the share of renewable energy in total energy consumption in climate policy and therefore supports the European Union’s ambitious target for 2030 to increase the share of renewable energy throughout the EU to at least 32 %.

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Our REFORM REFORM requests from the point of view of sustainability and European added value are three key points in the revision of the EU public procurement directives: The principle of the best bid rather than the lowest bidder: The obligation for contracting authorities to take into account social and environmental criteria and thus to strengthen the quality of public procurement in terms of social, labour and…

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The Federal Chamber of Labour would like to thank you for the opportunity to comment on the Digital Networks Act (DNA) and would like to share your thoughts on it. The Federal Chamber of Labour (BAK) is the statutory representative body for the interests of around 4 million workers and all consumers in Austria.

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The proposal for a 28th Regime is rejected. The protection of workers’ interests and rights and orderly competition are essential prerequisites for European integration. The proposal does not meet these fundamental requirements of the European economic order, but does not strike the right balance between innovation and social responsibility.

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In the view of the Federal Chamber of Labour, it is essential that the following four points be taken into account in the revision of the Taxonomy Regulation and the delegated acts: 1) Avoid greenwashing: Strict criteria must be maintained to prevent greenwashing and to clearly define sustainable economic activities.

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The BAK considers it essential that these standards are not further reduced or watered down in the subsequent legislative process. With regard to this social standard S 1 and 2, the BAK calls for the reporting requirements to be extended: the entire standard S 1 own workforce and also S 2 workers in the value chain are to be regarded as essential for all reporting companies and must be reported.

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Dear Madam, Dear Sir, Enclosed you will find the statement from the Vienna Chamber of Labor. The Federal Chamber of Labor (BAK) is the legal representation of the interests of around 3.7 million employees and consumers in Austria. It represents its members in all social, educational, economic and consumer policy matters at national and EU level. In addition, the BAK is part of the Austrian social partnership.

The BAK has the following comments on the Geo-blocking Regulation. With regard to the Geo-blocking Regulation, which entered into force on 3 December 2018, there is an urgent need for improvement or clarification in the following two areas.

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The Federal Chamber of Labour (BAK) is convinced that increasing energy efficiency is the key prerequisite for achieving climate and energy policy objectives. Energy efficiency also plays a supporting role in objectives such as combating energy poverty, improving industrial competitiveness and security of supply.

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The Federal Chamber of Labour (BAK) is convinced that increasing energy efficiency is the key prerequisite for achieving climate and energy policy objectives. Energy efficiency also plays a supporting role in objectives such as combating energy poverty, improving industrial competitiveness and security of supply.

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The Federal Chamber of Labour (BAK) is the legal representative of the interests of around 3.7 million workers in Austria. It represents its members in all social, educational, economic and consumer policy matters, both at national and at the EU level in Brussels. The BAK criticises the Commission’s proposal, which has the clear aim of facilitating the cultivation of new genetic engineering in the EU.

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The European Commission proposes to set a binding 2040 climate target by amending Regulation (EU) 2021/1119 (European Climate Law). The target is to reduce net greenhouse gas emissions by 90 % by 2040 compared to 1990 levels. Among other things, as of 2036, it is foreseen to allow limited international credits (CO allowances for emission reductions achieved in third countries under Article 6 of the Paris Agreement).

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Europäische Kommission Prinz-Eugen-Straße 20-22 1041 Wien Datum GZ: Ref. Ares(2025)6194267 Unser Zeichen Bearbeiter/in Tel GEBU/EU/W/2026/0042 [name removed] E-Mail 21.04.2026 [phone removed] [email removed] EU-Konsultation | Vereinfachung der Verwaltung im Bereich des Umweltrechts Die Bundesarbeitskammer (BAK) bedankt sich für die Übermittlung des Entwurfs und nimmt dazu wie folgt Stellung: Zum Inhalt des Entwurfs…

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

Bundesministerium für Justiz BMJ - I 7 (Persönlichkeitsrechte, Gerichtsgebühren, zivilrechtliche Nebengesetze und Rechnungslegung [address removed] E-Mail: [email removed] Ihr Zeichen Unser Zeichen Bearbeiter/in Tel 501 65 GZ: 2021- BW-GSt/Mu [name removed], DW 12701 DW 142701 8.6.2021 [name removed] DW 12293 DW 142293 0.291.563 Fax 501 65 Datum Proposal for a Directive of the European Parliament and of the council…

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

The introduction of natural credits follows the neoliberal logic of solving problems by creating markets. However, this is a deception. The main causes of the environmental and social crisis are the profit-orientation of our economic system, the associated permanent growth pressure and the ever-increasing concentration of wealth.

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Executive Summary - Standardisation is increasingly intervening in industrial relations, work processes and occupational health and safety. - 90 percent of standards are defined at European and international level and must be adopted into the national standardisation system. The involvement of stake-holders such as trade unions and consumer organisations is limited to the role of participation without voting rights.

The Federal Chamber of Labour (BAK) is the statutory body representing the interests of around 3,8 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy issues at national level and in Brussels at European level. 1.) Renewable gas: The production of both biomethane and green hydrogen involves a great deal of resources.

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The Federal Chamber of Labour (BAK) is the statutory representation of approximately 3.7 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy matters at national and EU level. In addition, the BAK is part of the Austrian social partnership and is registered in the EU Transparency Register under number 23869471911-54.

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The BAK welcomes this objective of the planned update of the Late Payment Directive: The immediate settlement of outstanding payments prevents unnecessary liquidity difficulties, especially for small and medium-sized enterprises, which may in the worst case result in the insolvency of the company. Payment delays bind human and financial resources.

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Europäische Kommission Generaldirektion Beschäftigung, Soziales und Inklusion Direktion C, Referat C.3 (Sozialer Dialog) B-1049 Brüssel Belgien Datum GZ: Unser Zeichen Bearbeiter/in Tel GEBU/BAK/2026/0732 Nikolai SOUKUP E-Mail 23.09.2026 [phone removed] [email removed] Quality Jobs Act Die Bundesarbeitskammer (BAK) bedankt sich für die Übermittlung des Entwurfs und nimmt dazu wie folgt Stellung.

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

The BAK is critical of the current draft, in particular for consumers, and calls for all stakeholders concerned to be involved without delay. Cartels and cartel-like cooperation involving indirect price coordination are contrary to Article 101 TFEU. They lead to higher prices for consumers and higher profit margins for individual players.

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Dear Sir, Madam, Please find attached the opinion of the Federal Chamber of Labour (BAK) on the Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulations (EC) No 261/2004, (EC) No 1107/2006, (EU) No 1177/2010, (EU) No 181/2011 and (EU) 2021/782 as regards the enforcement of passenger rights in the Union (COM(2023) 753 final). Yours sincerely,

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The Austrian Chamber of Labour (AK) would like to give the following feedback to the EU Commission´s initiative "Travel - a better protection for passengers and their rights on EU-level": It is well known that the coronavirus pandemic has hit consumers and companies hard, particularly in the field of travel.

Fokus on cities, employees and resource-saving modes! Europe is heading towards a fully decarbonized economy. To reach this goal the pattern of production and consumption will change dramatically. Cycle economy and recycling, local production, and long-lasting and repairable products will become more important. Extraction of raw materials hast to be reduced and altered (f.e.

The AK is the statutory representative body for the interests of 4 million workers and consumers in Austria. We are part of www.kettensaege-stoppen.at and oppose blind deregulation projects. In the light of the Commission’s omnibus proposals to date, the WG has serious concerns about the announced citizens’ omnibus.

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Dear Sir, Madam, Please find attached the opinion of the Federal Chamber of Labour (BAK) on the Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Directive (EU) 2015/2302 in order to improve the protection of travellers and simplify and clarify certain aspects of the Directive (COM(2023) 905 final). Yours sincerely,

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The Austrian Federal Chamber of Labour wishes to sumbit feedback within this initaitive with a position/policy-paper we just recently published on our website https://akeuropa.eu/policy-brief-european-travel-law-addressing-current-issues-and-challenges-light-covid-19, that directly addresses the issues and questions of this initative. Thank you for your consideration!

The Federal Chamber of Labour, representing almost 4 million workers and consumers in Austria, expressly welcomes the revision of the Air Services Regulation. Studies show that air transport workers and consumers need more effective protection and clear definitions and binding rules are needed to prevent unfair competition. The promotion of environmentally sustainable connectivity is strongly supported.

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The Office of the Austrian Federal Chamber of Labour (BAK) would like to contribute to the call for evidence with the following contribution: (1) Proposal for a European Social Security Pass The objectives of the European Social Security Card, namely to facilitate the mobility of workers, to facilitate the work of authorities and businesses and to reduce fraud and errors in the issuing of documents, are supported by…

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The Austrian Federal Chamber of Labour (BAK) is the legal representation of interest for about 4 million employees and consumers in Austria. BAK represents its members in all social, educational, economical and consumer policy matters, both at national and at EU level. BAK welcomes in principle the introduction of a Repair Clause in the Design Directive (Art 19/1).

Abteilung Sozialpolitik – Nikolai Soukup 15.07.2025 Ref. Ares(2025)6164688 - 29/07/2025 „QUALITY JOBS ROADMAP“: EFFEKTIVE EU-AGENDA ZUR STÄRKUNG DER QUALITÄT DER ARBEITSPLÄTZE NÖTIG Die Europäische Kommission hat angekündigt, Ende 2025 eine „Quality Jobs Roadmap“ (oder einen „Fahrplan für hochwertige Arbeitsplätze“) vorzulegen.

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

Not only does the European Commission’s action plan to promote long-distance and cross-border passenger transport show that the current legal situation is extremely unsatisfactory, as companies only protect passengers if they are obliged to do so. In order to encourage as many passengers as possible to switch to cross-border rail travel, the risk of missed connecting means must be fully protected.

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The Federal Chamber of Labour (BAK) is the statutory representation of around 3,7 million employees and consumers in Austria for all social, economic and consumer policy matters. The BAK has already assessed the Commission’s initiative in the context of the White Paper preceding the Regulation and has sent important requests for interest.

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The Federal Chamber of Labour thanks for the opportunity to provide feedback on the important issue of income transparency. We see gender equality as an essential element of a socially just society. Particular attention must also be paid to the unequal pay of women and men. Wage transparency is an important approach to tackling the gender pay gap.

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The Federal Chamber of Labour (BAK) is the statutory representation of the interests of around 3.9 million workers and consumers in Austria. It represents its members in all social, educational, economic and consumer policy matters, both at national and EU level. In addition, the BAK is part of the Austrian social partnership. The BAK is registered in the EU Transparency Register with number 23869471911-54.

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The Bundesarbeitskammer (Federal Chamber of Labour) is grateful for the opportunity to comment on the legal representation of around 4 million workers and consumers in Austria. The simplification of the CAP weakens the principle of public money for public goods. Environmental requirements are withdrawn as a condition for receiving public funding.

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There is no uniform legal framework for railways in the EU neither in the technical nor in the social area. The Commissions proposals, as presented in the document attached to the Consultation (language skills, certification method etc), do not fill the regulatory gap. In order to make transport by rail more attractive, a further harmonization is necessary.

The Federal Chamber of Labour welcomes the opportunity to contribute to the consultation on the future mandate of the European Union Agency for Railways (ERA). The Federal Chamber of Labour is the statutory body representing the interests of more than 3.8 million employees in Austria. It is registered in the EU Transparency Register under the number 23869471911-54.

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The Consumer Unit of the Austrian Federal Chamber of Labour welcomes the Commission proposal to ban CMR 1A/1B substances in childcare products. According to ECHA, childcare products are a significant and largely unregulated source of childrens exposure to toxic chemicals. Also tests by European consumer groups regularly show hazardous chemicals are widely present in childrens products.

While we agree that the double transformation creates a huge investment gap and that a higher investment ratio would be desirable in the current cyclical situation, we see the problem more in high uncertainty and subdued sales expectations. This is also shown by the ECB’s surveys on the access to finance (safe) regularly and most recently.

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Representing 3.8 million workers and consumers in Austria, the Federal Chamber of Labour (Bundesarbeitskammer — BAK) welcomes the European Commission’s initiative and is strongly in favour of a rapid and fundamental revision of the Air Services Regulation. Recent years have shown that Regulation 1008/2008 is not in a position to sufficiently protect the rights of employees and consumers.

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The draft revision of the EU framework for institutions for occupational retirement provision (IORPs) touches upon key issues of pension provision, risk sharing between public, occupational and private provision, governance and suitability requirements for management bodies.

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In the opinion of the Austrian Federal Chamber of Labour, special attention must be paid in the evaluation of the stakeholders to the solutions proposed by the staff representatives (works council, trade union, etc.). This is particularly necessary as the number of stakeholders on the business side is much higher.

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The BAK welcomes the initiative at European level and advocates a comprehensive approach to prevent and effectively combat violence and harassment and to support those affected. The facts set out in the Annex also support the need to address the issue. A wide range of policies is needed, including the world of work.

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