The Bundesdruckerei Group welcomes the proposal for a regulation establishing a Union certification framework for carbon removals and gladly provides feedback to the European Commission. The Bundesdruckerei Group has identified a number of differences between the requirements formulated in the explanatory memorandum to the act and the proposed method of implementation.
BUN
Bundesdruckerei
Company · Germany · EU Transparency Register 197184824639-83
7
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
3
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1210 companies & groups on this site, they rank #250 by legislative files engaged, a count of participation, not a measure of influence.
0.8
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2016
in the register since
Declares membership of
- https://www.bundesdruckerei.de/de/konzern/gremienarbeit
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Companies & groups
- Registered as
- Bundesdruckerei GmbH
- Head office
- Berlin, Germany
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Bundesdruckerei filed 7 positions between 27 Aug 2020 and 30 Sept 2025, across 6 of the 665 legislative files tracked here, attaching a full position paper 3 times.
2020 · 1 filed2021 · 1 filed2023 · 1 filed2025 · 4 filed
What they argued
The Bundesdruckerei Group explicitly welcomes the European Commission's proposal as an effective legislative framework for the trustworthy and secure handling of data. The envisaged specifications for the use of Data Sharing Services (Art.
The initiative to create a legal act establishing EU-wide rules on a business wallet is very welcome. We see great potential for digitalisation, automation, and cost reduction in B2G- and especially B2B-processes, which have so far been underutilised. However, it must be emphasised that technical automation alone is not enough to reduce bureaucracy.
The Bundesdruckerei (a German federal technology company), which is actively engaged in the development of European Data Spaces, welcomes the European Commission's initiative to introduce a European Business Wallet (EUBW). We consider the EUBW a key enabler of a trustworthy, interoperable, and sovereign digital economy in Europe.
Bundesdruckerei GmbH would like to contribute to the successful creation of a future-proof legal framework to support an EU-wide, trustworthy and secure system for identities and trust services in the digital space.
In general, it should be noted that additional requirements that deviate from the referenced standards should be viewed critically because they interfere with professional discussions and autonomy. Technical standards are written and approved by a large group of experts after thorough discussions and scrutinization.
- In general: Harmonized regulations regarding liability coverage according to Art 24 Abs. 2 lit. c) eIDAS should be integrated into this Implementing Regulation, in particular through liability insurance. Currently, there is still a great deal of fragmentation in the supervisory practices of the member states in this field. Harmonization through uniform requirements is absolutely essential. - Art 1 Nr.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.