BusinessEurope

BusinessEurope welcomes the opportunity to contribute to the Call for Evidence on the future legislative initiative Digital Networks Act (DNA). First we would like to remind that in September 2024, we published a high-level reaction to the White Paper: How to master Europes digital infrastructure needs?.

MAKING CBAM EFFECTIVE AGAINST CARBON LEAKAGE – FIX THE DESIGN AND ADOPT A STEP-BY-STEP APPROACH Effective carbon leakage measures are crucial to level the playing field and support European industry in its decarbonisation efforts. On 1 January 2026, CBAM enters into its definitive phase. Importers of CBAM goods will then have a financial obligation to pay for the embedded emissions, with payments starting in 2027.

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

BusinessEurope welcomes the opportunity to provide feedback on the Draft Guidance for the implementation of the Cyber Resilience Act (CRA). We would like to reiterate and highlight two key points previously raised in our position paper "Simplifying the EU digital rulebook", which remain highly relevant in the context of the current draft guidance.

As mentioned in BusinessEurope's submission to the Evaluation of the Regulation, BusinessEurope is of the opinion that a targeted revision of Regulation 1025/2012 is warranted. Regulation 1025 is quite clear under Art 10.1 that European Standards and European Standardisation deliverables are to be market-driven and take into account public objectives alongside the policy goals of the Commission.

As Europe seeks to strengthen its competitive position in an increasingly interconnected world, it must ensure that the rules are clear, simple, and predictable. BusinessEurope welcomes the European Commissions initiative to assess the effectiveness, coherence, and cumulative impact of the EU digital rulebook.

BusinessEurope believes that global carbon markets are crucial to lay the ground for a global carbon price in the medium to long term, as well as mobilise investments in climate mitigation in a cost-efficient manner and add private climate finance to public efforts.

BUSINESSEUROPE is Europe's largest business organisation and a leading advocate for growth and competitiveness at the EU level. Please find attached our detailed views on how the Tax Omnibus should deliver tangible simplification in practice. We remain ready to engage constructively to ensure that this initiative delivers meaningful simplification and a more effective EU tax framework.

iIt s important that this Package is a strategic enabler of mobility in Europe and that it constitutes a genuine approach to simplification of the rules and procedures with the aim of promoting and facilitating mobility. This is particularly important in terms of the role that mobility can play in helping to overcome persistent labour and skills shortages, while preserving fair competition.

BusinessEurope welcomes the Commissions initiative to recast the Directive on Administrative Cooperation (DAC) and strongly supports the objective of delivering measurable reductions in administrative burden while preserving effective tax transparency. Successive amendments (DAC1DAC9) have resulted in fragmentation, duplication and disproportionate compliance costs, particularly under DAC6.

CEOE fully endorses the European Unions objectives regarding lifelong learning, employability and the adaptation of skills to the digital, green and demographic transitions. Lifelong learning is an essential tool for enhancing peoples opportunities, promoting professional mobility and contributing to a more productive, competitive and inclusive economy.