BusinessEurope

BusinessEurope appreciates the opportunity to provide feedback to the call for evidence. This document puts forward a series of concrete examples to illustrate where and how (digital) regulation can and must be simplified to reduce the burdens that hold back European businesses.

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?.

BusinessEurope acknowledges the Commissions draft Delegated Act published on 8 May 2026 amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain European Sustainability Reporting Standards (ESRS). We recognize and appreciate the Commissions efforts to introduce targeted improvements to EFRAGs original work with the objective of alleviating reporting burdens on companies.

BusinessEurope welcomes the positive tone of the Commission’s White Paper acknowledging the many opportunities that AI can bring to Europe’s economy and society. We support the Commission in its venture to build ecosystems of excellence and trust in Europe for Artificial Intelligence (AI).

COMMENTS 13 November 2020 INCEPTION IMPACT ASSESSMENT ON SUSTAINABLE PRODUCT POLICY INITIATIVE (SPPI) We thank the European Commission for the opportunity to provide comments on the inception impact assessment of the Sustainable Product Policy Initiative (SPPI).

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

Comment 1 April 2020 BUSINESSEUROPE COMMENTS CARBON BORDER ADJUSTMENT MECHANISM INCEPTION IMPACT ASSESSMENT BusinessEurope is grateful for the opportunity to provide comments to the inception impact assessment of the carbon border adjustment (CBA) mechanism under the EU Green Deal. CBAs are arguably a sensitive measure and BusinessEurope at this point does not take a position for nor against it.

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

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)

Position Paper 14 July 2021 CORPORATE SUSTAINABILITY REPORTING DIRECTIVE Executive summary • The business community is fully committed to global sustainability and to driving investment more into sustainable activities. More and more companies take an active role in this by integrating sustainability in business strategies and practices.

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

Over the years BusinessEurope consistently called for encouragement of all players in the value chain to ensure products, processes and systems are cybersecure from the earliest stage of the engineering process in a dynamic way, thereby also promoting responsible innovation through security-by-design.

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.

BusinessEuropes views on Union Customs Code Reform Key Messages: 1. EU Customs are subject to increasing pressures from enormous e-commerce volumes to ever-growing non-financial measures. The UCC reform is therefore more urgent than ever. BusinessEurope fully supports this reform, which is crucially needed.

The reform of the Union Customs legislation presents a timely and excellent opportunity to modernise EU Customs, to stay fit for purpose in a rapidly changing international trade environment. It is especially important that this revision helps with harmonising the application of UCC across Member States as well as restoring the balance between customs obligations and simplifications for business.

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.

BusinessEurope highly appreciates the Commissions efforts to follow up on the reduction of reporting requirements by 25% with a publication of respective measures in the Commission Annual Work Program 2024. We also welcome the Commissions confirmation to expand this work by launching this call for evidence.

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.

BUSINESSEUROPE is the leading advocate for growth and competitiveness at the European level, standing up for companies across the continent and actively campaigning on the issues that most influence their performance. We speak for enterprises of all sizes in 35 European countries whose national business federations are our direct members. Patents are meant to stimulate innovation.

BUSINESSEUROPE is the leading advocate for growth and competitiveness at the European level, standing up for companies across the continent and actively campaigning on the issues that most influence their performance. We speak for enterprises of all sizes in 35 European countries whose national business federations are our direct members.

BusinessEurope welcomes the opportunity to provide feedback on the proposed amendment to the Regulation (EU) No 1025/2012 European Standardisation. Standardisation is a key priority for our members and its governance is a strategic question. Therefore, we reiterate the importance to involve and properly consult stakeholders on these important issues.

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 COMMENTS TO THE INCEPTION IMPACT ASSESSMENT ON THE REVIEW OF THE EU DESIGN PROTECTION LEGISLATION BUSINESSEUROPE is the leading advocate for growth and competitiveness at European level, standing up for companies across the continent and actively campaigning on the issues that most influence their performance.

BusinessEurope welcomed the White Paper on Foreign Subsidies and submitted its comments on the dedicated consultation in September 2020. To ensure that the instrument delivers on its objective, is efficient, and does not impose an undue burden on companies, it is essential that the different modules presented therein be subject to a thorough impact assessment (IA), particular regarding scope, thresholds and…

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.

INPUT 9 September 2026 BusinessEurope input to Call for Evidence: ILAs ctive Labour Market Policies Overall comments 1. BusinessEurope supports the objective of increasing participation in relevant upskilling and reskilling ,and to share best practices among the Member States.

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

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.

Towards an EU anti-coercion instrument – messages from BusinessEurope General remarks: • BusinessEurope generally welcomes the Commission’s proposal to introduce an EU instrument to protect the EU and the Member States from economic coercion by third countries. In an increasingly challenging geopolitical and environment, it is important that the EU is equipped with the necessary instruments to protect its interests.

BusinessEurope generally welcomes the European Commissions proposal for a Regulation on the screening of foreign investments in the Union, published on 24 January 2024. Our guiding principle is that the EU needs to remain an open and attractive destination for trade and investments, while risks related to security and public order stemming from certain types of investments need to be addressed effectively, in a…

BusinessEurope collected a lot of evidence on the problems companies faced during the Covid19 crisis when the Single Market was severely disrupted. On the basis of that evidence, it is clear that the four freedoms of the Single Market are key in serving the urgent needs of the society in dire times.

BusinessEurope strongly opposes the European Commission’s proposal to introduce more qualified majority voting in social policy. The Commission wrongly asserts in its roadmap that this initiative is a response to citizens’ expectations, whereas opening a debate on this issue could undermine trust in the European Commission and its actions, as well as be counterproductive.