Cisco Systems

Cisco strongly supports the European Commission's ambition for a Circular Economy Act, recognizing its potential for significant economic and environmental benefits. To unlock the EU's circular economy potential, we recommend establishing a true Single Market for waste and recycling, stimulating demand and supply for secondary raw materials, and facilitating favorable market conditions and investment.

Cisco Systems, Inc. welcomes the European Commissions Industrial Accelerator Act (IAA) proposal, reaffirming its commitment to supporting Europes digital and green transformation. As a long-term partner with 18,000 employees and a robust network of 12,000+ local partners across the continent, Cisco emphasizes that Europes strength lies in its openness and transatlantic cooperation.

The issues encountered by Cisco around public procurement in the EU do not come from the EU Directives themselves, but from national implementation across Member States. There is a great level of fragmentation in terms of public procurement processes, tender requirements and award criteria, even within Member States.

Cisco welcomes the European Commissions initiative to modernize the EUs connectivity framework through the Digital Networks Act (DNA). As a global leader in networking, Cisco views the DNA as a pivotal opportunity to secure Europes digital sovereignty and achieve its 2030 Digital Decade targets.

Cisco welcomes the European Commission's call for evidence looking at designing the future Digital Networks Act (DNA). Digital networks are not only the fundamental backbone for a thriving digital economy and society, but also for enabling Europes security and defense ambitions by ensuring secure communication channels and resilient infrastructure for military and intelligence operations.

Cisco applauds the Commissions work to identify challenges for Europes digital infrastructure and discuss possible public policy responses. We are committed to helping the Commission, and the EU more widely, to meet this challenge. Digital Infrastructures are the backbone of the Internet.

The clarifications provided in the draft guidance on the application of the Cyber Resilience Act (CRA) are very helpful. However, Cisco still has a number of questions and comments about key parts of the guidance, especially on substantial modifications, support periods and remote data processing solutions. We believe important amendments are necessary to ensure an effective CRA application.

Cisco welcomes the opportunity to comment on the upcoming Digital Fitness Check as it should assess how different laws work together, identifying synergies, good practices, and any remaining gaps, overlaps and inconsistencies.

Cisco welcomes the European Commissions initiative to establish a common Union rating scheme for data center sustainability. As data centers become the backbone of Europes digital economy and AI ambitions, Cisco advocates for a strategic shift from a sole focus on capacity expansion to the intelligent modernization of existing infrastructure.

Cisco welcomes the opportunity to provide input to the mid-term review of the Digital Decade Policy Programme (DDPP). As a long-standing partner to European governments, Internet service providers and enterprises, we strongly support the Unions goal of accelerating digitalization while strengthening competitiveness, resilience and secure technological capacity.

On behalf of Cisco, please find attached our analysis of the draft CRA Implementing Regulation. Our comments include revised definitions aimed at enhancing clarity, consistency with international frameworks, and practical implementation for manufacturers. We hope you will find this useful and remain available for any follow-up questions.