CONFAPI - Confederazione Italiana della Piccola e Media Industria Privata

Confapi, the Italian Confederation of Small and Medium Private Industry, represents and supports Italys industrial SMEs the backbone of the national productive system. Confapi welcomes the initiative for a Circolar Economy Act (CEA), recognizing circularity as essential for the EUs strategic autonomy and competitiveness.

Confapi, the Italian Confederation of Small and Medium Private Industry, represents a wide-ranging system: more than 116,000 industries, up to 1,200,000 employees, 63 local and regional associations, 13 productive sectorial federations, and 2 groups of interest. The Confederation welcomes the Commissions initiative as a decisive step towards restoring manufacturing as a strategic priority for Europe.

Confapi, the Italian Confederation of Small and Medium Private Industry, represents a wide-ranging system: more than 116,000 industries, up to 1,200,000 employees, 63 local and regional associations, 13 productive sectorial federations, and 2 groups of interest.

The recognition of the carbon price already paid in third countries can be a useful tool to avoid double taxation, but it requires very strict criteria. It represents a critical and potentially dangerous aspect of the CBAM, which Confapi rejects in its current design.

Confapi welcomes the opportunity to contribute to the public consultation on the Commissions draft Delegated Regulation amending Annex I of Regulation (EU) 2023/1115 (EUDR), and appreciates the efforts made to improve legal clarity and reduce compliance burdens, particularly for SMEs.

Confapi, representing Italian private industrial SMEs, acknowledges the importance of the CBAM in preventing carbon leakage but considers its current design disproportionate and burdensome for Industrial SMEs. The calculation methodology must ensure environmental integrity, legal certainty and proportionality of obligations, avoiding duplication with existing rules under Regulation (EU) 2023/956, the EU ETS…

The gradual phase-out of free allowances under the EU ETS system, scheduled between 2026 and 2034, represents a crucial transition that coincides with the full entry into force of the CBAM. The implementing act under Article 31 of Regulation (EU) 2023/956 must clearly define how free allocation will be translated into a discount on CBAM certificates, ensuring equal treatment between goods produced in the EU and…

Confapi, Confederazione Italiana della Piccola e Media Industria Privata, accoglie con favore l'iniziativa della Commissione europea di avviare una valutazione approfondita delle Direttive 2004/9/CE e 2004/10/CE in materia di Buone Pratiche di Laboratorio (BPL).