Confederation of Industry of the Czech Republic

PRAGUE, DECEMBER 15TH 2025 POSITION OF THE CONFEDERATION OF INDUSTRY OF THE CZECH REPUBLIC (SP ČR) ON THE DIGITAL OMNIBUS The Digital Omnibus marks an important and long-awaited shift in the EU’s approach to digital regulation.

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

Ideas for Simplification - SPCR proposals No. Name and number of Responsible Legal the EU legal act Directorate obligation General Problem definition: reasons for simplification or deregulation How to amend (abolish or Estimated impact change wording, concrete (financial or human proposal how) resources) Proposal Provide the official title ID and citation (e.g., Directive 2006/112/EC on the common system of VAT)…

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

The Confederation of Industry of the Czech Republic (SPČR) welcomes the European Commissions initiative to create the Circular Economy Act (CEA) as a tool to strengthen the EUs competitiveness, strategic autonomy, and climate neutrality. The document emphasizes the need for realistic legislative settings without excessive administrative and financial burdens, with a focus on harmonizing existing rules.

1. The proposal clearly states in recitals 18, 20 and 21 that it will be possible to use valid permits (IPPC) or the EIA process to demonstrate compliance with the DNSH criteria (water, pollution, biodiversity) when demonstrating DNSH with existing permits.

Filed in Czech · English published by the European Commission

PRAGUE, 10 SEPTEMBER 2020 Response to the European Commission’s inception impact assessment on AI ethical and legal requirements Smart government approaches to regulation will play an important role in boosting public confidence and ensuring that AI is used responsibly, while also encouraging innovation.

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

The Confederation of Industry of the Czech Republic (SP CR) appreciates that some of the adjustments called for by industry have been made, for example in the area of the linear reduction factor, the use of revenues, or partial adjustment of the market stability reserve. The proposed adjustments give industry more room to implement decarbonisation measures, but time alone is not enough.

Observations of the Czech Republic on the Market Stability Reserve: In order to further calm the price of the allowance, it is necessary to adjust the current functioning of the Market Stability Reserve (MSR). At present, the MSR only operates unilaterally – constantly withdrawing allowances from the market and thus triggering an increase in their price.

Filed in Czech · English published by the European Commission

The Confederation of Industry of the Czech Republic believes that setting mandatory targets for company vehicles is inappropriate. These targets are counterproductive and threaten the competitiveness of businesses and freight transport operators alike. They also misdiagnose the problem.

The Carbon Border Adjustment Mechanism (CBAM) proposal is not an adequate solution to the risk of carbon leakage. In this form, it will have a major negative impact on the EU industry and, ultimately, an increase in global emissions.

The position of the SP ČR on the proposal to revise the benchmarks for calculating the free allocation of emission allowances The Confederation of Industry appreciates the opportunity to comment on the proposal for a Regulation establishing revised benchmarks for the free allocation of emission allowances for the period from 2026 to 2030 pursuant to Article 10a(2) of Directive 2003/87/EC of the European Parliament…

Filed in Czech · English published by the European Commission

The Confederation of Industry of the Czech Republic (SP CR) considers energy efficiency to be an important part of the gradual decarbonisation of the EU. Companies have invested considerable funds in energy efficiency and plan to invest additional funds. However SP CR is afraid that setting too ambitious energy efficiency targets will lead to cost inefficiency.

Confederation of Industry of the Czech Republic (SP CR) welcomes the opportunity to comment on Inception Impact Assessment to Amendment (IIA) of the EU Emissions Trading System. SP CR understands that following increase in overall ambitions in emission reduction until 2030 changes in ETS are necessary. SP CR would like to submit comments in the attached file for further consideration by the Commission.

The Confederation of Industry of the Czech Republic supports the European Commissions goal of protecting consumers in the digital environment and strengthening trust in new technologies. However, the current EU regulatory framework already provides extensive consumer protection, including through the Unfair Commercial Practices Directive (UCPD), the Digital Services Act (DSA), the Digital Markets Act (DMA), the…

The Confederation of Industry of the Czech Republic welcomes the opportunity to comment on the forthcoming revision of the post-2030 framework for climate and energy targets. For the 2030-2040 framework, we call for maintaining only the headline target in terms of emissions reduction, and not moving towards sub-targets for RES, hydrogen, energy savings, etc.

Filed in Czech · English published by the European Commission

Confederation of Industry of the Czech Republic supports the direction of simplification, however we are of the opinion that even greater pragmatism, legal certainty and consideration of the practical realities of industrial production at key points are necessary, so that the taxonomy can serve as functional means of supporting sustainable investments.

The Confederation of Industry of the Czech Republic welcomes this initiative to increase competitiveness. Among other things, we see the following four problematic points: 1) Unification of concepts and their legal definition (definition).

The Czech Confederation of Industry and Transport (SP ČR) strongly rejects the European Commission’s proposal for a 90 % reduction in greenhouse gas emissions by 2040 compared to 1990. This ambitious objective is considered unrealistic by the SP ČR and risks causing significant additional costs to the Czech industry when applied to the Czech Republic, endangering its global competitiveness and dramatically weakening…

Filed in Czech · English published by the European Commission

Confederation of Industry of the Czech Republic (SP CR) welcomes the opportunity to comment on the Inception Impact Assessment on Hydrogen and Gas markets Decarbonisation Package. SP CR believes he amendment of the Gas Directive and Regulation should achieve the following objectives: maximize synergies between gases (methane) and hydrogen (in particular, repurposing or retrofitting gas infrastructure opportunities)…

The Confederation of Industry of the Czech Republic welcomes the European Commission's initiative regarding the forthcoming implementing and delegated acts intended to regulate the calculation, verification, and import of recycled plastic content in packaging pursuant to Article 7 of the Packaging and Packaging Waste Regulation (PPWR). We have long supported the transition towards a circular economy.

Confederation of Industry of the Czech Republic (SP CR) welcomes the opportunity to comment on the Inception Impact Assessment on Proposal for a legislative act to reduce methane emissions in the oil, gas and coal sectors. From the gas business perspective, methane emissions have been primarily related to security concerns because natural gas leaks could pose a significant safety risk.

The Confederation of Industry of the Czech Republic (SP ČR) has long supported reducing the regulatory burden and the systematic assessment of the cumulative impacts of European digital legislation. The Digital Fitness Check initiative could be an appropriate instrument to identify overlaps, inconsistencies, and disproportionate administrative requirements. However, we fundamentally disagree with its current timing.

The Confederation of Industry of the Czech Republic welcomes the opportunity to comment on the forthcoming revision of the post-2030 framework for climate and energy targets. For the 2030-2040 framework, we call for maintaining only the headline target in terms of emissions reduction, and not moving towards sub-targets for RES, hydrogen, energy savings, etc.

Filed in Czech · English published by the European Commission

PRAGUE, 4 OCTOBER 2021 We support the principle of improving Product Safety throughout the European Union and updating the GPSD into a Regulation, which will enhance harmonization throughout the Union. The GPSD is the overarching product safety legislation that covers all aspects of consumer products not already covered by other sectoral legislation (e.g. specific rules on toys).

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

The Confederation of Industry of the Czech Republic appreciates the opportunity to submit feedback to the European Commission’s inception impact assessment on fairness in platform to business relations. We wanted to provide a couple of reflections on the wider consequences that this sort of platform regulation could have on the growing European platform ecosystem.

On behalf of the Confederation of Industry of the Czech Republic, we would like to submit the following comments and recommendations regarding the revision of Regulation (EC) No 1008/2008. We appreciate the opportunity to contribute to the consultation process and hope that our input will be helpful in refining the final version of the proposal. 1.

The Confederation of Industry is the leading business lobbying organization in the Czech Republic providing a voice for employers at the national and international level. We are here to assert the interest of our members. We speak for companies and associations of all shapes and sizes across the key sectors of industry, including many SMEs.

Opinion of the Confederation of industry of the Czech Rep. (Inception impact assessment): We prefer the solution including all crucial countries which represents consensus at the OECD level. OECD consensus represents a relevant effort to modernise the tax system and to adapt the current tax system to the structure of the economy where new forms of digital business appeared (and for these new forms of business the…

The opportunity to provide feedback on the proposed amendments to Regulation (EC) No 1907/2006 (REACH) concerning substances classified as carcinogens, germ cell mutagens or reproductive toxicants and subject to restrictions is welcomed. The European Unions objectives of protecting human health and ensuring regulatory alignment with updated harmonised classifications are fully supported.

The initiative to strengthen the EU defence single market and reduce fragmentation is strongly supported. Enhancing joint procurement, improving interoperability and reinforcing the European defence technological and industrial base are essential steps towards greater strategic autonomy and operational readiness by 2030.