Confederation of Swedish Enterprise

The Packaging and Packaging Waste Regulation (PPWR) aims to reduce packaging waste, increase recyclability and reuse, and strengthen the circular economy across the EU. These objectives are widely supported by Swedish business, as is the use of EPR fees to finance and further improve the collection, sorting and recycling of packaging waste.

The Confederation of Swedish Enterprise welcomes the opportunity to respond to this consultation. For ease of reference, our detailed responses and recommendations are set out in the attached. The omnibus proposals must not stand alone but should be the first in a series of reforms. SN is pleased to see the Commissions committed to further simplification initiatives via the Digital Fitness Check.

General: If EU could ensure harmonised application of all digital regulations, it would make compliance less burdensome. Further, it would be rational to clear burdens of administrative requirements like documentation that do not increase the protection of consumers or society.

Europes transition to a circular economy must go hand in hand with industrial competitiveness, innovation and open markets. The linked paper holds 14 recommendations from the Swedish business community on how to make the circular economy work better for companies, large and small, while strengthening Europes resilience and environmental performance.

While we broadly share the Commissions assessment of the challenges, we consider many of the proposed measures to be problematic from a competitiveness perspective. Below and attached, we summarise our primary recommendations to improve the proposal. Maintain the broader scope of countries considered equivalent to EU origin, to ensure that the EU complies with its international commitments.

In its response to the consultation to the EU Commission, the Confederation of Swedish Enterprise has stressed the importance of well-functioning public procurement that creates competition, transparency and efficiency. Our own research shows that the main problems in today's system are: Lack of competition - A high proportion of procurements are won by previous suppliers.

POSITION PAPERCONFEDERATION OF SWEDISH ENTERPRISE Ref. Ares(2025)5711470 - 14/07/2025 Call for evidence EU Digital Networks Act Europe’s digital infrastructure is greatly influenced by new technologies and a new geopolitical landscape. It is essential that the infrastructure is secure, reliable, and resilient throughout the EU.

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

Position on the Packaging and Packaging Waste Regulation (PPWR) by the Confederation of Swedish Enterprise This document contains the Confederation of Swedish Enterprise’s (hereafter Swedish Enterprise) position on the Packaging and Packaging Waste Regulation. Swedish Enterprise is Sweden’s largest business federation, representing over 60 000 member companies in all sectors with almost two million employees.

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

Thank you for the opportunity to provide comments to the European Commissions call for evidence for an impact assessment relating to a potential new optional EU-wide 28th regime company form. The Confederation of Swedish Enterprise has 60,000 member companies organized in 49 business and/or employer associations. Our comments to the European Commissions call for evidence are included in the attached letter document.

The Confederation of Swedish Enterprise welcomes the European Commission's initiative to improve access to critical and strategic raw materials for business in the EU. It notes that this is both through the intention to promote opportunities for exploration, mining, processing and recycling as well as the ambition to strengthen trade relations with like-minded countries.

The Confederation of Swedish Enterprise welcomes the opportunity to respond to the public consultation on the revised European Sustainability Reporting Standards (ESRS). The implementation and initial years of reporting under ESRS Set 1 have provided clear evidence that the current framework is overly complex and disproportionate in relation to its objectives.

Comments by the Confederation of Swedish Enterprise on the European Climate Law The Confederation of Swedish Enterprise welcomes the Commission's proposal for a new 2050-target, ensuring that the EU becomes the world's first climate-neutral continent. However, climate neutrality by 2050 will not be sufficient on its own.

The Confederation of Swedish Enterprise supports the goal of reaching climate-neutrality by 2050 and believes that it is essential that the EU stays at the forefront of the fight against climate change. For the EU to stay at the forefront of global climate action the EU must ensure not only that emissions decrease and reach net-zero by 2050 but also that businesses and societies continues to grow.

Confederation of Swedish Enterprise represents 49 sector-member organisations and 60,000 member companies and would like to state the following in light of the European Commission’s consultation on the artificial intelligence act, AIA.

Svenskt Näringslivs position om EU-kommissionens förslag på revidering av avfallsdirektivet (2008/98/EG) Svenskt Näringsliv företräder drygt 60 000 små, medelstora och stora företag. Dessa är organiserade i 49 bransch- och arbetsgivarförbund. Förbunden utgör föreningen Svenskt Näringslivs medlemmar. Svenskt Näringslivs ställningstagande har utarbetats efter samråd med berörda branschförbund inom Svenskt Näringsliv.

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

The Confederation of Swedish Enterprise is the main business association in Sweden representing 60,000 companies and 50 national industry and employer organisations. Please find our feedback to the proposal in the enclosed document. We would be happy to furnish more detailed information on the points raised, if this would be of interest.

The Confederation of Swedish Enterprise (“Svenskt Näringsliv”) is the main business organization in Sweden, representing 50 member organizations (industry and employer organizations) and over 60.000 member companies, among them most listed companies. It represents almost all sectors of business with the exception of the banking industry.

The Confederation of Swedish Enterprise fully support the European climate ambitions to achieve climate neutrality by 2050, and the intermediate targets set up within Fit-for-55. The Confederation of Swedish Enterprise further supports a continued high ambition for the net greenhouse gas emissions target for 2040 and firmly believe that cost-efficient carbon pricing should continue to be a main feature of the EUs…

This document contains Swedish Enterprise’s initial comments on the Sustainable Product Initiative and the Ecodesign requirements for sustainable products regulation (ESPR) presented on March 30 by the European Commission. Confederation of Swedish Enterprise is Sweden’s largest business federation, representing 60 000 member companies in all sectors with almost 2 million employees.

Inception Impact Assessment for Sustainable Product Initiative We thank the European Commission for the opportunity to provide comments to the Inception Impact Assessment (IIA) on the Sustainable Product Initiative (SPI). The Confederation of Swedish Enterprise welcomes the European Commission's action plan on circular economy and the SPI.

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

The Confederation of Swedish Enterprise sees climate change as a major challenge, one which should ideally be dealt with by introducing a global CO2 price. This should continue to be the overarching goal, but even without such a price, we support the EU ambition to become climate neutral by 2050.

The Confederation of Swedish Enterprise supports the EU ETS as the cornerstone of European climate policy. A well-functioning ETS must provide an effective and predictable investment signal for industrial decarbonization, while ensuring effective protection against carbon leakage for sectors exposed to global competition.

The Confederation of Swedish Enterprise supports efficient use of energy and increased energy efficiency across the EU. Cost efficient energy efficiency improvements can led to positive socio-economic effects and The Confederation of Swedish Enterprise emphasizes the importance of these improvements being realized.

Comments from the Confederation of Swedish Enterprise on the roadmap consultation on the EU ETS The Confederation of Swedish Enterprise fully supports the objectives of the European Green Deal and we strongly support the goal of reaching net zero greenhouse gas emissions by 2050. Further the Confederation of Swedish Enterprise is open to discuss a more ambitious 2030-target.

The Confederation of Swedish Enterprise (SN) welcomes the goal of strengthening the EU's cybersecurity and reducing fragmentation in the internal market. Unfortunately, the European Commission is not taking the opportunity to significantly facilitate compliance and streamline the complex set of cybersecurity rules adopted in recent years.

The Confederation of Swedish Enterprise Welfare the Green Deal and the holistic perspective that chartered the strategy and we also support the EU ambition to be neutral by 2050. Both the Commission and the Member States (MS) need to conclude to a long-term policy framework with specific objectives, and simple and clear rules to provide the this stable environment.

Filed in Swedish · English published by the European Commission

Core messages from the Confederation of Swedish Enterprise Copyright is no longer solely a cultural policy issue. In a digital and knowledge-based economy, copyright is also a central issue for competitiveness, innovation, scaling, and the functioning of the Single Market. As an intellectual property right, copyright has a totally different position for business than most other rights.

The Confederation of Swedish Enterprise wants to contribute to the Call for Evidence regarding a Digital Fairness Act. Besides the attached document (Joint Nordic Comments DFA), we want to highlight two proposals to improve consumer protection in the European Union without adding additional new legislation with a Digital Fairness Act (DFA): 1.

Stockholm 13 May 2022 The Confederation of Swedish Enterprise position on the Data Act proposal The Confederation of Swedish Enterprise brings together 60,000 companies and 50 industry and employer organisations. We work on issues that are important to all companies, irrespective of sector and size.

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

The Confederation of Swedish Enterprise's input to the White paper includes comments on - the trends and challenges within the digital infrastructure sector, - the market discription in the White Paper and what it falls short in. Based on the White Paper, Swedish Enterprise also gives six proposals for action, summarized below; 1.

We agree to the conclusion that the Directive has significant EU added value and the Seville process is an important tool and should continue. For IED to interact with decarbonization and contribute to circular economy a review of the Seville process could be sufficient. Many BREFs are neither reviewed nor implemented yet, so we don’t know the Directives full performance.

The Confederation of Swedish Enterprise supports the Commission's work on sustainable products, in accordance with the Circular Economy Action Plan. The Swedish business community is already at the forefront of this work, and wishes to play a leading role in developing and contributing constructively to the European Commission's work on the topic.

The Confederation of Swedish Enterprise welcomes the Commission’s ambition to strengthen Europe’s competitiveness, innovation capacity and resilience in the semiconductor sector. Semiconductors are a fundamental enabling technology for large parts of European industry and a well-functioning semiconductor supply is important for both digitalisation and the green transition.

Filed in Swedish · English published by the European Commission

Summary Overall, the Confederation of Swedish Enterprise welcomes the European Commission's initiative to improve the investment conditions for certain green technologies within the European Union. The green transition is being challenged by high energy prices in Europe as well as ongoing lengthy and unpredictable permit processes.

The Confederation of Swedish Enterprise welcomes the European Commission’s Chemical strategy for sustainability and a revision of REACH that make the legislation and more effective. This combined with a strong and coordinated enforcement across the Union will protect consumers, environment and ensure a level playing field and competitiveness for business. Our input is further developed in the attached file.

Filed in Swedish · English published by the European Commission

The Confederation of Swedish Enterprise supports revising the Standardisation Regulation alongside the New Legislative Framework (NLF) to ensure a cohesive approach to placing safe, compliant products on the EU single market.

The Confederation of Swedish Enterprise welcomes the development of the Digital Product Passport (DPP) as a strategic tool to support a more circular, transparent, traceable and competitive Europe, aligned with the objectives of the Ecodesign for Sustainable Products Regulation (ESPR).

The European Commission has stated in the proposal regarding the 2040 climate target and its impact assessment that a technology neutral approach needs to be taken to power generation as all types of low carbon technologies will be needed to achieve a fully decarbonized power system by 2040 if 90 % emission reduction are to be achieved.

A key competitiveness issue is whether the EU prudential framework remains coherent and proportionate across Member States, or whether cumulative requirements create uneven effects that undermine investment capacity.

The problems tackled in the Omnibus packages are only the tip of the iceberg. This DFC is an essential next step. We urge the Commission to be ambitious. That does not mean lowering Europes regulatory standards.

European businesses continue to face fragmentation across 27 national administrative systems, resulting in duplicated procedures, repeated data submissions and high compliance costs. This particularly affects SMEs and companies operating cross border.

The Confederation of Swedish Enterprise is sceptical of export restrictions as a trade policy tool and emphasises that open markets and free trade are essential for Europes competitiveness, resilience and long-term industrial strength. The proposed restrictions on aluminium scrap represent a significant departure from established EU trade principles and risk undermining integrated global value chains.

The Confederation of Swedish Enterprise welcomes the opportunity to provide input to the revision of the governance framework established under the Regulation (EU) 2018/1999 on the Governance of the Energy Union and Climate Action.

The Confederation of Swedish Enterprise appreciates the Commission's proposals to simplify processes for companies and aligning product legislation with the digital age. We support digitalising the EU Declaration of Conformity, enabling digital instructions, and making electronic communication with authorities the norm.

The Confederation of Swedish Enterprise welcomes the opportunity to contribute to this consultation on the Market Integration Package under the Savings and Investments Union. We support the overall objective of strengthening Europes capital markets and improving the mobilisation and allocation of capital across the EU.

The Confederation of Swedish Enterprise welcomes the opportunity to contribute to this consultation on the Market Integration Package under the Savings and Investments Union. We support the overall objective of strengthening Europes capital markets and improving the mobilisation and allocation of capital across the EU.

The Confederation of Swedish Enterprise supports the Commissions goal to strengthen the capital markets within the EU under the frameworks of an effective Savings and Investments Union. We share the ambition to improve how capital is mobilised and allocated across the EU. In our view, this must go hand in hand with preserving the integrity of well-functioning national frameworks.

The Confederation of Swedish Enterprise welcome this opportunity to give feedback regarding the proposed amendment to Regulation (EU) No 575/2013 (the Capital Requirements Regulation or CRR) and the wider legislative package of which it is a part, known as Banking Package 2021. Please see the attached document for our views, which are very briefly summarised below.

Swedish Enterprise welcomes the Commission's initiative to develop ecodesign requirements for iron and steel intermediate products under the Ecodesign for Sustainable Products Regulation (ESPR). As the first delegated act covering an intermediate product, it will set an important precedent.

The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). The Confederation of Swedish Enterprise (Svenskt Näringsliv) is taking an active part in the field of intellectual property rights since knowledge-based assets are crucial in the knowledge economy.

The Confederation of Swedish Enterprise welcomes the Commissions review of the Rescue and restructuring guidelines for state aid. In summary, we would like to highlight the following recommendations: 1. We recommend that the steel sector continues to be excluded from the guidelines. 2.

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the Commission’s IP Action Plan Roadmap. It is an important initiative, as a strong IP framework is key to sustainable innovation. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs).

The Confederation of Swedish Enterprise welcomes the opportunity to provide feedback on the European Commissions consultation on the evaluation and potential review of the Shareholder Rights Directive (SRD). The Confederation of Swedish Enterprise represents approximately 60,000 member companies, organized in 48 business and employer associations across all sectors of the Swedish economy.

The Confederation of Swedish Enterprise welcomes these new Standard Contracual Clauses, SCCs, in particular since the old SCCs only addressed two data flow scenarios: an EU-based controller exporting data outside of the EU to other controllers, or to processors.

Build European capacity, keep markets open The Confederation of Swedish Enterprise supports CADAs ambition to strengthen Europes cloud and AI capacity. Success requires better investment conditions, faster permitting and access to competitive energy, not digital isolation. Assurance requirements must be risk-based and proportionate, avoiding unjustified restrictions based on provider origin or ownership.

Confederation of Swedish Enterprise submits the following initial feedback and intends to return with more detailed comments when more is known about the package. ESSPASS The Confederation of Swedish Enterprise is generally positive to modernizing and simplifying the rules for free movement within the EU.

A design proposal based on out-of-date assumptions The review of the EUs rules on industrial design was widely welcomed when it was first announced in the Intellectual Property Action Plan. However, now that the proposals have been presented, they seem to be based on old, out-of-date assumptions.

The Confederation of Swedish Enterprise (Svenskt Näringsliv) welcomes the Commission’s IP Action Plan Roadmap. It is an important initiative, as a strong IP framework is key to sustainable innovation. The Confederation of Swedish Enterprise is Sweden’s largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs).

We welcome the roadmaps emphasis on job creation, incentives to work, and labour market dynamism. But for the initiative to deliver real impact, it must also address Europes structural weaknesses in particular, low productivity, persistent skills shortages, and declining competitiveness. These factors are critical to reversing stagnation and enabling long-term, sustainable job creation.

Revision of Council Directive 98/24/EC and European Parliament and Council Directive 2004/37/EC concerning OEL and BLV for lead and its inorganic compounds and diisocyanates The EU Commission has put forward proposals for new limit values for lead and its inorganic compounds and for diisocyanates.

The Confederation of Swedish Enterprise are staunch advocates for greater work life equality, see reports in attached file. It is our firm conviction that achieving greater gender equality is essential for the realization of the full potential of all individuals and undertakings. Research shows that workplaces where both men and women work achieve better business results and build better workplace communities.

Please find attached the comments from the Confederation of Swedish Enterprise and the Swedish Confederation of Transport Enterprises. Aviation plays a crucial role for Swedish businesses by facilitating international trade and business travel. Airports serve as important hubs for companies' logistics and supply chains, contributing to regional economic growth.

The EU Commission has published a package of measures for improved asbestos protection and an asbestos-free future. Exposure to asbestos fibres can lead to serious illness and death, so it is of the utmost importance to minimise the risk of human exposure to asbestos fibres. The Confederation of Swedish Enterprise therefore welcomes the Commissions initiative that raises awareness of asbestos.

Confederation of Swedish Enterprise considers that the ability of workers to move freely within the Union is of great importance for the skills and competitiveness of companies. This is particularly important in view of the skills shortages in most sectors of the Swedish labour market. Confederation of Swedish Enterprise emphasizes that ELA can make further progress within its current mandate.

Regarding the European Chips Act, Swedish Enterprise would like to make the following general points: • Reforms to promote business and trade in semiconductors are fundamentally positive. Semiconductors are a key input for many Swedish companies, and many Swedish companies and universities are at the forefront of this area.

In our view, it might be necessary to develop an instrument like this one. However, we do see several risks associated with it. The instrument gives the Commission vast powers to use in a discretionary way with an almost unlimited arsenal of trade policy tools. Some of these tools are inappropriate and should not be used. It is very unclear to us what this new instrument will lead to, when and how it will be used.

We see an increasingly geopolitical trade policy being developed and this initiative is very much a part of that new philosophy/strategy. This is regrettable as the aim of trade policy should be to open up markets and establish market access. It should not be to introduce measures to close markets or even threat to close them.

2024-04-29 Proposal for a Regulation on the screening of foreign direct investments in the European Union The Confederation of Swedish Enterprise is the main business association in Sweden bringing together 60,000 companies and 48 industry and employer organisations.

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

We welcome the upcoming guidelines, as business are in need of further clarity on these and other key concepts within the FSR, in particular the concept of foreign financial contributions. Please read our thoughts on for instance distortions of competition and the balancing test in the attached document.

A design proposal based on out-of-date assumptions The review of the EUs rules on industrial design was widely welcomed when it was first announced in the Intellectual Property Action Plan. However, now that the proposals have been presented, they seem to be based on old, out-of-date assumptions.

The Confederation of Swedish Enterprise is Swedens largest and most influential business federation representing 60 000 member companies. Among the member companies many are Small and Medium-Sized Enterprises (SMEs). The Confederation of Swedish Enterprise (Svenskt Näringsliv) is taking an active part in the field of intellectual property rights since knowledge-based assets are crucial in the knowledge economy.

Introductory remarks The Confederation of Swedish Enterprise welcomes the envisaged review due to the fact that many problems arise from the current VAT framework regarding financial and insurance services. The current rules entail increased costs for start-ups and SMEs, different approaches from member states, an unlevel playing field and great complexity.

The Confederation of Swedish Enterprise strongly opposes the European Commission’s proposal to introduce more qualified majority voting in the area of social policy. • The Commission wrongly asserts that this is a response to citizens’ expectations, and not identified problems, while that which has been expressed are their concerns.

SVENSKT NÄRINGSLIV SWEDISH ENTERPRISE Stockholm, 27 May. 24 Comments from the Confederation of Swedish Enterprise on the European Commission’s proposal for a Directive on improving and enforcing working conditions for trainees and combating regular employment relationships disguised as traineeship, and proposal for a Council Recommendation on a reinforced Quality Framework for Traineeships.

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