Confederation of Swedish Enterprise

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.

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.

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)

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 (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.

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'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.

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.

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 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.

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 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 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.

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.

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.

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.

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.

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.

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)

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