Danish Chamber of Commerce

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)8443957 - 04/09/2026 Danish Chamber of Commerce response to the draft Implementing Regulation on registration and reporting under Article 44 in the PPWR General remarks The Danish Chamber of Commerce welcomes the Commission's objective of establishing harmonised formats for registration and reporting under…

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

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)2752595 - 13/03/2026 13. march 2026 Consultation feedback on the Digital Omnibus on Data & Cyber and the Digital Omnibus on AI General remarks The Danish Chamber of Commerce welcomes the European Commission’s initiative to simplify the EU’s digital regulatory framework through the Digital Omnibus proposals…

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

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)2752653 - 13/03/2026 13. march 2026 Consultation feedback on the Digital Omnibus on Data & Cyber and the Digital Omnibus on AI General remarks The Danish Chamber of Commerce welcomes the European Commission’s initiative to simplify the EU’s digital regulatory framework through the Digital Omnibus proposals…

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

The Danish Chamber of Commerce/Dansk Erhverv support the European Commissions ambitions on the simplification agenda and welcomes the initiative on the Digital Omnibus, as outlined in the Call for Evidence published on September 16, 2025 (Ref. Ares(2025)7724296).

The Danish Chamber of Commerce (DCC) welcomes the initiative to establish a Circular Economy Act as a key step toward a more competitive, sustainable, and resilient European economy. To ensure that the circular transition truly takes off, Europe needs a harmonised and predictable regulatory framework that removes barriers to circular business models, creates a well-functioning market for secondary raw materials, and…

The Danish Chamber of Commerce considers that the revision of the EU public procurement directives should focus on strengthening competition, reducing administrative burdens and increasing predictability in public procurement.

Filed in Danish · English published by the European Commission

The Industrial Accelerator Act (IAA) has the potential to strengthen European green industry and create opportunities for Danish companies to supply green technologies while reducing unfair competition from third countries. Danish Chamber of Commerce supports this objective, particularly in light of geopolitical risks and Europes dependencies on external suppliers.

THE DANISH CHAMBER OF COMMERCE Børsen 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2021)5892791 - 28/09/2021 The European Commission DG ENER Unit C1 24 September 2021 The Danish Chamber of Commerce’s consultation response regarding the Renevable Energy Directive (RED) The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU…

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

For Dansk Erhverv, uniform and well-functioning regulation is essential to ensure efficient and value-adding public procurement. The purpose of regulation is to strengthen competition, increase transparency and promote innovation, not to create unnecessary complexity and administrative burdens for businesses and contracting entities.

Filed in Danish · English published by the European Commission

Dansk Erhverv (The Danish Chamber of Commerce) welcomes the opportunity to provide feedback to the European Commissions proposal for a revision of the Medical Devices Regulation (MDR) and the In Vitro Diagnostic Medical Devices Regulation (IVDR). We look forward to a continued and constructive engagement with the Commission as the legislative process progresses.

The MDR and IVDR originally aimed at ensuring higher patient safety and more uniform regulation across the EU. This was and is an important goal. Unfortunately, we now have a regulatory system which has not only been difficult to implement, but which is also incredibly fragmented and burdensome. Many companies struggle with a slow and unpredictable certification process.

The Danish Chamber of Commerce (Dansk Erhverv) welcomes the voluntary EU Inc. initiative, which aims to make it easier for companies, and particularly SMEs and entrepreneurs, to operate and scale across borders. A well-designed and ambitious regime could represent a genuine break-through for the Single Market and strengthen Europes competitiveness.

The Danish Chamber of Commerce welcomes the initiative and supports the ambition to create a fair and sustainable interaction between AI and the cultural and creative sectors. AI holds great potential for cultural and creative industries and can contribute to innovation, new business models and access to new markets and customer groups.

Filed in Danish · English published by the European Commission

We welcome the opportunity to provide feedback on the Commissions draft amendments to the EU Taxonomy Climate Delegated Act and Environmental Delegated Act. We appreciate the Com missions effort to simplify, clarify and improve the usability of the technical screening criteria. We continue to acknowledge that the EU Taxonomy can play a valuable role as a common refer ence framework for sustainable investments.

We welcome the opportunity to provide feedback on the EU Taxonomy Climate Delegated Act and Environmental Delegated Act, and we appreciate the Commissions intention to simplify, clarify and improve the technical screening criteria. We acknowledge that the EU Taxonomy can play a valuable role as a common reference framework for sustainable investments.

We welcome the opportunity to provide feedback on the EU Taxonomy Climate Delegated Act and Environmental Delegated Act, and we appreciate the Commissions intention to simplify, clarify and improve the technical screening criteria. We acknowledge that the EU Taxonomy can play a valuable role as a common reference framework for sustainable investments.

The Danish Chamber of Commerce represents food retailers og wholesalers in Denmark. We welcome the Commissions proposal to revise and clarify key provisions of Regulation (EU) 2018/848, especially the withdrawal of the previously announced positive list of permitted disinfectants and de-tergent, as well as the postponement of the expiry of equivalence arrangements with third countries until 2036.

The Danish Chamber of Commerce welcomes the opportunity provide suggestions for updating the Organic Regulation (EU) 2018/848. We support the EUs ambition for the organic sector in Europe and have suggestions that can help the further growths of the sector and help reduce the regulatory burden for businesses.

The Danish Chamber of Commerce welcomes the revision of the Energy Performance of Building Directive (EPBD) as energy efficiency can result in reduced greenhouse gas (GHG) emissions. The Danish Chamber of Commerce strongly supports the Paris Agreement targets and the EU climate goal of 55 % GHG reduction by 2030, as referred to in the proposal for a directive – COM (2021)802 (hereafter “EPBD”), recital 2 in the…

The revision of the EPBD is part of the “Fit for 55 package” included in the Commission Work Programme 2021. This revision will focus on provisions that are central to delivering a Renovation Wave and that contribute to emission reduction. The Danish Chamber of Commerce fully supports the EU Green Deal, Climate Target Plan 2030, and Fit for 55 package and their complementary policies.

Call for Feedback - EU’s next long-term budget (MFF) – EU funding for competitiveness Dansk Erhverv (The Danish Chamber of Commerce) welcomes the European Commission’s proposal to establish the European Competitiveness Fund (ECF) as part of the next Multiannual Financial Framework.

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

The Danish Chamber of Commerce welcomes the opportunity to comment on the Commissions draft revised European Sustainability Reporting Standards (ESRS). We strongly support the overall objective of simplifying sustainability reporting under the CSRD while safeguarding the purpose of providing relevant, reliable and decision-useful sustainability information.

The Danish Chamber of Commerce supports the climate ambition as set out in the European Green Deal as well as the proposed European Climate Law. Ambitious goals are important in order to set the direction and hence the Danish Chamber of Commerce supports increasing the EU’s 2030 GHG target to at least 55%.

The proposal uses a vague definition of artificial intelligence (AI) and it should be clearer how AI is used in different respects. In addition, the proposal relies to a great extent on the use of delegat-ed acts, which increases the uncertainty for the companies affected by the legislation, e.g. the def-inition of what AI is can be changed.

DANSK ERHVERV Ref. Ares(2023)7958649 - 22/11/2023 November 22, 2023 Consultation on the revision of the Waste Framework Directive The Danish Chamber of Commerce has received a consultation on the revision of the Waste Framework Directive focusing on food waste and extended producer responsibility on textiles and has the following comments.

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

The Danish Chamber of Commerce welcomes the initiative to review the EU waste framework Directive. The revision is an opportunity to support regulation that contribute to the transition towards a circular economy. This includes but is not limited to regulation that supports circular business models, harmonization of implementation in Member States and creating a marked for secondary raw materials.

The Danish Chamber of Commerce welcomes the opportunity to provide input to the Commissions roadmap on Sustainable corporate governance. Please find the full response on behalf of the Danish Chamber of Commerce attached.

The Danish Chamber of Commerce’s consultation response regarding a Carbon Border Adjustment Mechanism (CBAM). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Carbon Border Adjustment Mechanism (CBAM).

The Danish Chamber of Commerce strongly support the European Commissions ambition to revitalise the EUs biotechnology and life sciences ecosystem through a comprehensive and forward-looking Biotech Act. An ambitious and innovative policy approach is essential to leverage the full potential of biotechnology in addressing societal, environmental, and economic challenges, while reinforcing Europes strategic autonomy.

The Danish Chamber of Commerce’s consultation response regarding the revision and update of the Energy Efficiency Directive (EED). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision and update of the Energy Efficiency Directive (EED).

The Danish Chamber of Commerce’s consultation response regarding the revision of the EU Emissions Trading System (ETS). The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the revision of the EU emissions trading system (ETS).

THE DANISH CHAMBER OF COMMERCE Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2026)4808384 - 12/05/2026 Directorate-General for Communications Networks, Content and Technology (DG Connect) Rue de la Loi 200 1049 Brussels, Belgium 12th of May 2026 The Danish Chamber of Commerce: Feedback to the European Commission’s Cybersecurity Package: Revision of the Cybersecurity Act…

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

DANSK ERHVERV Børsgade 4 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2025)8987455 - 21/10/2025 Orientering Den 21. oktober 2025 Dansk Erhvervs høringssvar vedrørende Kommissionens høring om den kommende Digital Fairness Act Dansk Erhverv takker for muligheden for at afgive høringssvar i forbindelse med Europa-Kommissionens åbne høring om den kommende Digital Fairness Act (DFA).

Filed in Danish · English published by the European Commission

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

We welcome the opportunity to provide feedback on the Commissions draft amendments to the EU Taxonomy Climate Delegated Act and Environmental Delegated Act. We appreciate the Com missions effort to simplify, clarify and improve the usability of the technical screening criteria. We continue to acknowledge that the EU Taxonomy can play a valuable role as a common refer ence framework for sustainable investments.

DANSK ERHVERV Børsen 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2021)4161505 - 25/06/2021 European Commission June 25th 2021 Comments from the Danish Chamber of Commerce on the Commission’s roadmap/IIA on the Data Act The Danish Chamber of Commerce is pleased to provide feedback on the European Commission’s IIA for the Data Act.

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

The Danish Chamber of Commerce appreciates the Commission's publication of the White Paper, How to master Europe's digital infrastructure needs? and the opportunity to contribute to the consultation. Please find attached our contribution. Regards from the Danish Chamber of Commerce.

The Danish Chamber of Commerce is the second largest business organisation in Denmark and represents more than 15.000 members in different sectors including retail, wholesale and tele companies. We have the following input and suggestions: We share the European Commission’s concern about the online sale of counterfeit, dangerous or illegal products putting citizens at risk and harming law-abiding legitimate…

In general, Dansk Erhverv works for an efficient healthcare system in which citizens have a high level of trust and receive the highest quality of care, whether public or private. In this context, Dansk Er is a representative of the Danish health and life science industry in a broad sense, including pharmaceutical companies, media and diagnostic companies, biotech, health IT companies and other life science…

Filed in Danish · English published by the European Commission

Danske Erhverv would like to thank the European Commission for the possibility of submitting a consultation response to the Commission’s draft delegated act amending Annex I to the Regulation on combating global deforestation and forest degradation. Dansk Erhverv supports the political ambition to combat global deforestation.

Filed in Danish · English published by the European Commission

The Danish Road Directorate: Analysis of testing scheme for double trailers (December 2021): Link - https://www.trm.dk/media/zeqbjmqz/rapport-analyse-af-en-mulig-forsoegsordning-med-dobbelttrailere_final-a.pdf Danish Road Traffic Authority: COWI analysis: Analysis OF OPTION AND TILPASNING OF NATIONAL wall AND DIMENSIONSREGULATION (December 2021): link -…

Filed in Danish · English published by the European Commission

Danish Chamber of Commerce on Affordable Housing Act Call for evidence Copenhagen, the 30th of May 2026 The Danish Chamber of Commerce welcomes the European Commissions initiative to address housing affordability challenges across the Union. We recognise the urgency of the issue in numerous urban and high demand areas.

Dansk Erhverv welcomes the Commission’s initiative to revise the Standardisation Regulation. Better access to standards, transparency and faster availability of standards for the benefit of businesses are essential. Similarly, it is key that harmonised standards are developed in close cooperation with SMEs, NGOs and research communities to ensure access to standards.

Filed in Danish · English published by the European Commission

Danish Chamber of Commerce (DCC) welcomes the establishment of the digital product passport (DPP) registry under Regulation (EU) 2024/1781 and as such support the establishment of a functional and secure registry that can facilitate compliance, improve market surveillance, and support a more level playing field across the Single Market.

DANSK ERHVERV Børsen 1217 København K www.danskerhverv.dk [email removed] T. [phone removed] Ref. Ares(2025)6377550 - 05/08/2025 European Commission 1049 Bruxelles Belgium 5th of August 2025 Consultation Response to the European Grids Package Dansk Erhverv (Danish Chamber of Commerce) appreciates the opportunity to contribute to the European Commission’s call for evidence on the European Grids Package initiative.

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

The Danish Chamber of Commerce welcomes the opportunity to provide feedback to the roadmap on revision of EU marketing standards for agricultural products. We especially endorse the stated objective of the proposal to simplify current legislation and align with evolving technology and production methods.

Dansk Erhverv (Danish Chamber of Commerce) appreciates the opportunity to contribute to the European Commissions call for evidence on the Electrification Action Plan. General remarks Dansk Erhverv supports the Commissions work on the forthcoming Electrification Action Plan.

The Danish Chmaber of commerce have the following input and suggestions: To remain competitive, retailers and wholesalers need a regulatory framework that supports strong European retail and wholesale ecosystems in a digital environment and gives them legal certainty and incentives to invest in robust omnichannel strategies.

Provided on behalf of The Danish Chamber of Commerce and Mrs. Lisbet Hagelund: The Danish Chamber of Commerce supports the Commissions considerations, points and objectives in the Inception Impact Assessment regarding the revision of the Waste Shipment Directive. We believe it is necessary that the EU revises the WRS regulation in order to ensure a rapid shift towards a circular economy.

The European Commission launched the European Quantum Strategy in July 2025, paving the way for a future EU Quantum Act. This initiative was both urgent and necessary. Quantum technology has become a domain of strategic, economic, and military significance. Its transformative po-tential is immense but so are the risks it poses to critical infrastructure, financial systems, and defense applications.

The Danish Chamber of Commerce is positive about a green progressive line from the EU Commission. We support the higher ambitions of the LULUCF Regulation. As a starting point, common EU rules are unequivocally good for Danish companies, as they provide more equal conditions of competition in the EU's internal market.

The Danish Chamber of Commerce welcomes the opportunity offered by the European Commission to provide comments on the Commission proposal for a regulation on combating late payment in commercial transactions (the Proposal) published on 12 September 2023. Please find the Danish Chamber of Commerce position paper on the revision of Late Payment Directive in attached files.

General remarks. Please see attachment for further evidence. The Danish Chamber of Commerce strongly believe that all companies, regardless of size, should respect the contractual terms they have agreed to with their contractual partners, including ensuring payment in accordance with agreed payment terms.

Dansk Erhverv welcomes the Commissions focus on ensuring that the EU energy system is suffi-ciently secure and resilient in the face of increasingly complex and emerging challenges. In todays geopolitical landscape, this focus is essential. The green transition is no longer solely a climate imperative; it is a strategic necessity.

The Danish Chamber of Commerce thanks the European Commission for the opportunity to provide comments on the draft delegated regulations concerning the classification of green-listed waste under Regulation (EU) 2024/1157 on shipments of waste. See consultation response attached

The Danish Chamber of Commerce thanks for the opportunity to provide input to the European Commission’s evaluation of the AVMSD and stresses the need for a modern, well-functioning and future-proof regulatory framework for the European media market. The Directive continues to play a key role, but technological developments and changing user behaviour make targeted adjustments necessary.

Filed in Danish · English published by the European Commission

The Danish Chamber of Commerce welcome the opportunity to provide comments on the Commissions proposal for a regulation amending Regulations (EU) No 1308/2013, (EU) 2021/2115 and (EU) 2021/2116 as regards the strengthening of the position of farmers in the food supply chain (the Proposal), published on the Have your say platform on 13 January 2025.

Danish Chamber of Commerce welcomes the revision of the general product safety directive, including in particular the fact that the proposal aims to create compliance with the principles and definitions contained in the harmonised part of the product safety legislation and the market sur-veillance regulation.

European Commission DG JUST.E4 Product Safety and Rapid Alert System Upload via better regulation website 1 September 2020 Contribution to the European Commission’s Combined Roadmap and Inception Impact Assessment on the revision of Directive 2001/95/EC of the European Parliament and of the Council (the General Product Safety Directive) The Danish Chamber of Commerce welcomes the opportunity to provide input on the…

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

The Danish Chamber of Commerce thanks the Commission for the opportunity to provide contribution to the consultation on the revision of the Market Surveillance Regulation. It is clear that the current NLF, GPSR and MSR systems do not prevent non-compliant products from being placed on the internal market in situations where consumers in the EU shop online from sellers in third countries by using e-commerce platforms…

We thank the Commission for the opportunity to reply to this important Inception Impact Assessment. The regulation on product safety and product liability is one of the key stones in protecting the European Consumers and creating and uphold a level playing field for operators in EU.

The Danish Chamber of Commerce supports the vision of the European Green deal and the Sustainable and Smart Mobility Strategy. Climate and environmental challenges are a major challenge for this generation, and clear pan-European solutions, instruments and regulation are needed if the EU is to achieve targets of at least 55 % greenhouse gas emission reductions by 2030 and climate neutrality by 2050.

Filed in Danish · English published by the European Commission

Dansk Erhverv is very positive about the Commission’s initiative to introduce a single set of rules for EU companies to calculate their tax base. Dansk Erhverv was a strong supporter of the Commission’s previous proposal on the CCCTB and is convinced that a common consolidated corporate tax base will be the most important tax proposal to ensure an efficient internal market.

Filed in Danish · English published by the European Commission

The Danish chamber of commerce welcomes the opportunity to provide input to support the development of ecodesign requirements for iron and steel products to be adopted as a delegated regulation under the Ecodesign for Sustainable Products Regulation (ESPR). Please see our response attached.

The Danish Chamber of Commerce (Dansk Erhverv) (DE) welcomes the opportunity to provide input on the simplification of EU legislation on energy labelling. The DE supports the EU energy label as a well-known and effective tool that helps consumers make informed and energy-efficient purchasing decisions.

Dansk Erhverv welcomes the Commission’s initiative on special rules on driving and rest periods for bus and coach drivers in the case of occasional services. At present, the same rules apply to drivers of the carriage of goods and bus and coach passengers. The two sectors differ significantly in a number of respects, which is reflected in the driver’s driving needs and pattern.

Filed in Danish · English published by the European Commission

Initially we would like to thank the Commission for taking the initiative to revise the existing SCCs. New standard contracts have long been needed and it is of enormous importance that the Com-mission focuses on creating tools that in practice enable data transfer to the US until we hopefully very soon will have a new EU-US agreement to replace the Privacy Shield agreement.

The Danish Chamber of Commerce supports the efforts to avoid distortions in the single market as a result of foreign subsidies. There is a real need to adress these issues. EU member states are subject to very strict regulation, that only as an exception allows state aid for European businesses.

In theory, Dansk Erhverv takes the view that it is positive that debt and equity are treated in the same way for tax purposes. Ideally, this balance can be achieved in many ways, it would certainly be to reduce corporate tax or to abolish it altogether, as corporation tax is the most productivity-inhibiting tax.

Filed in Danish · English published by the European Commission

Dansk Erhverv supports the AML Regulation to help ensure a more uniform legal position across Member States, in line with developments in money laundering and terrorist financing. Dansk Erhverv hopes that the Regulation will contribute to the increased protection of EU citizens, and in particular the EU’s financial system, by setting higher standards reflecting the best practices used by EU financial institutions.

Filed in Danish · English published by the European Commission

The Danish Chamber of Commerce welcomes the opportunity to provide comments on the Commissions call for evidence (Call for Evidence) for an evaluation/fitness check on the Agricultural & food supply chain combating unfair trading practices, published on 18 October 2023.

The Danish Chamber of Commerce supports the Commission’s ambition of shielding individual Member States and their businesses from arbitrary coercive measures from third countries. However, the Danish Chamber of Commerce stresses that it must not be used as a protectionist measure and that it is essential that the EU remains open to international trade and investments.

Dansk Erhverv was in favour of the establishment of a single EU supervisory authority to help ensure effective supervision and uniform processing across Member States. Dansk Erhverv hopes that this can help to strengthen the protection of the EU’s financial system and of EU citizens by setting higher standards reflecting the best practices used by EU financial institutions.

Filed in Danish · English published by the European Commission

The Danish Chamber of Commerce (Dansk Erhverv) supports the initiative to review the Merger Guidelines as mandated in the Mission Letter to Executive Vice-President Ribera and outlined in the Commissions Competitiveness Compass and Clean Industrial Deal.

The Danish Chamber of Commerce welcome the opportunity to provide comments on the Commissions proposal for a regulation (the Proposal) on cooperation among enforcement authorities responsible for the enforcement of Directive (EU) 2019/633 on unfair trading practices in businessto- business relationships in the agricultural and food supply chain (the UTP-Directive), published on the Have your say platform on 13…

The Danish Chamber of Commerce supports the objective of the directive: strengthening the coordination between national financial intelligence units. The Danish Chamber of Commerce supports a deeper harmonization of anti-money laundering standards across the Union as well as greater coherence of the supervision undertaken by the national financial intelligence units.

Brugen af E-faktura når der handles med offentlige myndigheder har været obligatorisk i Danmark siden 2005. For at sikre mest mulig interoperabilitet er det vigtigt, at man fra EU-systemets side ikke påtvinge én bestemt teknisk transmissionsmetode i forhold til brugen af E-faktura.

The Danish Chamber of Commerce’s consultation response regarding the Communication on the Fit for 55-package from The European Commission. The Danish Chamber of Commerce thanks the EU Commission for the opportunity to respond to the Communication on EU Emission Trading System.