Danish Industry

DI generally welcomes the Commissions digital omnibus but stresses the need for further simplification and harmonization to strengthen Europes competitiveness and innovation. DI supports postponing requirements for high-risk AI systems until relevant standards are in place and welcomes simplified requirements for SMEs. DI prefers promoting AI skills through guidance and education rather than general obligations.

Europe has long been at the forefront of regulation and requirements in the digital sector with the aim of creating a safe and secure environment for the use of digital technologies, as well as strengthening digital security against growing threats. While the intention is both right and necessary, the volume and complexity of the legislation has increasingly led to uncertainty and burdens for European businesses.

The Confederation of Danish Industry (DI) welcomes the opportunity to comment on the European Commissions proposal for an Industrial Accelerator Act (IAA), published on 4 March 2026. The IAA comes at a time of profound geopolitical and economic change.

Accelerating Approval Processes : Expediting approval processes for decarbonisation projects is crucial for the energy-intensive sector's green transition and competitiveness. Currently, approvals in Denmark take on average 8.5-9 months through the Environmental Protection Agency, plus an additional year for environmental assessments, totaling nearly two years for project initiation.

DI comment to Roadmap: EU renewable energy rules – review The Confederation of Danish Industry (DI) appreciates this opportunity to comment on this inception impact assessment related to the revision of the Renewable Energy Directive (REDII). DI supports the overall objective, i.e. to ensure that renewable energy sources contribute to the achievement of EU’s climate ambition.

DI is pleased to provide feedback on the Commissions evaluation and the future of EU public procurement to support and promote European competitiveness. Public procurement matters both for contracting authorities and companies who benefit from the single market when bidding for public contracts on their own as well as in other EU and EEA Member States.

1-7-2025 Danish Industry - DI Digital Transparency Register No: 749958415-41 Contribution from the Confederation of Danish Industry (DI) on Digital Networks Act - call for evidence The Confederation of Danish Industry (DI) welcomes the opportunity to contribute to the European Commission’s forthcoming proposal for a “Digital Networks Act” (DNA).

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

The Confederation of Danish Industry welcomes and support the efforts to improve the clarity, usability, legal certainty and cost-effectiveness of the EU Taxonomy, in particular the EU taxonomy climate ((EU) 2021/2139) & environmental ((EU) 2023/2486) delegated acts. Attached, please find our comments.

Revision of the Energy Performance of Buildings Directive 2010/31/EU DI welcomes the opportunity to comment on the European Commission’s Inception Impact Assessment on the Revision of the Energy Performance of Buildings Directive (EPBD).

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

Danish Industri welcomes the opportunity to comment on the Revised European sustainability reporting standards (ESRS revised). We fully support the efforts with Omnibus I to ensure the competitiveness of Europe and reducing the administrative burdens of sustainability reporting while safeguarding the green deal policy goals.

Confederation of Danish Industry (DI) on call for evidence on EU Waste Framework DI strongly supports the measures in the Waste Framework Directive and the political commitments in the European Green Deal and the Circular Economy Action Plan the crux of which we consider ensuring high quality recycling.

DI welcomes the objective of strengthening corporate sustainability due diligence and create a level playing field but sees several areas where the proposal needs adjustments to make it workable and proportionate. The role of states and companies should not be mixed up as companies do not have the mandate nor the ability to solve all problems arising from weakly governed states globally.

DI believes that it is crucial for the green transition and consumers' role in it: 1. That companies can commercially communicate about all the measures they take to improve their green footprint and sustainability. 2.

Confederation of Danish Industry supports the proposed Ecodesign for Sustainable Products Regulation (ESPR). Overall, we find that the proposal if implemented according to the good intentions will strengthen the Single Market, push for more circular products in the EU and create more transparency in the value chain.

DI Biosolutions welcomes the European Commissions proposal COM(2025) 1031 as an important step towards a more proportionate, risk-based and innovation-friendly regulatory framework for genetically modified micro-organisms (GMMs) in the European Union. GMMs play a critical role across a wide range of sectors, including food and agriculture, industrial biotech and environmental applications.

DI Food welcomes the proposal for a European Biotech Act. Although the primary focus is on the health sector, the regulation is highly relevant for the food and feed area. A central element of the proposal is the introduction of regulatory sandboxes under the General Food Law.

DI response to the Call for Evidence on a European Biotech Act DI appreciates the opportunity to comment on the Call for Evidence for a future Biotech Act. We strongly support the development of a Biotech Act, the description of the rationale behind and the positive impact it will have for the sector and European competitiveness as described in the Call for Evidence.

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

DI fully supports the EU ETS as a common, market-based European climate regulatory tool. Later this Summer, the EU-Commissions proposal to a post-2030 ETS1 revision will be followed by intensive - sometimes emotional - debates. Already, in recent months, the EU ETS has received significant attention in European media.

Thank you for this opportunity to briefly comment on this combined evaluation roadmap/inception impact assessment. DI would like to emphasize the key role of energy efficiency in building a carbon neutral EU economy. The current state of affairs indicates, that implementation must be improved in many Member States.

DI appreciates this opportunity to comment on the framing and scoping of the coming EU ETS revision. The EU ETS has been developed over 1,5 decades, and is the key instrument for decarbonisation in Europe and also nationally. The current target design builds on an objective to form a coherent, cost-effective and balanced marked-based regulation.

Confederation of Danish Industry (DI) The Confederation of Danish Industry (DI) welcomes the European Commissions efforts to strengthen Europes cybersecurity and resilience framework in an increasingly complex geopolitical and technological environment.

Danish Industry August 26th 2025 CBAM – downstream expansion On behalf of Danish Industry, we thank you for the opportunity to provide input to the consultation regarding conditions and procedures related to the status of CBAM scope expansion.

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

DI greets the intentions behind the proposal for securing uniformity, transparency, and compliance with other EU-legislation. Manufacturers and suppliers already deliver many different kinds of information about chemicals to customers and authorities.

DI welcomes the possibility to submit our feedback on the CLP revision Inception Impact Assessment consultation. In general, DI - supports the goals in the Chemicals Strategy for Sustainability and to build on the chemicals safety legislation to ensure safe and sustainable use of chemicals - recognizes the need to find a way to address new hazards as endocrine disrupting effects - strongly support the harmonization…

Dansk Industri (DI) welcomes the opportunity to contribute to the European Commissions Call for Evidence for the impact assessment on Biotech Act II. DI's proposed structure for Biotech Act II is based on four regulatory design principles: (1) common information should be organised for reuse across procedures; (2) regulatory orientation should be provided before major data-generation investments are made; (3)…

The Confederation of Danish Industry (DI) welcomes the opportunity to provide comments to public consultation on the draft ATP to the CLP, as part of its Better Regulation approach. DI representsmore than 10,000 private enterprises within manufacturing, trade and services covering most sub-sectors.

Danish Industry (DI) welcomes the Commissions ongoing review of the Copyright in the Digital Single Market (DSM) Directive, as well as the associated call for evidence and public consultation regarding text and data mining (TDM). Setting the right framework for copyright and data access is fundamental to innovation, growth and competitiveness in Denmark and in the EU as a whole.

Danish Industry (DI) thanks the Commission for the opportunity to provide our feedback to the renewable Energy Framework for the decade ahead. Please read our full contribution in the file attached. DI is fully committed to reaching climate neutrality by 2050 and to deliver on the agreed 90 % emission reduction target by 2040.

DI Danish Energy Industries welcomes the review of the EU Taxononmys Climate and Environmental Delegated Acts. We fully support the EU Taxonomy and its purpose of directing investments towards sustainable projects and activities.

The Confederation of Danish Industry (DI) welcomes the opportunity to comment on the Commissions Call for Evidence concerning the implementation of Regulation (EU) 2026/1388 on plants obtained by certain new genomic techniques (NGTs). The forthcoming delegated and implementing acts should ensure that the Regulation can be applied uniformly, effectively and in a timely manner across the EU from 17 July 2028.

European Innovation Act response on the call for evidence DI, the largest Business Confederation in Denmark, welcomes the opportunity to reply on the call for evidence for a coming European Innovation Act. Overall assessment and remarks The Confederation of Danish Industry (DI) acknowledge the EU Commissions ambition to pro-mote innovation and strengthen European businesses (see DIs specific remarks in Annex 1…

Contribution from the Confederation of Danish Industry (DI) to the consultation of the Commission's white paper How to master Europe's digital infrastructure needs? The Confederation of Danish Industry (DI) are thankful for the opportunity to submit comments to the European Commission's consultation on the white paper "How to master Europe's digital infrastructure needs?".

Danish Industry (DI) represents more than 21.000 companies across a wide range of industries. DI supports the SUPDs aim to reduce plastic pollution and marine litter and to foster a circular economy but calls for an evaluation to improve coherence and implementation rather than expanding the directives scope.

22 June 2020 Ref. Ares(2020)3345933 - 26/06/2020 LARA, CESM og MQF DI-2020-10340 The Commission Response to the Commission on roadmaps for the Commission’s Digital Services Act 1. General remarks The Confederation of Danish Industry (DI) has been asked for our opinion regarding the roadmaps for the Commission’s Digital Services Act. DI acknowledges this and submits the following remarks.

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

Contribution to the EU-Commission's consultation of the Inception Impact Assessment of the Industrial Emmission Directive From Confederation of Danish Industry, we find that the directive works well i the context it was agreed upon by the European Parliament and the Council. Since 2010 the discussion on environmental regulation in Europe has changed it focus.

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

CONFEDERAtION OF DANISH INDUSTRY (DI) FEEDBACK ON ROADMAP TO REVISE EU RULES ON FOOD CONTACT MATERIALS The Confederation of Danish Industry (DI) appreciates this opportunity to provide feedback and support the revision of rules on FCM.

DI welcomes the Commissions Environmental Simplification Omnibus as an important first step towards a more coherent and manageable EU environmental framework. DI supports the ambition from Member States and the Commission to strengthen competitiveness and resilience through high environmental standards, while emphasising that regulation must be implementable and proportionate.

DI generally supports a more consistent and comparable sustainability reporting on a global level. We therefore believe that the review of the former Non-Financial Reporting Directive as proposed with the CSRD is very timely. It should be recognised that with the NFRD, the EU went to the forefront of sustainability reporting.

Copenhagen, September 2025 DI Consultation Response: Nature Credits Roadmap to reward nature-positive action and boost private finance Introduction: Danish Industry (DI) welcomes the opportunity to provide feedback on the European Commission's Roadmap towards Nature Credits. DI represents more than 20.000 Danish companies across industries with high ambitions to achieve a green transition.

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

DI welcomes the possibility to submit our feedback. In general, DI - advices the Commission to strive for a coherent regulation of chemical risks across regulations and to avoid overlapping regulation for chemicals - acknowledges that REACH is the data generating regulation and supports the wish from the Commission to let data on e.g.

DI agrees there is a need to strengthen the cyber security of products in Europe and we support the proposed CRA regulation. We support a horizontal approach to cybersecurity and appreciate that the proposal aims at applying the NLF principles which will ease compliance for our member companies. Never-the-less, adaptations will be needed to clarify the obligations and make them more proportionate.

DI supports the ambition to strengthen cyberresilience in Europe. We are in favor of policy option 4 with the modification that we do not believe ancillary services should be included. From Option 5 we would support the inclusion of embedded software and also non-embedded (standalone software) with an intended use to be integrated into specific products, preferably only for critical software.

The Confederation of Danish Industry (DI) welcomes the opportunity to submit input in response to the Commissions Call for Evidence on the Affordable Housing Act. Please find DIs feedback set out in the attached document. DI remains at your disposal and is ready to provide any further information or clarification, should this be required.

DI’s response to the Call for Evidence for an Impact Assessment on the Revision of the Standardisation Regulation (EU) 1025/2012 DI appreciates the opportunity to comment on the European Commission’s plans related to the impact assessment (IA) regarding the revision of the standardisation regulation (SR).

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

Danish Industry (DI) welcomes the Commissions initiative to establish a comprehensive framework for climate resilience and risk management. Targeted climate adaptation is essential to protect and build resilience to the growing climate challenges in the coming years. Climate change will increasingly change weather in Europe, which will increase storms, heavy rain, droughts, floods, and increase in sea level.

Danish Industry (DI) represents more than 20.000 Danish companies across a range of industries. DI supports the ambition to establish a robust and interoperable system that can strengthen circularity, transparency and market surveillance in the EU. At the same time, DI highlights a number of key concerns that should be addressed to ensure effective implementation and industry uptake.

Danish Industry (DI) would like to thank the EU Commission for the opportunity to comment on this proposal. DI represents 20.000 Danish companies across many different industries and sectors. >A level playing field and continued investment in technology DI welcomes harmonized rules to calculate, verify and report the share of recycled plastic in sin-gle-use plastic bottles.

5 August 2025 Ref. Ares(2025)6378192 - 05/08/2025 AKZS DI-2025-05881 Transparency register number: 5749958415-41 Danish Industry – Feedback on the call for evidence consultation on the European Grids Package Danish Industry welcomes the EU Commission’s initiative to set forward a European Grids Package. Sufficient grid capacity is a prerequisite for the clean energy transition of the EU.

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

Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and brand owners. DI welcomes the opportunity to provide input on sustainability criteria for plastic recycling technologies. Sustainability criteria should be based on objective environmental performance and remain technology-neutral.

Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and brand owners. DI welcomes the opportunity to provide input to the development of harmonised EU rules for calculating and verifying recycled content in plastic packaging.

AKZS DI-2025-06720 European Commission DG ENER, Unit C1: Renewables and Energy System Integration Policy Call for Evidence for the EU Electrification Action Plan Danish Industry are highly supportive of scaling up electrification with the Electrification Action Plan.

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

Confederation of Danish Industry (DI) and Waste and Resource Industry, Denmark, support a revision of the Waste Transport Regulation. We find it crucial for the circular economy in the EU: • For manufacturing companies: The legislation should support take-back solutions and sourcing of secondary raw materials across national borders.

Danish Industry welcomes the Commissions work on a Heating and Cooling Strategy ac-companied by a Geothermal Action Plan, which should accelerate the decarbonization of the heating and cooling sector and increase energy efficiency. The following issues should be addressed in the upcoming strategy: 1. Reducing the demand side of energy, energy efficiency and flexibility.

Confederation of Danish Industry (DI) fully supports the Commission’s initiative to revise the UWWTD and its road map for an impact assessment. The UWWTD should contribute to a clean and more circular/resource efficient and climate adapted economy in EU. DI supports that the overall context of the UWWTD is linked to the EU Strategy for Energy System integration supporting energy efficiency, and energy production.

DI calls for an ambitious simplification agenda beyond the existing omnibus proposals that prioritise practical, risk-based, and innovation-friendly rules, with, cross-legislation consistency, and real reductions in administrative burdens, aiming at at least a 25% reduction overall, 35% for SMEs. Find our detailed recommendations attached.

The speed in which society is digitised and experience from the existing NIS Directive justify the new proposal as part of the EU's efforts to create the necessary cybersecurity in the Union. At the same time, numerous examples of the harm that hacker attacks and cybercrime can inflict on our society continue to be seen.

DIs response can be found in the attached document. It focuses on three overarching priorities: the need to address regulatory trade-offs across EU legislation, the importance of accelerating the deployment and scaling of solutions that already exist, and the need to strengthen skills and workforce development to support the green and digital transition of the water sector.

Confederation of Danish Industry (DI) strongly supports maintaining Energy Efficiency (EE) as a key pillar of EU competitiveness, energy security, resilience, strategic autonomy, and decarbonisation efforts. Reducing energy demand across sectors is essential to achieving a cost-efficient, resilient energy system and should remain a central complement to expanding energy supply.

The Confederation of Danish Industry share the Commissions view that the current BPR framework presents substantial regulatory and practical challenges. We are ready to contribute to identifying and implementing constructive solutions to improve the system, and our members are committed to ensuring high standards to protect the environment.

Danish Industry (DI) is Denmarks largest business and employers organisation, representing companies across the Danish economy, including manufacturers, recyclers, packaging producers and users of recycled materials. DI welcomes the opportunity to provide input on the conditions for importing recycled materials into the EU for use in packaging.

Danish Industry advocate for a balanced and workable CBAM, that effectively prevents carbon leakage and protects competitiveness of European industries, while simultaneously recognizing the impact on downstream supply chains.

AM Issue/topic Text location COM text DI’s proposed text Peak shaving products Recital 16 (16) To ensure the efficient integration of electricity generated from variable renewable energy sources and to reduce the need for fossil-fuel based electricity generation in times when there is high demand for electricity combined with low levels of electricity generation from variable renewable energy sources, it should be…

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

DI (Confederation of Danish Industry) represents more than 20.000 Danish companies across sectors. DI welcomes the Commission's initiative to facilitate the intra-EU shipment of non-hazardous waste destined for recycling and to strengthen the internal market for secondary raw materials.

The Confederation of Danish Industry (DI) welcomes the European Commissions proposal to introduce a harmonised EU energy efficiency rating scheme for data centres, building upon the established reporting framework under the Energy Efficiency Directive (EED).

To whom it may concern, On behalf of the Confederation of Danish Industry, I would hereby like to submit our comments on the Commission's proposal for a General Product Safety Regulation (attached). DI supports the European Commission’s initiative to update the existing General Product Safety Directive (GPSD) as well as its transformation into a regulation (GPSR).

DI appreciates the opportunity to comment on targeted amendments permitting the use of common specifications and paperless documentation within existing NLF legislation, namely COM(2025) 503 final and COM(2025) 504 final. Summary: DI supports the Commissions proposal to enable digital fulfilment of information obligations.

EU Commission July 8, 2025 LOBU DI-2021-23557 Danish Industry (DI) response on disclosure requirements regarding unsold con-sumer products Danish Industry (DI) thanks the EU Commission for the opportunity to respond to this consultation. DI represents more than 20.000 companies within numerous industries from production, retail and construction to consulting and tourism.

DI welcomes the possibility to submit our feedback on the EU Commission Inception Impact Assessment on “Simplification and digitalization of labels on chemicals (CLP, Detergents, Fertilising Products)”. In general, DI is in favor of the initiative on the simplification and digitalisation of the labels that should lead to clearer hazard communication on human health and environment both to consumers, professional and…

The Confederation of Danish Industries (DI) appreciates til opportunity to comment on the proposed amendments to the standardization regulation (EU) 1025/2012. The amendments strengthen the national delegation principle. It is a principle that DI supports as it is a well-proven principle that also increases inclusiveness of societal stakeholders and SMV's.

Executive Summary: DI broadly supports CADAs ambition to strengthen Europes cloud and AI capacity through investment, innovation and improved framework conditions. At the same time, digital sovereignty should be built on enhanced competitiveness, flexibility, strategic choice and robust security requirements not on protectionism or geographically based restrictions.

General comments (more detailed comments included in the attached PDF) The Confederation of Danish Industry (DI) supports the European Commission’s ambi-tion to enhance the resilience of the Single Market’s four freedoms in future times of cri-sis. We agree that crisis-mitigating measures should be readily available – under strict criteria – and swiftly applied. This requires a clear legal framework at EU level.

DI Confederation of Danish Industry welcomes the opportunity to provide input to the European Commissions evaluation of Regulation (EU) No 608/2013 on customs enforcement of intellectual property rights (IPR). From a business perspective, an effective and harmonised customs regime for the protection of IPR at the EUs external borders is crucial to protect innovation, investment, and consumer safety.

DI Construction thanks the Commission for the opportunity to comment on the draft delegated act supplementing Regulation (EU) 2024/3110 by laying down conditions for classification without testing of certain products as regards reaction to fire performance.