Trade union · Germany · EU Transparency Register 07595112423-87
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Among the 410 trade unions and professional associations on this site, they rank #17 by legislative files engaged, a count of participation, not a measure of influence.
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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DGB filed 22 positions between 7 Oct 2020 and 2 Jun 2026, across 20 of the 665 legislative files tracked here, attaching a full position paper 14 times.
The aim of simplifying and optimising the European digital rulebook is in principle to be welcomed. However, the Commission’s proposals are not suitable for achieving the objective and may even lead to serious interferences with personality rights in the employment context.
Filed in German · English published by the European Commission
The DGB welcomes the Commission’s intention to simplify the implementation of the AI Regulation and to ensure the necessary legal certainty. There is a high degree of legal uncertainty regarding the classification of AI applications in high-risk areas under Article 6 of the AI Regulation.
Filed in German · English published by the European Commission
DGB-Stellungnahme zum europäischen Kreislaufwirtschaftsgesetz Der Aufbau einer Kreislaufwirtschaft ist ein zentraler Baustein für die sozialökologische Modernisierung der europäischen Industrie und Wirtschaft. Aus Sicht des Deutschen Gewerkschaftsbundes (DGB) leistet sie nicht nur einen wesentlichen Beitrag zum Klima- und Ressourcenschutz, sondern stärkt zugleich die Resilienz industrieller Wertschöpfungsketten…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Stellungnahme des Deutschen Gewerkschaftsbunds zum Industrial Accelerator Act (IAA) Kernforderungen im Überblick • • • Seite 1/15 Schlupflöcher schließen und Ausnahmen auf wenige strategische Handelspartner begrenzen Die Wirksamkeit von Local-Content-Vorgaben und den vorgesehenen Regelungen für ausländische Direktinvestitionen darf nicht durch weitreichende Ausnahmen verwässert werden.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The DGB firmly rejects the European Commission’s proposal for a regulation establishing the EU Inc. The draft does not create meaningful harmonisation of European company law, but opens up new possibilities to circumvent participation rights, labour standards and social protection mechanisms. Instead of addressing Europe’s economic challenges, such as underinvestment or lack of access to finance, the EU Inc.
Filed in German · English published by the European Commission
The German Trade Union Confederation (DGB) firmly rejects the proposal for a 28th regime. The new European legal framework would provide companies with additional tools to weaken co-determination structures and circumvent national labor law. As a consequence, it would significantly undermine the autonomy of the social partners and the rights of workers and their representatives.
The DGB refers to its ‘trade union requirements for a modern supply of raw materials’ (see Annex). A strategic raw materials policy must meet the demands of sustainability, security of supply and good work. In the DGB’s view, four objectives should be pursued: Promote circular economy and, where possible, reduce the consumption of raw materials and reduce good work and high environmental standards along the raw…
Filed in German · English published by the European Commission
The DGB and its member trade unions strongly oppose the proposed amendments to the ESRS in the context of the European Commission’s draft regulation. In the view of the DGB and its member trade unions, the planned adjustments do not lead to meaningful relief, but rather to a significant weakening of sustainability reporting and jeopardise the CSRD’s objective of providing transparent, comparable and reliable…
Filed in German · English published by the European Commission
Feedback Online Consultation EU Commission ARTIFICIAL INTELLIGENCE ACT 21 April 2021 In principle, the German Trade Union Confederation – DGB – welcomes that the EU Commission generally classifies AI systems as high-risk in the context of labour and employment as well as in education or vocational training and thus makes them subject to special approval conditions.
The DGB shares the Commission’s analysis that the short-term nature of enterprise policy has a negative impact on sustainability. One of the many manifestations of the short-term idea is the recent call by international financial investors in the German debate on corporate governance to shorten the term of office of supervisory boards. This would create a worrying incentive for short-term policy.
Filed in German · English published by the European Commission
Stellungnahme Stellungnahme des Deutschen Gewerkschaftsbundes zur Konsultation der EU-Kommission zur Überprüfung des EUEHS (See- und Luftverkehr und ortsfeste Anlagen) sowie der Marktstabilitätsreserve Ausgangslage Die Herausforderungen der europäischen Wirtschaft sind enorm.
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
In addition to ETUC views on Skills Portability Initiative, the DGB explains its position on the proposal for a Skills Portability Initiative. The German Trade Union Confederation (DGB) emphasizes the importance of recognizing foreign qualifications as a means to combat exploitation, improve working conditions, and facilitate access to training.
stellungnahme Stellungnahme des Deutschen Gewerkschaftsbundes zum Richtlinienvorschlag der Europäischen Kommission über eine „Corporate Sustainability Reporting Directive“1 07.06.2021 1) Einleitung und zusammenfassende Hinweise Deutscher Gewerkschaftsbund Für den Deutschen Gewerkschaftsbund (DGB) und seine Mitgliedsgewerkschaften hat die nachhaltige Entwicklung in Deutschland, in Europa und weltweit einen hohen…
Filed in German · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
As Germany's largest trade union confederation, the DGB supports the aim of revising Regulation (EU) No 1025/2012 to enhance the European Standardisation System (ESS). Standards are vital for market access and competitiveness, but must also safeguard societal interests. Inclusiveness and democratic legitimacy must remain the guiding principles of European standardisation policy.
The European Commission presented a proposal on the Machinery Regulation in April 2021. The Regulation is intended to replace the existing Machinery Directive. The proposed rules on machinery aim to ensure that the new generation of machinery products ensures the safety of users and consumers and encourages innovation. Machinery products include a wide range of consumer and professional products — from robots (e.g.
Filed in German · English published by the European Commission
DGB views on EUs VET Strategy In addition to the ETUC views on Building a Worker-Centred VET Strategy for Quality Jobs and Fair Transitions, the DGB explains its position on the proposal for a new EU VET Strategy. A European Strategy for Vocational Education and Training (VET) must not become a one-way street for employees. We see it as an equal challenge for businesses and companies.
DGB (German Confederation of Trade Unions) does not question the European standardisation system as governed by Regulation (EU) No 1025/2012, nor the process by which the European Commission, in line with specific procedures, can mandate the development of standards and standardisation deliverables to support Union legislation and policies.
The evaluation of the Shareholders’ Rights Directive must take into account the different corporate governance systems and industrial relations structures in the Member States. Germany is characterised by the dualist board system: The board of directors manages the company, which supervises and appoints a co-determined supervisory board.
Filed in German · English published by the European Commission
The DGB strongly welcomes the Commissions intention to present a Fair Labour Mobility Package. This initiative is crucial to address persistent shortcomings in the internal market that undermine workers rights and fair competition.
The DGB supports the introduction of a European Social Security Pass (ESSPASS) as a tool to protect and enforce workers’ rights more effectively across borders. The current system has too much potential for abuse due to fragmented processes and forms that cannot be authenticated in real time.
Filed in German · English published by the European Commission
If undertakings post workers to another Member State to provide a service there, they must submit a posting declaration at the request of the host Member State. Without these controls would be largely impossible because it would not be clear which posted workers are deployed in the country.
Filed in German · English published by the European Commission
The German Trade Union Confederation welcomes the possibility of a consulate on the ERDF for the 2014-2020 funding period. The DGB has been involved in the planning, design and implementation of operational programmes in numerous monitoring committees at federal, regional and regional level.
Filed in German · English published by the European Commission
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