DIGITALEUROPE

DIGITALEUROPE welcomes the opportunity to provide input to the forthcoming Industrial Decarbonisation Accelerator Act (IDAA). Integrating digital technology into the implementation of the Clean Industrial Deal is not only a strategic move; it is necessary for achieving a sustainable, competitive and resilient industrial sector. Please see more concrete recommendations in the attachment.

Public procurement is one of Europes most significant economic levers. The 2014 Public Procurement Directives established a strong framework, but inconsistent implementation across Member States has prevented their full potential from being realised, limiting cross-border participation and European competitiveness.

DIGITALEUROPE welcomes the European Commissions initiative to establish a 28th regime, a voluntary legal and administrative framework for businesses operating across the EU. As proposed in the Letta report, European startups and scaleups need a simplified and uniform legal framework that allows them to focus on growth rather than paperwork.

Please find attached our detailed recommendations, and below a summary. Public procurement is one of Europes most significant economic levers. The 2014 Public Procurement Directives established a strong framework, but inconsistent implementation across Member States has prevented their full potential from being realised, limiting cross-border participation and European competitiveness.

DIGITALEUROPE welcomes the proposed Digital Networks Act (DNA) and supports its objective of delivering a more harmonised, simplified and investment-friendly connectivity framework across the European Union. The transition from a Directive to a Regulation is a positive step towards reducing fragmentation and enabling greater scale in Europe's connectivity market.

Europes ambition to lead in connectivity is being held back by a regulatory framework that no longer matches the realities of todays digital infrastructure. As the Commission explores reform through the upcoming Digital Networks Act (DNA), it is time to move towards a simplified, harmonised and investment-focused model.

DIGITALEUROPE welcomes the European Commissions initiative to comprehensively review the taxonomy technical screening criteria in the climate and environmental delegated acts. Large swathes of companies struggle with implementation of the taxonomy due to its overly complex reporting requirements and usability challenges.

DIGITALEUROPE welcomes the European Commissions initiative to comprehensively review the taxonomy technical screening criteria in the climate and environmental delegated acts. Large swathes of companies struggle with implementation of the taxonomy due to its overly complex reporting requirements and usability challenges.

18 July 2023 DIGITALEUROPE feedback on Substantiating Green Claims’ public consultation Executive summary The proposed Green Claims Directive (GCD) is a positive step toward combating greenwashing. However, its effectiveness will depend on enforcement and the establishment of clear methodologies.

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

See attached the full position. Summary: In the recent years, the EU has built one of the worlds most ambitious regulatory frameworks for cybersecurity, driven by rising cybersecurity risks. The challenge the newly proposed cybersecurity package must meet is to make it work in practice.

The EUs cybersecurity framework has undergone substantial expansion since the adoption of the Cybersecurity Act (CSA) in 2019. Alongside the CSA, new legislative instruments including NIS2, the Cyber Resilience Act (CRA), DORA and the Cyber Solidarity Act now define a much more comprehensive and multi-layered regulatory architecture for cybersecurity across the single market.

A balanced copyright framework plays a crucial role in supporting creativity, investment, access to knowledge and innovation. The EU has made significant progress in adapting copyright rules to the digital environment, including via the Copyright (CDSM) Directive and the copyright-related provisions of the AI Act.

Taxonomy Climate Change Delegated Act - activity 8.1 Data processing, hosting and related activities DIGITALEUROPE welcomes the European Commission's efforts to update the technical screening criteria for Activity 8.1 under the EU Taxonomy Climate Change Mitigation (Annex I) and Climate Change Adaptation (Annex II) Delegated Acts.

A European Innovation Act to boost commercialisation and enable growth. Europe does not suffer from a lack of innovative ideas and research it suffers from a lack of commercialisation. This is the core challenge the European Innovation Act must address if Europe is to remain globally competitive. To translate ideas into growth, the Act must: 1.

DIGITALEUROPE welcomes the Commissions strategic evaluation of the EUs connectivity landscape. Our vision aims to elevate Europe to a Digital Powerhouse, setting ambitious targets for universal gigabit internet and 5G coverage by 2030, necessitating decisive policy actions. Europe has long grappled with connectivity challenges compared to global peers.

Please find attached DIGITALEUROPE's Priorities for Europe's Skills Agenda, among which the following recommendation: "DIGITALEUROPE supports the Skills Portability Initiative as a cornerstone of the EU Single Market. It should build on our call for a Digital Skills Passport incorporating industry-recognised qualifications, certifications, micro-credentials, digital badges and courses.

DIGITALEUROPE brings together a diverse range of companies leading the digital transformation of Europes energy infrastructure. Our members include energy providers, clean tech leaders like grid equipment manufacturers, and energy consumers like data centres.

Electrification is central to Europes competitiveness, addressing the energy trilemma of affordability, security and sustainability. Replacing imported fossil fuels with homegrown clean electricity can shield EU industry from volatile costs and boost competitiveness. Yet, electricity makes up just 23 per cent of final energy use, well below climate-neutrality needs.

Executive summary The Delegated Act on rules for DPP service providers presents a critical opportunity to establish a framework that is both effective and pragmatic. Open and constructive dialogue with industry will key moving forward to shape a framework that meets regulatory goals, reduces administrative burdens for all actors, and guarantees the safety and integrity of the DPP system.

The clarifications provided in the draft guidance in support of the Cyber Resilience Act (CRA) are most welcome. Nevertheless, several important amendments are required to ensure an effective CRA that works in practice. To that end, please see DIGITALEUROPE's HYS comment template attached.

Quantum technologies promise to revolutionise Europes economy and security, but the current EU quantum technology programme is fragmented. To help quantum companies scale at home whilst preserving Europes openness, the EU must provide immediate support to the quantum sector and simultaneously develop a new regulatory framework geared towards industrial application.

Please find attached our detailed recommendations, and below a summary. DIGITALEUROPE welcomes the European Commissions initiative to develop a European business wallet (EBW), as announced in the 2025 Commission Work Programme and to build upon the EU Digital Identity Framework.1 The EBW is intended to address long-standing fragmentation in the way businesses identify themselves, share credentials, and interact with…

Please find attached our recommendations specifically for prominence of audiovisual media services, and below a short summary. Prominence rules applicable to distributors of audiovisual service providers and user interface providers require harmonisation. To achieve this, the European Commission should issue guidance on prominence, as foreseen by the European Media Freedom Act (EMFA) .

FINAL DRAFT – 29 AUGUST 2025 Less paper, more standards: The case for digitalisation and for repairing, not replacing, Europe’s standardisation system Executive summary The fourth omnibus proposal touches on two important areas for European industry: the digitalisation of product documentation – which can reduce burdens for companies and take forward Europe’s digital transformation – and the generalisation of common…

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

DIGITALEUROPE welcomes the European Commission's draft delegated act establishing a common Union rating scheme for data centres. The rating scheme represents an important step towards transparency and performance improvement across Europe's digital infrastructure sector. The automatic label generation approach demonstrates the Commission's commitment to creating a workable, climate-aware framework.

FINAL DRAFT – 29 AUGUST 2025 Less paper, more standards: The case for digitalisation and for repairing, not replacing, Europe’s standardisation system Executive summary The fourth omnibus proposal touches on two important areas for European industry: the digitalisation of product documentation – which can reduce burdens for companies and take forward Europe’s digital transformation – and the generalisation of common…

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

DIGITALEUROPE welcomes the continued collaborative approach on the Battery Regulation labelling provisions, including earlier discussions with the European Commission, Member States and stakeholders experts in the Expert Group on Waste. We appreciate that several of our earlier recommendations have been taken into consideration on the draft act, and the opportunity to provide the following additional feedback.

DIGITALEUROPE welcomes the Digital Decade Policy Programme (DDPP) review at a moment of profound geopolitical, technological and economic change. Since the DDPPs adoption in 2022, Europe has faced a significantly altered security environment, marked by Russias continued aggression against Ukraine, rising hybrid threats and a more contested global technology landscape.

Thank you very much for the opportunity to react to this draft implementing act. Whilst we are appreciative of the substantial work already done, we see a need for further improvements to the both the recitals and technical descriptions, predominantly to provide greater legal certainty.

Overall, the draft act lacks clear mechanisms for defining confidentiality levels and access conditions, creating a critical gap in the protection of intellectual property (IP) and trade secrets (TS) in EHDS implementation. Missing safeguards: There is no clear process or tag for data holders to label commercially sensitive information or define confidentiality levels.

DIGITALEUROPE welcomes the establishment of the EHDS Board as a crucial element for the successful and harmonised implementation of the EHDS. While the draft Implementing Act provides some level of clarity on its operations, we believe that the areas outlined below should be further formalised in the Implementing Act: 1) Formal and meaningful stakeholder collaboration: the draft Implementing Act does not provide…

DIGITALEUROPE welcomes the forthcoming Communication on the Defence Single Market to strengthen Europe's defence technological and industrial base. From the digital and dual-use industry's perspective, the priority is to accelerate deployment by reducing fragmentation and translating innovation into scalable, interoperable capabilities.

Please find attached detailed comments, and below our key observations and recommendations on the draft implementing act on AI regulatory sandboxes: - Regulatory sandboxes should operate with harmonised processes, uniform treatment and predictable outcomes across the EU. The European AI Board should receive a clear mandate to coordinate sandboxes and issue EU-wide guidelines, in partnership with industry.

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty.

DIGITALEUROPE welcomes the opportunity to express its views on the EUs future export control policies, and the European Commissions White Paper on Export Controls specifically. We appreciate the Commissions efforts to protect European know-how and businesses.

DIGITALEUROPE welcomes the opportunity to respond to the European Commission's Call for evidence and lend support to the reviewing of Ecodesign Regulation 2019/2021 and Energy labelling Regulation 2019/2013. This position paper elaborates on our perspectives and recommendations concerning the proposed review and potential revision of these regulations.

DIGITALEUROPE welcomes the opportunity to provide feedback to the draft delegated regulations amending Annex I to the Regulation on persistent organic pollutants to amend the limit values for unintentional trace contamination (UTC) for PCBs and PBDEs.

Estimated savings, complexity & duty cycle Industry would caution on the increase of the estimated energy saving potential. Projecting PC usage and energy consumption growth to 2030 is meaningless; projections involving digital technology further than five years ahead provides no degree of accuracy or certainty.