DIGITALEUROPE

The digital omnibus is Europes first attempt to move its digital rulebook from expansion towards simplification. DIGITALEUROPE welcomes this shift. The proposal responds to several issues that industry has raised for years: fragmentation of the data acquis, uncertainty around pseudonymisation or the proliferation of incident-reporting portals.

Europes ambition to lead in AI will only succeed if the AI Act can be implemented in a way that is credible, predictable and workable across sectors. The AI omnibus is therefore a pivotal moment not just to adjust timelines, but to determine whether simplification will be real. At present, the proposal and surrounding debate miss the core issue.

THE EXECUTIVE BRIEF: REMOVING REGULATORY BURDEN FOR A MORE COMPETITIVE AND RESILIENT EUROPE Europe’s tech future is a geopolitical imperative. Staying competitive in critical technologies like AI, quantum computing and advanced semiconductors is essential for our economic resilience, defence capability and global relevance.

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

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 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.

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital solutions play a key role in achieving the climate goals and allowing grids to absorb more power from renewable energy sources whilst also helping to balance supply and demand.

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.

17 MARCH 2023 DIGITALEUROPE position paper on the proposed Packaging and Packaging Waste Regulation Executive summary DIGITALEUROPE welcomes the revision of the EU Packaging and Packaging Waste Directive 94/62/EC and notes with appreciation the ambition and significant innovative thinking in the proposed revision which sets the direction to minimise the adverse impacts of packaging and packaging waste on the…

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

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.

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.

Critical raw materials (CRMs) are essential to the twin transition. Studies show the CRM demand for 5G network equipment, photonics, edge computing applications and quantum technologies would grow 15-fold in a fast-rollout scenario. The EU can spur public and private initiatives to promote responsible, environmentally friendly and socially sustainable CRM production, processing and recycling.

DIGITALEUROPE welcomes the European Commission’s revision of the Energy Performance of Buildings Directive (EPBD), published on 15 December 2021. Net-zero emission buildings require major changes in the way we design, build, operate and renovate buildings. Digitalisation has the potential to ensure a sustainable building sector in the European Union.

The revision of the Energy Performance of Buildings Directive is a great opportunity to lay the foundations for deep, digital and future-ready renovations of the EU’s buildings stock. The potential is obvious as buildings now contribute to about 40% of EU energy consumption and 36% to greenhouse gas emissions.

DIGITALEUROPE welcomes the Commission's efforts to simplify the European Sustainability Reporting standards (ESRS) and recognises further meaningful progress from the draft amended ESRS published by EFRAG in December 2025. In particular, we welcome the restored flexibility on Greenhouse Gas (GHG) reporting boundaries, improved omission provisions, new phase-in reliefs, and clarified materiality assessment.

DIGITALEUROPE is convinced that digital technologies are key enablers for attaining the sustainability goals of the European Green Deal and contributing to the Paris Agreement and United Nations Sustainable Development Goals (SDGs) .

Please find attached our detailed feedback, and a summary below. DIGITALEUROPE welcomes the European Commission’s legislative proposal for a Regulation laying down harmonised rules on artificial intelligence (‘AI Act’). We have been a key partner to EU institutions on AI topics for years, having notably participated in the work of the Commission’s AI High-Level Expert Group.

10 SEPTEMBER 2020 DIGITALEUROPE input to Commission Inception Impact Assessment on AI DIGITALEUROPE supports the Commission in its ambition to stimulate the development and uptake of AI and new technologies, while ensuring that any potentially linked risks are adequately addressed. In this paper, we provide our comments to the public consultation on the published Inception Impact Assessment1.

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

DIGITALEUROPE welcomes the opportunity to comment on the Commission Proposal, is supportive of a common approach and level playing field at EU level on mandatory human rights and environmental due diligence. Companies within the digital technology sector recognise their significant responsibility regarding sustainable corporate behaviour, and thus welcome the European Commission’s efforts to foster a resilient…

See attached document. DIGITALEUROPE welcomes the opportunity to comment on the Inception Impact Assessment in advance of broader public consultation and publication by the European Commission of legislative proposals in 2021.

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)

As an organisation representing over 35,000 businesses in the digital sector, DIGITALEUROPE and its members have been at the forefront of the transition of the digital industry towards more responsible and sustainable models for some years now.

The European Green Deal and the New Circular Economy Action Plan have set out a historically ambitious agenda for environmental policy. DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way.

DIGITALEUROPE welcomes the European Commission’s “Fit for 55” legislative package, published on 14 July 2021. Digital plays a key role in enabling the green transition and achieving the ambitious climate goals. Studies show that carbon emissions of traditional sectors e.g., construction, manufacturing, energy, transport, or agriculture can be cut by a fifth by 2030 through digitalisation.

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.

Please find attached our detailed recommendations, and below a summary. Europe already boasts one of the worlds most comprehensive consumer protection frameworks, applying horizontally across all consumer-facing businesses. A new Digital Fairness Act would merely duplicate existing regulations, driven by the mistaken belief that tech companies require special regulation.

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 possibility to provide feedback on the European Commission’s inception impact assessment for a Data Act and a revision of the Database Directive. Find attached all our comments. We also plan to reply to the public consultation. - Scope: The different notions applicable to the Data Act will need to be carefully defined.

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.

The Digital Services Act (DSA) proposal marks an important update to internet regulation in Europe. DIGITALEUROPE's membership supports the European Commission's ambition to strengthen the Single Market for digital services in the EU. Clarity is needed on the role and responsibilities of online intermediaries to address the problem of illegal content online and help boost trust in the internet.

DIGITALEUROPE’s membership fully supports the European Commission’s ambition to strengthen the digital services market in the EU. We agree that clarity is needed on the role and responsibilities of online platforms to make the internet safe. Illegal and harmful content is too prevalent on the internet.

DIGITALEUROPE is a great supporter of the ambitions outlined in the Commission’s proposal for a regulation on the European Health Data Space (EHDS) which in our view is not a mere regulation but rather a holistic vision for the future of health and care for Europe. More effective use of health data is necessary to address diseases impacting often vulnerable communities.

The EHDS Inception Impact Assessment sets out ambitious objectives linking together the need for secure and trusted health data sharing for what will be the creation of the first European data space. The EHDS has the potential to be the single market for digital health products and services, and the global centre of development of secure AI powered digital health.

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 appreciates the opportunity to comment on the inception IA. In the past, we have extensively commented on the ongoing revision of the Batteries Directive (Directive). The inception IA document remains vague on the relationship between the envisaged “new regulatory instrument” and the existing regulatory framework for batteries. Based on the public consultation for the eco-design prep.

DIGITALEUROPE welcomes the proposal for a Data Governance Act (DGA) and the possibility to provide feedback to the Commission. We are still finalising an in-depth analysis, but we already share below a set of early comments. Scope: The scope of the DGA needs to be clarified.

Please find attached our detailed feedback. Summary: The future EU data spaces, as outlined in the Commission’s Data strategy, will be key to create a Single Market for data that will drive the EU’s digital transformation.

The next European Chips Act must evolve from an emergency response into a strategic industrial policy that makes Europe competitive, indispensable and resilient within the global semiconductor ecosystem. It should be guided by realistic, market-driven objectives and strengthen the entire semiconductor value chain.

DIGITALEUROPE supports the ambition to manage substances to the best possible extent in order to protect human health and the environment. The REACH Regulation is a fundamental piece of legislation for the management of chemicals both in the EU and globally and across many industries, including the digital one. Therefore, DIGITALEUROPE welcomes the opportunity to provide input to the Regulation revision.

Cybersecurity has become indispensable to our economy and society, and can no longer be an add-on to Europes regulatory landscape for products. DIGITALEUROPE strongly welcomes and supports the objectives of the proposed Cyber Resilience Act (CRA), which will for the first time introduce mandatory cybersecurity requirements for products with digital elements.

24 MAY 2022 Building blocks for a scalable Cyber Resilience Act Executive summary Cyber resilience is central to Europe’s social, economic and political future. This is reflected in the name of the European Commission’s upcoming flagship proposal for a Cyber Resilience Act (CRA).1 While the name is all-encompassing, the proposal should focus on solving the most pressing issues emerged so far – notably, around…

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

FINAL DRAFT – 17 JULY 2025 DIGITALEUROPE reply to call for evidence – Regulation 1025/2012 Executive summary The European standardisation system is a successful example of a public–private partnership where roles are clearly defined, and technical expertise drives outcomes.

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

DIGITALEUROPE supports the objectives of this ambitious reform and the aim of modernising the Union Customs Code in the wake of structural changes induced by the digitalisation of trade and of business models. We also welcome the proposed improvements for a coherent and uniform interpretation of the Code, as well as reformed mechanisms striving for enhanced trade facilitation for economic operators.

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.

The proposed Right to Repair Directive creates a positive new framework to enable more European consumers to access high-quality, safe repairs. Our members perform millions of repairs annually. Their repair facilities across Europe help promote sustainable consumption, reduce ICT products environmental impact, deliver real consumer benefits, and create high-skilled jobs.

DIGITALEUROPE believes that consumers should be entitled to high-quality repairs that are safe, secure and reliable. Our members already treat repair, refurbishment and remanufacturing as part of their everyday business practice, performing millions of repairs annually.

DIGITALEUROPE welcomes the proposal for the revision of the EU Waste Shipment Regulation WSR. We believe the proposal has the potential to enable the movement of secondary raw materials, to avoid environmental dumping and burdensome shipment of secondary raw materials and accelerate the circular economy. We support the EU’s focus on enabling the shipment of secondary raw materials within the Single Market.

DIGITALEUROPE fully subscribes to the initial objective of the WSR of protecting the environment from unsound waste management practices. DIGITALEUROPE believes there is a path to further increase the level of environmental protection by achieving more circularity for the EU. Today, the Circular Economy promotes the principle that waste is a resource, which should be re-introduced into the economy.

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.

The review of the Directive on Security of Network and Information Systems (NIS2) is an essential step towards a more resilient Europe, ensuring state-of-the-art risk management of current and emerging cyber threats to vital sectors of the EU economy and society.

As the voice of digitally transforming industries in Europe, DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission’s roadmap consultation on the review of EU rules on the security of network and information systems.

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 detailed feedback. Summary: The development of high-value datasets (HVDs) in specific fields will have major positive consequences for society. Such datasets offer significant potential for citizens and businesses, to help address societal challenges and to develop innovative services and products.

DIGITALEUROPE’s members have long led the way with environmental progress, and many have put forward ground-breaking commitments and programmes to deliver innovative products and services in a sustainable way. Our members empower consumers to take part in the circular economy through numerous strategies, including providing transparent information on the sustainability credentials of our products and services…

DIGITALEUROPE welcomes the opportunity to provide input to the European Commissions call for evidence for an impact assessment on the upcoming Quality Jobs Act. Our contribution focuses on Artificial Intelligence (AI) and Algorithmic Management (AM) at work.

Full DIGITALEUROPE's feedback attached. "DIGITALEUROPE welcomes the Commissions draft delegated regulation amending Regulation (EU) 2024/1157 as regards wastes and mixtures of wastes listed in Annex III, Annex IIIA, Annex IIIB and Annex IV. We strongly support the proposed introduction of BEU09 for certain non-hazardous electrical and electronic waste and BEU10 for permanent magnets.

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.

DIGITALEUROPE fully supports the European Commission’s goal to create a comprehensive legislative framework that involves the tech sector, government and civil society to ensure better protection of children against sexual abuse and exploitation. Our members play an important role in the battle against this horrible crime and take this responsibility seriously.

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.

Of the policy options in the Inception Impact Assessment, DIGITALEUROPE supports the promotion of market-driven standardisation to address the existing technical obstacles to data reuse without introducing any new data access rights.

We welcome the opportunity to provide our feedback on the VAT in the Digital Age proposal of the European Commission. We fully support the European Commissions ambition to improve the VAT system through the use of digital tools, reducing VAT-related barriers for cross-border trade in the EU and making the VAT system better for businesses, while also more resilient to fraud.

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.

In this contribution, DIGITALEUROPE follows up on the IP Action Plan’s proposal to evaluate the EU’s Compulsory Licensing framework. This builds on the comments previously provided as part of our comments on the IP Action Plan as a whole (our 2021 paper is attached separately).

MARCH 2026 Feedback on simplification of energy efficient product legislation Executive summary Following the implementation dialogue on energy efficient product regulations with Commissioner Dan Jørgensen on 14 October and the ‘reality check’ meeting on energy efficient product legislation that DG ENER hosted on 8 December, this paper provides additional feedback on ways to simplify and improve EU energy-related…

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

DIGITALEUROPE welcomes the recent publication of the European Commission’s EU Standardisation Strategy. We stand ready to support the Commission in leveraging global standards in support of a resilient, green and digital EU Single Market.

Background Persistent organic pollutants (POPs) are poisonous chemicals that break down slowly and get into the food chain, harming the environment and our health. Waste that contains POPs is of particular concern. The EU therefore sets concentration limits for these chemicals, which it reviews regularly to reflect the latest research.

DIGITALEUROPE believes the baseline policy option detailed in the inception impact assessment is the most suitable to advance instant payments today in Europe. At this stage, monitoring the market evolution and assessing the effects of voluntary efforts is the most sensible decision to foster the growth of instant payments, while the industry works to address their challenges. Please see attached our response.

DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…

DIGITALEUROPE welcomes the new set of standard contractual clauses (SCCs) for transferring personal data to third countries published by the European Commission. In particular, the new modular approach allows for many processing and transfer situations that were not captured under the current SCCs, bringing greater clarity and protection along with further modifications necessary in light of the General Data…

DIGITALEUROPE appreciates the opportunity to provide feedback on the European Commission's call for evidence on the establishment a common EU position to be negotiated by Member States on behalf of the EU at the World Radiocommunication Conference 2023. Our views, along with their underlying justifications, are set out in the attached position paper.

DIGITALEUROPE welcomes efforts by the European Commission to address the distortion caused by foreign subsidies in the Single Market, which may provide certain businesses an unfair competitive advantage in the global market. Any new instrument should be focused on identifying, assessing, and mitigating distortion caused specifically by subsidies while remaining proportionate, fair and non-discriminatory.

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.

The changing nature of the threat landscape requires better protection and more investment in the EU’s resilience capacities to secure our critical infrastructure. DIGITALEUROPE welcomes the Commission’s effort to strengthen the resilience of critical entities across the EU by developing and updating relevant legislation.

DIGITALEUROPE welcomes the opportunity to provide a response to the Commission’s consultation on the possible review of the existing Critical Infrastructure Directive (hereinafter “ECI Directive”) and the subsequent inception impact assessment.

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 proposed Regulation laying down additional procedural rules for the enforcement of the General Data Protection Regulation (GDPR). The proposal is an opportunity to reinforce the one-stop-shop (OSS) mechanism, which is central to the Digital Single Market. As is the proposals intention, this can be done by complementing, without reopening, the GDPR.

DIGITALEUROPE welcomes the European Commissions initiative to facilitate more harmonised procedural cooperation in cross-border enforcement of the General Data Protection Regulation (GDPR). We believe these efforts will greatly contribute to a reinforced one-stop-shop (OSS) mechanism, which we deem crucial for both businesses and data subjects.

DIGITALEUROPE believes that this initiative should only be limited to classes of radio equipment for which there is a clear evidence showing that the upload of software on radio equipment could lead to a serious risk of non compliance in the EU market. So far, problems causing a risk of non-compliance with the RED due to software uploads have not been clearly identified.

DIGITALEUROPE thanks the Commission for the opportunity to provide feedback on the European Chips Act package. Our organisation represents multiple stakeholders across the semiconductor ecosystem, including in areas like chip design, chip production and chip usage.

On 8th December 2021, the European Commission published its proposal for a “Regulation on the protection of the Union and its Member States from economic coercion by third countries”, the Anti-Coercion Instrument (ACI) Proposal.

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.

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.

In order to secure more efficient law-making in taxation policy, the Commission wants to substitute unanimity with qualified majority voting at the Council and consultation with codecision as far as the European Parliament is concerned. The business of today is global. DIGITALEUROPE supports comprehensive, global, long-term tax solutions negotiated through the OECD that also includes Europe’s main trading partners.

The draft DORA regulation is an opportunity to further accelerate the digital transformation of finance and show the EU’s global leadership in defining a first-of-its-kind framework for outsourced ICT operations in financial services. Yet, unclear and potentially overlapping provisions in the existing draft risk to dramatically hamper the achievement of these goals.

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.

DIGITALEUROPE, representing the digitally transforming industries in Europe, supports the initiative's objectives of increasing the material and energy efficiency of imaging equipment incl. consumables, and welcomes the opportunity to respond to the European Commission's call for evidence. Please see attached our more detailed position on the initiative.

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.

DIGITALEUROPE welcomes the opportunity to provide input to the consultation on the Roadmap for the Review of the Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS).

In the context of the ongoing public consultations on the updated EU rules on ecodesign and energy labelling that are open until 3 November and in view of the upcoming meeting of the Committee on Ecodesign and Energy Labelling of Energy–related Products on 10 November, DIGITALEUROPE has identified several critical issues in the adopted requirements for electronic displays, servers and data storage products.

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.

DIGITALEUROPE appreciates the opportunity to contribute its input to the new set of standard contractual clauses (SCCs) between controllers and processors located in the EU published by the European Commission. Contract negotiations following the General Data Protection Regulation (GDPR) have centrally revolved around defining clear tasks of the parties, as separate or joint controllers or processors; as in any…

DIGITALEUROPE appreciates the opportunity to contribute its input new set of standard contractual clauses (SCCs) between controllers and processors located in the EU published by the European Commission. Contract negotiations following the General Data Protection Regulation (GDPR) have centrally revolved around defining clear tasks of the parties, as separate or joint controllers or processors; as in any other…

DIGITALEUROPE and its’ members take their responsibility to maintain the safety, security, and privacy of millions of users seriously. They also recognise that there are situations where they need to assist law enforcement agencies (LEAs) carrying out investigations into criminal activity.

DIGITALEUROPE welcomes AGILE to accelerate high-TRL, dual-use and digitally enabled capabilities across Europes defence ecosystem. It should enable SMEs, startups and innovative companies to respond to challenge-driven defence needs. Recent conflicts in Ukraine and the Middle East demonstrate that operational advantage increasingly depends on how rapidly new technologies can be developed, validated and fielded.