DigitalTrade4.EU

Our feedback outlines how the European Trade Indexes Registry (EUTIR) can strengthen the EUs Digital Omnibus initiative by providing a unified, cross-sector trust infrastructure that ensures interoperability, reduces administrative burdensespecially for SMEsand enhances legal certainty across digital trade, sustainability, customs, and financial frameworks.

The document outlines the strategic synergy between the proposed Circular Economy Act (CEA) and the European Trade Indexes Registry (EUTIR) as a foundation for advancing the EUs green and digital transition. It advocates for EUTIR as a decentralized, interoperable digital infrastructure that ensures authenticity, traceability, and trust in cross-border trade data.

DigitalTrade4.EU proposes targeted changes to ensure that digital procurement remains legally accountable, proportionate and workable in practice. Technical verification failures or inconclusive results should not be treated as non-compliance, and economic operators should have a clear route to correct material data errors or use a lawful fallback before an adverse decision is taken.

DigitalTrade4EU welcomes the European Commission's initiative for an Industrial Decarbonisation Accelerator Act and outlines how digital trade solutions can enhance its success. This document emphasizes that digitalisation is not just complementary but essential to achieving rapid cost effective and inclusive decarbonisation in Europe. To read more download the full document

The Input to Digital Network Acts 2025 presents the consolidated feedback of the DigitalTrade4.EU consortium in response to the European Commissions strategic initiatives on the Digital Networks Act and the European Data Union. Our consortium outlines a unified vision for a secure, interoperable, and dual-use digital infrastructure that supports both economic competitiveness and defence readiness.

Our feedback to the EU Commission on the proposed 28th regime for an EU corporate legal framework highlights its potential to significantly strengthen Europes business environment by reducing legal fragmentation and lowering administrative burdens.

The document provides strategic input to the European Commission on the integration of the European Trade Indexes Registry (EUTIR) into the proposed 28th Company Law Regime. It outlines how EUTIR can serve as a digital trust anchor, enhancing legal certainty, interoperability, and efficiency for EU-based businesses.

This document presents a proposal for a European Trade Indexes Registry (EUTIR), a foundational digital infrastructure designed to strengthen EU competitiveness. Acting as a trust anchor for trade data, EUTIR ensures authenticity, traceability, and machine-readability across the Single Market.

Our feedback to the European Commission outlines strategic steps to modernize the EU Emissions Trading System (ETS) through digital innovation, ensuring it becomes a globally integrated, data-driven carbon market.

Our feedback to the European Commission highlights the strategic role of the European Trade Indexes Registry (EUTIR) in enabling the successful implementation of the Clean Corporate Vehicles Regulation and advancing the EUs green-digital transition.

This document presents feedback from DigitalTrade4.EU, a pan-European consortium of trade, logistics, and technology experts, to the European Commission. It advocates for aligning digital trade solutionsparticularly interoperable standards like MLETR and eIDAS 2.0with the EU's cybersecurity and defense initiatives.

This document, prepared by the DigitalTrade4.EU consortium, provides strategic input for the revision of the EUs Carbon Border Adjustment Mechanism (CBAM) and the New Legislative Framework (NLF). It proposes the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to support secure, transparent, and efficient cross-border trade.

The European Trade Indexes Registry (EUTIR) is a proposed EU-level digital infrastructure designed to enhance trust, transparency, and interoperability in cross-border trade. By securely registering and verifying metadata of trade-related datasetssuch as those used in the Carbon Border Adjustment Mechanism (CBAM), Digital Product Passports (DPP), and electronic Freight Transport Information (eFTI)EUTIR acts as a…

Carbon Border Adjustment Mechanism (CBAM): Downstream Extension, Anti-Circumvention Measures, and Electricity Emission Rules 1 U About Us The DigitalTrade4.EU consortium envisions a seamlessly interconnected Europe and neighbouring regions powered by harmonized standards for the digitalisation of trade documents and processes.

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

The Commissions assessment rightly points out limitations in the current SFDR framework that hinder private investment in the sustainable transition and risk excluding certain sectors. To avoid a fragmented single market for sustainable finance, Union-level action is needed to simplify the existing framework.

This document provides feedback to the European Commission on the proposed European Innovation Act, emphasizing the strategic role of the European Trade Indexes Registry (EUTIR) in advancing a digital, sustainable, and innovation-friendly Single Market.

The document titled Climate-Digital Synergies for a Trusted Trade Framework presents a strategic policy proposal to the European Commission, advocating for the integration of digital and climate objectives through the establishment of the European Trade Indexes Registry (EUTIR).

Our feedback proposes integrating the Carbon Border Adjustment Mechanism (CBAM) with the European Trade Indexes Registry (EUTIR) to create a trusted, interoperable digital foundation for carbon price deduction and compliance.

Our feedback outlines a strategic proposal to integrate Nature Credits into the European Trade Indexes Registry (EUTIR), establishing a unified digital trust infrastructure for environmental, trade, and sustainability data.

We support the Commissions objective to strengthen Europes semiconductor ecosystem, technological sovereignty, supply-chain resilience and crisis preparedness. Chips Act 2.0 rightly combines stronger R&D&I support, Strategic Projects, innovation procurement and improved semiconductor supply-chain intelligence.

Our feedback proposes integrating the CBAM implementing acts with the European Trade Indexes Registry (EUTIR) and eIDAS 2.0 to transform CBAM from a compliance mechanism into a trusted digital trade infrastructure.

The document outlines a strategic proposal to strengthen the European Union's steel sector through digital transformation by integrating the European Trade Indexes Registry (EUTIR) into the EUs regulatory and trade infrastructure. It emphasizes the need for digital trust, traceability, and interoperability in safeguarding the steel industry against global overcapacity and unfair trade practices.

The document is a comprehensive policy feedback submission by the DigitalTrade4.EU consortium to the European Commission, focusing on the revision of the New Legislative Framework (NLF) and its integration with the European Climate Resilience Framework.

This document provides feedback from the DigitalTrade4.EU consortium to the European Commission on the digitalization of recycled plastic content reporting for single-use beverage bottles. It emphasizes the strategic importance of the Digital Product Passport (DPP) in enhancing transparency, traceability, and compliance across the EU Single Market.

Our feedback to the European Commission links the development of a CO Market and Infrastructure with the EU Trade Framework 2025 (EUTIR), advocating for a unified digital trust backbone. We demonstrate how EUTIRs secure, interoperable registry can provide legal certainty, reduce risks, and enable SME access for cross-border carbon transport and storage.

We recommend that the revised EIT framework strengthen its role as the bridge between research, cross-border experimentation, market deployment and investment readiness. This is particularly important for horizontal innovations that cut across several sectors and KICs, such as trusted digital interoperability, verified trade and regulatory evidence, governed AI, supply-chain resilience and regulated finance.

We recommend that the Commission include trusted trade-finance interoperability and verified trade events among the thematic priorities for EU research and innovation funding from 2028 onwards. Cross-border trade increasingly generates authoritative digital evidence on shipment, delivery, customs, documentary and commercial events, but these data remain insufficiently connected to regulated financial processes.

Our feedback addresses the strategic integration of Digital Product Passports (DPPs) into the revised Regulation (EU) 2019/631, which sets CO emission standards for new passenger cars and light commercial vehicles. We highlight how DPPs can provide a robust digital infrastructure for tracking emissions, vehicle lifecycle data, and sustainability metrics across the automotive sector.

Created document by DigitalTrade4.EU outlines a strategy to harmonize digital innovation and sustainability in EU trade. Central to this vision are the European Business Wallet (EBW) and Green Economy framework, which together aim to streamline cross-border business operations while advancing environmental accountability.

Our feedback proposes integrating the European Trade Indexes Registry (EUTIR) as a foundational digital trust infrastructure to strengthen the implementation of the Carbon Border Adjustment Mechanism (CBAM). By anchoring emissions data, EU ETS free allocation benchmarks, and foreign carbon price payments through cryptographic hashes, unique identifiers, and Mutual Recognition Agreements, EUTIR enhances verification…

The contribution argues that future EU rules on algorithmic management should complement, rather than duplicate, the AI Act. The focus should be on how automated systems influence significant employment decisions and on whether those decisions remain attributable, reviewable and contestable in practice. The proposed approach is based on the principle Trace the decision, not the worker.

We support the Commissions objective to simplify intra-EU waste shipments for recycling by clarifying and extending green-listed waste categories and by introducing harmonised classification criteria. This can reduce administrative burden while supporting a stronger Single Market for secondary raw materials.

Our feedback addresses the European Commissions proposal COM(2025) 504 and its annexes, focusing on the integration of the European Trade Indexes Registry (EUTIR) into the New Legislative Framework (NLF). We propose EUTIR as a foundational digital infrastructure that ensures legal validity, traceability, security, and interoperability of electronic trade documents across the EU.

The DigitalTrade4.EU consortium provides feedback to the European Commission on strengthening the EUs leadership in green and digital trade. The consortium supports the Commissions Omnibus proposals aimed at reducing administrative burdens, promoting digital-by-default practices, and introducing common specifications for harmonized standards.

DigitalTrade4.EU proposes a targeted approach to reducing cross-border tax compliance burdens under COM(2026) 560 through the use of reliable, machine-readable electronic evidence and interoperable digital procedures. The European Business Wallet could support business identification, representation and the secure exchange of supporting information between companies and tax authorities across Member States.

Our feedback highlights the urgent need for the European Commission to align sustainability goals with digital transformation by accelerating the adoption of Digital Product Passports (DPPs), enhancing interoperability through global standards like MLETR and eIDAS 2.0, and simplifying compliance for businessesespecially SMEs.

The Commissions impact assessment confirms that fragmentation remains one of the most persistent barriers to fully integrated EU capital markets. National regulatory and supervisory silos continue to drive up costs, limit investment opportunities, and hinder market-driven consolidationultimately preventing the single market from reaching its full potential.

We support the Commissions objective to simplify energy and tyre labelling rules through better use of digital tools, stronger EPREL functionality and the once-only principle. In particular, the proposed interlinking of EPREL with the Digital Product Passport (DPP) offers an important opportunity to reduce duplicate registration and repeated document requests.

We welcome the Commissions approach to recycled-content traceability and verification under Regulation (EU) 2023/1542. The draft already establishes a distributed chain-of-custody model in which supply-chain actors retain traceability data in their own systems, while relevant data are exchanged across consecutive actors and verified by notified bodies.

Many strategically important European use cases rely on data distributed across authoritative enterprise, logistics, customs, regulatory and financial systems. These data may be commercially sensitive, legally constrained or operationally unsuitable for migration into a common AI platform.

This document presents feedback from the DigitalTrade4.EU consortium on the European Commissions proposals to simplify and digitalise the Common Agricultural Policy (CAP). It highlights the importance of leveraging digital tools and interoperability standards to reduce administrative burdens, support SMEs, and enhance the competitiveness and sustainability of the EU agricultural sector.

The document provides feedback to the European Commission on the 2025 Omnibus Package (COM(2025) 501), advocating for proportional regulation tailored to small mid-cap enterprises (SMCs). It highlights the need to extend SME-friendly simplificationssuch as reduced administrative burdens in GDPR, Prospectus Regulation, Batteries Regulation, and F-gas Regulationto SMCs, which face similar challenges but are often…

Our consortium DigitalTrade4.EU input to the European Commissions Omnibus 2025 proposals focuses on digital trade reforms to enhance the competitiveness of SMEs and Small Mid-Cap enterprises through interoperable infrastructure and reduced administrative burdens.

This feedback recommends targeted amendments to the draft delegated regulation before its adoption. The proposed changes aim to strengthen the reliability, traceability and operational usability of the evidence supporting the country list and authorised facilities.

The DigitalTrade4.EU consortium welcomes the European Commissions proposal to postpone battery due diligence obligations to August 2027. This response advocates leveraging the delay to build a resilient digital framework centered on Digital Product Passports (DPPs), ensuring supply chain transparency and regulatory alignment with EU Green Deal goals.

The feedback proposes evidence continuity as a practical way to assess whether the Employers Sanctions Directive works effectively from inspection through enforcement and worker remedies. The core question is whether facts already established by a competent authority can remain attributable, current and usable at later stages without unnecessary re-collection or re-verification.

Our feedback on the draft Implementing Regulation for Qualified Electronic Ledgers aims to future-proof the legal framework by embedding essential functionalitiessuch as metadata lifecycle management, exclusive control, and harmonised certificationthat ensure interoperability and legal validity across all electronic documents.

Our feedback aims to support the European Commission in aligning the Liquidity Coverage Ratio Delegated Regulation with the EUs broader goals of digitalisation, sustainability, and competitiveness. Building on recent policy milestones, our recommendations focus on enhancing financial resilience through the integration of digital tools, interoperable standards, and ESG-linked incentives.

The document presents proposed amendments to Commission Implementing Regulation (EU) 2019/2072, aimed at modernizing the EU's framework for regulating non-quarantine pests (RNQPs). Developed by the DigitalTrade4.EU consortium, it advocates for the integration of digital solutions such as Digital Product Passports (DPP), verifiable Legal Entity Identifiers (vLEI), and eIDAS 2.0-compliant cryptographic sealing to…

The document is a comprehensive feedback to the European Commissions Call for Evidence on the Review of the Merger Guidelines. It advocates for modernizing the EUs merger control framework to align with the green and digital transitions, emphasizing the integration of data-driven competition, sustainability, and resilience into merger assessments.

This document presents a strategic proposal for establishing the European Trade Indexes Registry (EUTIR) as a foundational trust infrastructure for EU digital trade. It outlines how EUTIR supports the EUs Multiannual Financial Framework (MFF) priorities by enhancing resilience, enabling the green and digital transitions, and improving crisis preparedness.

The evaluation of Regulation (EU) 2021/821 should consider not only the effectiveness of export-control decisions themselves, but also the end-to-end administrative, evidentiary and financing frictions created when those decisions and regulatory states must be used across exporters, competent authorities, customs, logistics operators and regulated financial institutions.

DigitalTrade4.EU supports the proposals goalsenhancing competitiveness, managing climate risks, and meeting consumer demandsand advocates for integrating digital tools and sustainability practices to achieve them.

The draft Implementing Regulation should remain technologically neutral and future-compatible with trusted digital credential and wallet-based interoperability, without changing the current legal role of the smart tachograph or driver card.

Our feedback to the European Commission highlights the strategic role of the European Trade Indexes Registry (EUTIR) in modernising EU antitrust procedural rules. As digital markets generate vast, complex evidence, traditional enforcement tools are no longer sufficient.

DigitalTrade4.EU proposes that the revised visa framework move beyond digital document upload and enable competent authorities to use trustworthy, machine-verifiable supporting evidence where it is available, legally appropriate and proportionate to the evidentiary purpose.

Our feedback presents targeted proposals to strengthen the draft Implementing Regulation for Qualified Trust Service Providers (QTSPs) under eIDAS 2.0. We advocate for enhanced legal certainty, global interoperability, and robust cybersecurity by embedding core principles like exclusive control over digital records, immutable metadata audit trails, and the mandatory use of globally recognised identifiers (e.g.…

Our feedback to the European Commission highlights the strategic integration of the European Trade Indexes Registry (EUTIR) as a foundational element for strengthening the European Border and Coast Guards operational capabilities. Developed by the DigitalTrade4.EU consortium, this proposal supports the modernisation of EU border management through a secure, decentralised, and interoperable digital infrastructure.

The feedback focuses on whether provenance, purpose, current status and relevant processing context remain traceable as law-enforcement data are shared, corrected, restricted and used in analytical or AI-assisted workflows. It recommends preserving a clear distinction between source information, assessments or analytical inferences, and accountable institutional decisions.

Scientific flexibility should be matched by trustworthy operational evidence: prove that the scientifically validated conditions were actually applied, allow reliable digital evidence without mandating technology, and avoid divergent evidentiary practices across Member States.

EU statistical legislation should define stable obligations, safeguards and governance principles, while rapidly evolving technical standards should be managed through a permanent cross-domain change-governance function within the European Statistical System.

The draft should follow an escalation model for metadata requirements. The first step should be to use and test the existing Annex IV quality concepts, SIMS metadata and Eurostat transmission standards. Only where implementation experience demonstrates a persistent comparability, validation or revision-traceability problem should additional mandatory structured fields be considered.

We support the Commissions objective to simplify, clarify and modernise the Brussels Ia Regulation in order to strengthen legal certainty, reduce litigation costs and administrative burdens, and improve the competitiveness of EU businesses in cross-border transactions. The Commission also explicitly identifies digitalisation as an area to be addressed in the review.

The main message of our latest submission is that the EU should move toward minimum performance standards for data centres, but binding thresholds should be based on robust, comparable and enforcement-ready evidence rather than applied mechanically to an immature dataset.

We support the Commissions intention to assess the Brexit Adjustment Reserve against effectiveness, efficiency, relevance, coherence and EU added value. Given that BAR supported customs and border controls, business and SME adjustment, sectoral support and product certification or authorisation, the evaluation should also examine whether these measures reduced the end-to-end economic frictions created by Brexit.

Shared document represents the DigitalTrade4.EU consortiums contribution to the European Commissions strategy for a simpler, seamless, and stronger Single Market. It outlines practical recommendations to accelerate the EUs green and digital transition by embedding interoperable digital tools, global standards, and ESG-linked trade finance into the core of Single Market policy.

We support the Commissions objective of strengthening Eurojusts analytical, proactive and cross-border cooperation capabilities, including improved interoperability and automated hit/no-hit information exchange with Europol, the EPPO and OLAF. The proposal correctly recognises that more efficient information exchange and digital tools are essential for serious cross-border crime investigations.

The feedback emphasizes the importance of standardized accreditation information, secure electronic evidence, clear allocation of responsibilities, and continuity of certification and oversight activities. It also encourages proportionate procedures, predictable decision-making, and common implementation guidance to reduce administrative uncertainty and improve consistency across Member States.

Our feedback supports the Commissions objective of reducing the administrative burden associated with buy-back and stabilisation reporting, while ensuring that aggregated information remains clear, reliable and usable for market supervision.