Eurochambres

The Digital Omnibus initiative is a critical opportunity to simplify the EU's complex digital regulatory framework, fostering a more innovation-friendly, competitive, and harmonised digital single market. Eurochambres welcomes the Commissions objectives to simplify the data acquis and reduce consent fatigue. Additionally, the implementation of the AI Act should follow a balanced and SME-friendly approach.

Secure and affordable access to raw materials is critical for the competitiveness of European businesses and for advancing the green and digital transitions. Yet, Europes continued dependence on external suppliers remains a strategic vulnerability.

The competitiveness of Europes industry is under considerable pressure from unfair competition, distortive subsidies and strategic dependencies, alongside structural challenges closer to home, including high energy costs, a fragmented single market and excessive regulatory burdens.

Europe's industrial decarbonisation efforts must not come at the expense of its global competitiveness. European businesses, particularly SMEs, continue to face major obstacles that undermine both their decarbonisation efforts and competitiveness from complex permitting procedures to funding barriers and an uneven global playing field.

Eurochambres generally welcomes the European Commission's proposal for a packaging and packaging waste regulation, which aims to advance a circular economy. This regulation offers an important opportunity to reduce waste, minimize environmental degradation, and lower processing and transportation costs.

Eurochambres welcomes the Commissions initiative to review the climate and environmental delegated acts of the EU Taxonomy. European businesses continue to struggle with the complex and burdensome requirements of the framework, particularly the Do No Significant Harm (DNSH) elements of the technical screening criteria.

EUROCHAMBRES, the Association of European Chambers of Commerce and Industry welcome the possibility to comment on the European Climate Law, however we must also underline the time and resource constraint our members currently face due to the Corona pandemic.

Brussels, 23 May 2022 Feedback Ref. Ares(2022)3881017 - 23/05/2022 Eurochambres feedback on the Proposal for a Corporate Sustainability Due Diligence Directive Eurochambres believes that sustainability is at the heart of businesses activities and is key to ensuring long-term economic growth.

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

The Commissions proposal to revise the EU Emissions Trading System (ETS) comes at a critical time when European businesses face high energy prices, regulatory burdens, and an uneven global playing field. Eurochambres therefore welcomes the revised ETS trajectory, the extension of free allocation and the stronger financing framework for decarbonisation.

Eurochambres believes that the existing EU consumer protection framework, when properly enforced, provides sufficient safeguards for digital markets and that priority should be given to implementing and evaluating current legislation rather than introducing a new Digital Fairness Act at this stage.

Brussels, 08 September 2026 INPUT Ref. Ares(2026)8548586 - 08/09/2026 Eurochambres input to the call for evidence on the Education Package 2040 Roadmap Eurochambres welcomes the European Commission's initiative to develop a longterm vision for quality education, focusing on reversing the decline in basic skills, strengthening the attractiveness of the teaching profession and modernising education in the digital age.

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

Brussels, 08 September 2026 INPUT Ref. Ares(2026)8548537 - 08/09/2026 Eurochambres input to the call for evidence on the Education Package 2040 Roadmap Eurochambres welcomes the European Commission's initiative to develop a longterm vision for quality education, focusing on reversing the decline in basic skills, strengthening the attractiveness of the teaching profession and modernising education in the digital age.

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

Brussels, 08 September 2026 INPUT Ref. Ares(2026)8548895 - 08/09/2026 Eurochambres input to the call for evidence on the Education Package 2040 Roadmap Eurochambres welcomes the European Commission's initiative to develop a longterm vision for quality education, focusing on reversing the decline in basic skills, strengthening the attractiveness of the teaching profession and modernising education in the digital age.

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

We welcome the aim of the Data Act initiative of creating a fairer and more competitive data economy in Europe and consider the creation of a European data space to be an important step towards strengthening the competitiveness and innovative capacity of European companies in international competition.

Eurochambres supports the objectives of the Single-Use Plastics Directive (SUPD) and has observed an increase in public awareness and a shift towards more sustainable alternatives. At the same time, the implementation of the directive has revealed several practical challenges for businesses, especially SMEs.

The European Commissions proposal for the 2040 climate target prioritises ambition over economic reality, placing additional strain on businesses already struggling with high energy costs, regulatory burdens and an uneven global playing field. Eurochambres calls for a pragmatic and business-friendly approach that aligns climate ambition with industrial competitiveness.

The Environmental Omnibus represents a positive step towards reducing administrative burdens stemming from EU environmental legislation. Eurochambres welcomes that several core demands of the chamber network are reflected in the simplification package, including the deletion of the SCIP database and measures to streamline permitting procedures.

Eurochambres supports the objective of delivering a secure and interoperable Digital Product Passport (DPP) Registry, representing a key pillar in the successful implementation of the DPP and in fostering circularity more broadly. However, its success will depend on whether companies of all sizes, especially SMEs, can use it in practice without disproportionate administrative or technical effort.

Eurochambres continues to raise concerns regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR), as smaller businesses in particular are struggling with the regulations complex requirements and the absence of key secondary legislation.

Eurochambres input for the Revision of the EIT Regulation and of the Strategic Innovation Agenda 1. Innovation ecosystems, knowledge triangle and market impact Eurochambres broadly agrees with the challenges identified. Europe needs to get better at turning its strong research and knowledge base into innovation, market uptake and economic value.

Eurochambres welcomes the Commissions initiative to assess the coherence, effectiveness, and administrative impact of EU digital legislation. European businesses, particularly SMEs, increasingly face overlapping and complex compliance obligations stemming from various digital regulatory acts.

EUROCHAMBRES, the Association of European Chambers of Commerce and Industry representing over 20 million enterprises in Europe, acknowledges the potential of using open data to innovate and welcomes the New Open Data Directive. For the implementing act on a list of High-Value Datasets we suggest that - The underlying data of High-Value Datasets must be of high quality.

Eurochambres continues to raise concerns regarding the implementation of the Packaging and Packaging Waste Regulation (PPWR), as smaller businesses in particular are struggling with the regulations complex requirements and the absence of key secondary legislation.

Access to secure and affordable energy is vital for Europes competitiveness and economic resilience. The 2022/23 energy crisis demonstrated the severe impact of volatile and high energy prices on all European businesses, especially SMEs. The revision of the EU energy security framework is an opportunity to build a more resilient and diversified energy system while ensuring access to energy at competitive prices.

Brussels 08/2025 Position Ref. Ares(2025)6776923 - 21/08/2025 Eurochambres position on IV Omnibus Simplification package Eurochambres supports the European Commission's simplification efforts and the goal of reducing administrative burdens on EU businesses. At the same time, the fourth Omnibus Simplification package presented on 21 May has a limited impact on the broader business community.

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

VET systems must become more responsive, attractive and closely aligned with labour-market needs. The Strategy should prioritise stronger foundations in basic and digital skills, simplified and better funded mobility, expanded work-based and dual learning, faster curriculum updates, higher and lifelong VET pathways, and innovation and entrepreneurship in close partnership with employers.

Brussels 08/2025 Position Ref. Ares(2025)6776884 - 21/08/2025 Eurochambres position on IV Omnibus Simplification package Eurochambres supports the European Commission's simplification efforts and the goal of reducing administrative burdens on EU businesses. At the same time, the fourth Omnibus Simplification package presented on 21 May has a limited impact on the broader business community.

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

Eurochambres welcomes the opportunity to provide feedback on the draft implementing act under the Ecodesign for Sustainable Products Regulation (ESPR), concerning the disclosure of information on unsold consumer products. We appreciate that demands, such as the establishment of a harmonised reporting format and a deferred application date, have been addressed.

The 2025 Digital Decade Policy Programme (DDPP) report reveals critical shortcomings in achieving the targets on digitalisation essential for European competitiveness. While certain indicatorssuch as e-health services and basic 5G coverageshow comparatively high achievement levels, key foundational digital technologies including AI adoption, cloud services, data analytics, ICT specialists, and basic digital skills…

Efficient cross-border coordination, reducing logistical bottlenecks, and maximising the benefits of EU-funded transport corridors would facilitate the harmonisation of common defence and security mobility priorities across member states.

The 2023 European Year of Skills is an excellent opportunity to work with EU level instruments to respond to labour market needs, such as mobility schemes, upgrading Vocational Educational Training (VET) and forecasting tools.

Eurochambres’ input for the “Reskilling and upskilling evaluation of individual learning accounts” call for evidence Increasing participation in adult learning remains a major challenge. With participation at around 40%, the EU remains far from its target of at least 60% of adults participating in training every year by 2030.

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

EUROCHAMBRES believes that the principle of unanimity in the field of taxation should be maintained, as it is there to preserve all EU Member States’ interests. A change to qualified voting could lead to countries being voted out where they do not share the same view as other Member States.

We welcome the European Partnership for Innovative SMEs under Horizon Europe, as an important initiative aimed at supporting the most innovative SMEs. To ensure the success of the “European Partnership for Innovative SMEs” we consider - easy accessibility for SMEs, - close alignment with other instruments and - a true European added value pivotal.

Traineeships play a crucial role, not only in providing practical experience to young people but also in fostering the skills required to maintain competitiveness within the business sector. While protecting trainees is imperative, it is crucial to strike a balance with the demands placed on businesses.