Bundesverband der Deutschen Industrie e.V.

The Federation of German Industries (BDI) supports harmonised, digital and proportionate registration and reporting under Article 44 PPWR. The implementing regulation should establish a genuine once-only approach, use a common EU-wide core dataset, distinguish clearly between the responsibilities of the different reporting entities, harmonise reporting periods and avoid requirements that depend on unavailable…

The European Commission's proposal for the Digital Omnibus is not the team bus we had hoped for, but neither is it the small car we feared. We welcome the Digital Omnibus and the European Commissions intention to streamline and simplify the digital rulebook. However, the proposals cur-rently on the table do not deliver the relief and clarity that industry hoped for.

Europes competitiveness is under severe pressure, as the Draghi and Letta reports stressed recently. The EU has fallen behind the USA and China in terms of growth, productivity and innovative strength. Europe is at risk of being left behind in key technologies, such as artificial intelligence.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The German Federation of Industries welcomes the intention of revising the RED II directive in response to the upcoming challenges and the need of system transformation to meet the set climate targets. The implementation of the defined climate policies requires increased investment, operating and production expenditures.

Executive Summary Connectivity is central to our society and economy and will only grow in importance in the future. However, Europes digital networks of today are not yet ready to address these challenges. Prior reports, such as those from Letta and Draghi, correctly describe the status quo of digital infrastruc-tures in terms of facing investment challenges, the need to stay resilient and technologically future…

Europes competitiveness is under severe pressure. The EU has fallen behind the USA and China in terms of growth, productivity and innovative strength. Against this background, German industry has very much appreciated the attention to digital infrastructures attributed by the European Commission through the White Paper How to master Europes digital infrastructure needs, the Letta Report and the Draghi Report.

With the EU Critical Raw Materials Act, the European Commission is sending an important signal to strengthen European sovereignty in the raw materials sector. However, central instruments for implementation are missing.

Russia's war of aggression against Ukraine, which violates international law, has highlighted Europe's dependence and vulnerability on Russian energy sources. But not only here: In the case of strategic minerals such as rare earths, the dependence, especially on China, is already much greater. Raw materials are being used as a weapon by Russia in particular. Europe can be blackmailed.

The European building stock is in urgent need of a renovation wave and a green and digital transformation to achieve its climate goals. The energy consumption of existing buildings must be significantly reduced through comprehensive retrofitting of the building envelope (roof, windows and façade), optimisation of building operation and comprehensive renewal of heating equipment, use of renewable energies and…

From BDI's point of view, it would be appropriate to maintain the existing requirements for new buildings until 2023 and only then provide for a review of the specifications. It is important that requirements for new buildings should only be developed further in accordance with the current state of technology and with an affordable time frame.

The BDI welcomes the opportunity to comment on the published draft. Some of the improvements of the revised ESRS are highly appreciated. However, the BDI remains concerned that the proposed amendments do not yet go far enough to meaningfully reduce the complexity and administrative burden associated with the ESRS framework in Europe.

With a European Climate Law (ECL) the EU Commission has to bring back entrepreneurial planning and investment security. To do so it needs to set realistic and feasible objectives that are in line with the holistic approach of the Green Deal.

Three things Industry wants to see in the European Climate Law With the "European Green Deal", the new European Commission has placed the issues of climate protection, ecology and sustainability at the centre of its political programme.

Artificial Intelligence (AI) is one of the most important key technologies in industry. Therefore, unbureaucratic and innovation-friendly framework conditions for the use of AI are a central prerequisite for securing the innovation capacity and competitiveness of the German and European industry. However, the rules on AI proposed by the European Commission need to be amended significantly.

The BDI welcomes the efforts of the European Commission to develop an appropriate ethical and legal framework based on the Union's values with the overriding goal to take on a global leading role in AI. A selective adaptation of the existing legal framework for AI can in-crease legal certainty for companies and foster trust in AI applica-tions.

The Federation of German Industries (BDI) is the leading organization of German industries and related service providers. She represents 40 inter-trade organizations and more than 100.000 companies with their approximately 8 million employees.

Environmental claims are playing an increasingly important role in shaping consumers' opinions and purchasing decisions. The sustainability of products and services has become a competitive factor. Products declared as "green" or sustainable are now experiencing greater growth in the EU domestic market than other products.

The BDI supports the further development of the Product Environmental Footprint (PEF) method as a voluntary procedure for evaluating the environmental impact of products. The further development should be brought in line with the ISO standards for calculation and reporting or communication. The methods for calculating (eco)toxicity need to be technically revised.

Successfully transforming the European transport sector to become climate-neutral while maintaining competitiveness poses a major challenge for European and German mobility industries and service providers. Defossilising road transport is key to this: Roads are the main mode of transport in Europe and ensure efficient and resilient logistics chains for the EU economy.

The announced “sustainable product policy legislative initiative” should be used to enable the European Union's environmental product policy to be a unified whole, i.e. without the coexistence of duplicate and contradictory sets of rules for the same products. The envisaged fundamental sustainability principles should take into account all aspects of sustainability, i.e.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

A successful, cost efficient translation of Europe´s political climate ambition into action depends on a holistic and consistent mix of policy instruments. The revision of the ETS Directive should be closely tied in with the revision of the ESR, the ETD and RED, the State Aid Guidelines (EEAG) or any possible CBAM proposal.

The ever-increasing cybersecurity threat landscape requires both regulators, industry and operators of critical infrastructures to adopt risk-adequate cybersecurity measures. Such concrete measures should be supported by a lean regulatory framework that outlines requirements and provides companies with the necessary support framework.

The ever-increasing cybersecurity threat landscape requires both regulators, industry and operators of critical infrastructures to adopt risk-adequate cybersecurity measures. Such concrete measures should be supported by a lean regulatory framework that outlines requirements and provides companies with the necessary support framework.

German industry welcomes the European Commissions aim to significantly strengthen Europes cyber-resilience and to create a level playing field for essential and important entities across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

Position of the German Industry Federation e.V. (BDI) on “Proposal for a revision of the Regulation on classification, labelling and packaging of chemicals (CLP)” Prof. Dr. Herbert Bender Referent Umwelt ,Technik und Nachhaltigkeit 1. General Statements Date: 27.03.2023 We reject entirely any unilateral implementation of new hazard classes before they had been implemented in UN-GHS.

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

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The European Innovation Act is an important initiative to strengthen Europes innovation capabilities and sustainably secure the competitiveness of the European economy. It is crucial that the Act creates better conditions for genuine innovation and provides a reliable, business-friendly framework.

BDI supports the EU Commission’s intention and objectives of promoting the use and fair sharing of data. However, there are serious concerns that with the Data Act-proposal these goals can be achieved. In our position paper, who provides general remarks and thus specific comments on the various chapters.

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BDI-Feedback BDI is convinced, that in order to make the EU data economy successful, it is necessary to increase the use and exchange of data based on legal certainty and trustworthy data infrastructures. However, in addition to making data accessible to many interested parties, the legal and economic interests of the data producers must be acknowledged equally.

The European Commission rightly places a political focus on digital infrastructure in the next legislative period. Digital infrastructure and the provided connectivity are crucial to making Germany fit for the future. Sufficient bandwidth, low latency and resilience of digital networks are key to enabling industry to leverage the potential of important future technologies.

Europe claims to be a frontrunner in climate action; a level plating field for companies is still not in sight. The longer this remains, the less there are incentives to invest in the EU due to the lack of competitiveness for large parts of industry (cf. Draghi report, 2024). Green production is not only economically viable through the availability of renewable electricity and green hydrogen.

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A connected and interoperable European Health Data Space (EHDS) is essential to unlock the potential of health data in Europe. The initiative will first and foremost benefit societies in Europe – including patients and healthcare providers – as it can play a crucial role in developing innovative technologies and treatments. Standard protocols can be replaced by personalised, data-driven insights and interventions.

No revision of the IED in the current crisis In view of the war in Ukraine, Europe must now preserve the economic strength of companies and work on quickly effective, targeted and temporary measures to cushion the crisis. German industry sees the danger that companies will face existential difficulties due to energy prices or because of a Russian export ban on energy raw materials.

BDI position paper Review of IED In the view of the BDI, there is currently no need to amend the EU directive on industrial emissions. The objectives of the directive - improving environmental quality and creating a level playing field - are being achieved.

The Federation of German Industries, the BDI, shares the opinion that there is a funding gap in sustainable investment. As outlined in the Action Plan for Financing Sustainable Growth, the capital markets can be stimulated to contribute to better reaching the EU’s climate and energy targets.

Measures and weights in road freight transport and commercial vehicles are highly relevant in terms of exploiting potential for efficiency gains and thus CO2 optimisation in the transport sector. Long trucks: In order to facilitate the use of long trucks, cross-border use of these vehicle combinations should be made easier between the EU Member States that today allow the use of these vehicles.

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BDI welcomes the European Commission's proposal for a regulation on European data governance to promote the increased reuse of data held by the public sector, support for voluntary data sharing by intermediaries, interoperability and standardization measures. In order to realize a smooth data flow EU-wide and through cross-sector value chains, a harmonized legal environment across Europe is needed.

The BDI would like to thank for the opportunity to provide feedback on the legislative framework for the governance of common European data spaces. In this respect, we refer to our statement (29 May 2020) in the public consultation process on the EU Data Strategy, in particular to our chapters A.I and A.III.

From the perspective of German industry, the simplification and de-bureaucratisation of procedures and laws in environmental law are not fundamentally at odds with high environmental and health protection standards. The aim is to better reconcile competitiveness with a high level of environmental protection.

POSITION | SUSTAINABILITY REPORTING | CSRD The new Corporate Sustainability Reporting Directive 14 July 2021 Businesses call for a global standard German industry attaches great importance to sustainability reporting. German companies have supported and continuously developed numerous international frameworks.

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

This statement represents more than 100,000 companies and 8 million employees. The German economy like the European economy is under considerable pressure. Bureaucratic hurdles, rising energy costs, stringent environmental regulations, and international trade conflicts are undermining competitiveness and hindering investments that are urgently needed for biodiversity, climate protection, and the necessary…

The EU Chips Act 2.0 offers the opportunity for a decisive turning point in the European semiconductor industry and technology policy. While the first Chips Act focused primarily on resilience and security of supply at a time of acute supply bottlenecks, Europe now needs a semiconductor policy that focuses on technological leadership, competitive strength, and indispensability in the value chain through innovative…

POSITION | EUROPEAN POLICY | EU GREEN DEAL Proposal for a Net Zero Industry Act Recommendations for the way forward May 2023 Implementing the EU´s Green Deal Industrial Plan for the Net Zero Age Europe has arrived at a critical junction in terms of its attractiveness as a business location.

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

As part of the CSS, the European Commission has proposed a large number of very ambitious measures to adapt EU chemicals legislation. The implementation of these would have far-reaching consequences for European industry. In particular, significant improvements are foreseen in the adaptation of the REACH Regulation.

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German industry advocates for the implementation of risk-adequate cybersecurity measures across all products with digital elements during the design, development and production phases as well as when and while a product is placed on the market. We therefore support the European Commissions proposal for the Cyber Resilience Act (CRA) in principle.

POSITION| TECHNICAL AFFAIRS | STANDARDISATION Regulation (EU) No. 1025/2012 on European Standardisation Input Call for Evidence 17 July 2025 Revision of Regulation (EU) No 1025/2012 The European standardisation system constitutes a fundamental pillar of the internal market and plays a decisive role in strengthening the international competitiveness of the European Union.

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

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The IIA correctly states that "CO2 standards give vehicle manufacturers the legal certainty to invest more in related R&D, to produce more zero-emission vehicles so that with increased supply and economy of scale they can become more affordable for citizens”.

For the successful implementation of the Green Deal the development of an internal hydrogen market is of vital importance. The existing regulatory framework for gas should be made fit and adaptive to integrate renewable and low-carbon gases into the system.

Stellungnahme Überarbeitung des Zollkodex der Union Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates zur Festlegung des Zollkodex der Union und zur Einrichtung der Zollbehörde der Europäischen Union sowie zur Aufhebung der Verordnung (EU) Nr.

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

Stellungnahme Überarbeitung des Zollkodex der Union Sondierung zu einer Folgenabschätzung Ares(2022)5239631 Referentenentwurf/ Regierungsentwurf Gesetz zur Modernisierung der Netzentgeltstruktur Bundesverband der Deutschen Industrie e.V. Stand: 14. September 2022 Inhaltsverzeichnis Einleitende Anmerkungen ..............................................................

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

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The aviation industry and the air transport sector ensure the mobility of passengers and goods, safeguard both civil and military technological leadership, and thereby substantially contribute to climate protection, security, and the strategic sovereignty of the European Union. As a key strategic industry, aviation drives cross-sector innovation, creates high-quality jobs, and generates sustainable value.

To stay ahead in the global race for best climate and energy technology solutions, companies need a clear, reliable fit-for-55 implementation plan committing to Europe as an attractive business, investment and innovation location.

The “ReFuelEU Aviation” initiative by the EU Commission sends a positive signal for the sustained introduction and roll-out of sustainable aviation fuels (SAF) into the market in the pursuit of reducing CO2-emissions in aviation. In order to reach the ambitious CO2-emission reduction targets for the whole transport sector, the use of carbon neutral fuels (e.g.

Regulation (EC) No 1013/2006 on shipments of waste (VVA) is one of the key building blocks for the successful use of secondary raw materials and thus for the substitution of primary materials. Only if reliable, enforceable and practical rules are in place for companies to transport and trade waste for the production of secondary raw materials can they be used throughout the whole area in often global value-added…

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Federation of German Industry German industry strongly supports the achievement of the objective of good water status according to the Water Framework Directive and is prepared to continue to make a major contribution here, also within the framework of the polluter pays principle.

The Bundesverband der deutschen Industrie e.V. (BDI) participates in this consultation with a list of proposals for reporting obligations in EU law that should be simplified or removed (paper attached). This list is a joint compilation of the four umbrella associations of German industry: BDI, BDA, ZDH and DIHK.

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BDI welcomes the initiative of the European Commission to develop the EU Quantum Act as an initiative, facilitating the implementation of the Quantum Strategy of the EU. BDI welcomes the suggested focus on research and innovation, industrialisation and supply chain resilience, and supports the focal role played by industrialisation activities.

The automotive industry and its suppliers are of strategic importance for Germany and Europe as industrial locations. The industry, which includes many small and medium-sized enterprises and family businesses, faces enormous challenges due to the dual transformation toward climate neutrality and digitalization, geopolitical risks, challenging business conditions and fierce international competition.

Its important that the EU places competitiveness at the centre of its political reform agenda. The proposals for the Data and AI Omnibuses, the Regulation to establish EU Business Wallets, the Cybersecurity Package and the Digital Networks Act underline that the European Commission recognises in principle the necessity to cut unnecessary complexity, simplify regulatory requirements, and enhance coherence across the…

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for essential and important entities across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

German industry welcomes the European Commission’s aim to significantly strengthen Europe's cyber-resilience and to create a level playing field for operators of essential services (OES) across the European Union. Cyber and IT security are the basis for a long-term secure digital transformation of the state, economy and society.

German industry welcomes the European Commissions proposal for the establishment of EU Business Wallets (EBW). The introduction of EU Business Wallets will make it much easier for companies to interact with public administrations across Member States. It has the potential to significantly reduce bureaucratic costs and can act as an anchor of trust between companies and between companies and public authorities.

Reducing the bureaucratic burden and streamlining the EUs rulebook have the potential to unleash Europes innovation potential, and thereby, enhancing the EUs long-term competitiveness. Since businesses have on average 200 contacts with the public administration per year and have to fulfil an ever-increasing amount of reporting obligations not least due to EU legislation an EU Business Wallet as part of a…

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Harnessing the potential of the LULUCF Regulation will be essential for achieving the goals of the EGD. With the climate neutrality target (by 2050) in mind, the ETS should be geared towards immediately incentivising also negative emissions (“carbon removal solutions”). In its projections the EU integrated negative emissions before 2050.

In principle, the BDI welcomes the European Commission’s objective of combating late payment in commercial transactions and unduly long payment periods. A timely payment culture is of enormous importance for businesses in the German industry. It is essential for trust-based cooperation between companies and/or state actors, as well as functioning supply chains.

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The competitiveness of European industry and the simultaneous maintenance of the highest level of safety and protection can only be maintained through legislation that is technology-neutral and open. The BDI expressly welcomes the alignment of the proposal for a Regulation on Machinery Products with the New Legislative Framework.

BDI Opinion on the EU Space Act (COM(2025) 335) The Federation of German Industries (BDI) is the umbrella organisation of German industry and industry-related service providers. 39 interbranch organisations, over 100.000 companies with around 8 million employees and 15 regional representations make it the voice of the German industry. I.

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The BDI supports the European Commission’s initiative to promote potentially dual-use technologies more effectively. It is a good step to strengthen synergies between civil and non-civil research. The aim must be to generate and strengthen the spill-over effects of defence and dual-use research for the civilian domain and, on the other hand, those from civil research for defence.

Filed in German · English published by the European Commission

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The Federation of German Industries (BDI) is grateful for the opportunity to comment on the draft delegated act. The BDI welcomes the European Commission’s objective of including certain non-hazardous waste in the Green List of the EU Waste Shipment Regulation in order to facilitate and speed up its transport within the EU for recovery purposes.

Filed in German · English published by the European Commission

Industry is committed to ambitious but technically and economically realistic targets. The overall trajectory proposed by the European Commission for all vehicle categories (-45 % from 1 January 2030, -65 % from 1 January 2035 and -90 % from 1 January 2040) is very ambitious.

Filed in German · English published by the European Commission

Federation of German Industries (BDI) There is no urgent need for action to amend the existing and very successful EU Ambient Air Quality Directives now. At the same time, the EU is pursuing a large number of legislative projects that already contribute directly and indirectly to improving air quality.

Federation of German Industries e. V.: In BDI's view, a revision of the European ambient air quality directives is not necessary at present. 1. Preserving Europe as a business location: European industry is currently undergoing structural change and also has to cope with the effects of the pandemic. Corona and restrictions on business are leaving deep scars on employment and prosperity in the European member states.

The Federation of German Industries (BDI) welcomes a uniform and horizontal regulation of the use of Common Specifications (CS) but expresses serious concerns about the European Commissions proposal. While the initiative aims to counteract delays in the availability of harmonised European standards (hENs), BDI warns that the systematic use of CS risks undermining the integrity, efficiency, and global relevance of…

Executive Summary Data centres form the backbone of the digital transformation and are a critical enabler of Europes competitiveness, innovation capacity, and digital sovereignty. They underpin the storage, pro-cessing, and provision of data in an increasingly interconnected and data-driven world.

The German Industry is under significant competitive pressure. Investment decisions are being weighed very carefully, and there is now a clear need for strong, positive signals from policymakers. The forthcoming EU Commissions tax omnibus package presents a valuable opportunity to deliver meaningful relief: reducing administrative burdens, simplifying tax obligations, and eliminating redundant reporting…

The Federation of German Industries (BDI) welcomes the efforts of the European Commission for a transparent and harmonised calculation of transport-related greenhouse gas emissions. To provide incentives for climate protection in passenger and freight transport and effectively reflect emissions of logistics chains, a technology-neutral design of the regulatory approach is required across all modes of transport and…

The Federation of German Industries (BDI) supports the Commission's goals of creating a level playing field for GHG calculations in the transport (freight and passenger services) and logistics sector with a uniform framework for calculating GHG emissions, while facilitating behavioural changes by users.

The BDI expressly supports the Commission’s objective of improving air quality in the European Union. The continuous updating of the vehicle pollutant standard with the current Euro 6/VI has also made an important contribution to this. A moderate and harmonised proposal for Euro 7/VII, taking into account environmental protection and climate protection alike, would therefore be an appropriate approach.

Filed in German · English published by the European Commission

Combined transport (KV) is the rail segment with the highest growth potential. Therefore, CT has an important role to play in strengthening intermodality in Europe and in catching up rail. The privileges existing or possible for transport today are crucial and fundamental incentives for the choice of transport modes and should therefore be maintained and expanded.

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Digital development creates fundamental changes in many markets. A central role is played by digital platforms, a powerful dominating the digital economy have become business model. Thus, six of the top ten companies in the world and seven of the ten höchstbewerteten start-ups successfully with this model in the world.

Filed in German · English published by the European Commission

The Federation of German Industries (BDI) welcomes the initiative for a military mobility package as a key component of European security and defense policy. Strong European defense capabilities require resilient infrastructure, efficient logistics and reliable supply chains.

Filed in German · English published by the European Commission

The BDI welcomes the European Commission's proposal on VAT in the Digital Age (VIDA) to mod-ernise VAT reporting obligations by introducing Digital Reporting Requirements (DRR) by 2028. According to the EU Commission this is an important step to overcome the fragmentation of the European VAT system and to complete the single market by adequately combating fraud using the possibilities of digitalisation.

BDI, Federation of German Industry, supports the intention to make the prioritization processes, the setting of quality standards and thresholds more transparent and efficient and to align them with other principles in order to make the best use of available expertise and data.

European Standardisation System internationally competitive and appreciated by industry: The European Standardisation System (ESS) is internationally competitive and appreciated by industry. Standardisation is a tried and tested tool for relieving the legislator and promotes practical, lean and thus innovation-friendly regulation.

BDI comments to the European Commission Inception Impact Assessment related to the update of concentration limit values of persistent organic pollutants in waste as per the Annex IV and V of the EU Regulation 2019/1021 on POPs The technical feasibility and relevance of enforcing more stringent limit values and the efforts required to analyse waste streams prior to recycling in waste processing plants should be…

Industry supports the European Mobility Strategy’s goal of shifting to rail. At the same time, the European rail network is significantly overloaded in many sections and is used beyond its capacity limits: Overall, the demand for freight lines already exceeds the available nominal capacity. The heavily congested lines, e.g.

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Executive Summary BDI supports the overall direction of the Cloud and AI Development Act (CADA). Europe urgently needs to expand its cloud, AI and data-centre capabilities, reduce critical technological dependencies, and create better conditions for investments and innovations.

The BDI supports the Commission in effectively addressing competition-distorting third country subsidies. In its opinion (Annex) to the White Paper (COM (2020) 253 final), the BDI proposed, inter alia, complementary measures.

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The BDI welcomes the overall objective of the Implementing Regulation to improve data exchange in rail freight and to increase its interoperability. However, as it stands, there are legal concerns and regulatory uncertainties that require a revision of the current draft with a greater involvement of the railway sector.

Filed in German · English published by the European Commission

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

German industry is committed to the objectives of the Paris Climate Protection Agreement. The extremely ambitious climate protection goals of the EU for the transport sector also apply to air transport and must be reconciled with economic efficiency, international competitiveness, social concerns, and international principles.

As the voice of German industry, BDI highly appreciates the opportunity to provide feedback on the European Commission’s proposal for a Directive on the Resilience of Critical Entities (COM(2020) 829). German industry welcomes the European Commission’s aim to strengthen the resilience of critical entities in the Member States and to further level the playing field for critical entities across the European Union.

We would like to thank the European Commission for the opportunity to provide input in the context of the Call for Evidence on Directive 2011/16/EU on administrative cooperation in the field of direct taxation (DAC), as well as its subsequent amendments. The proposed DAC recast offers numerous opportunities to improve the efficiency of data reporting.

The Federation of German Industries (BDI) welcomes the intention of the European Commission to further harmonize the European insolvency law as there are still considerable differences in the legal systems of the Members States in terms of its constitution and handling. Please find attached our detailled response to the roadmap on enhancing the convergence of insolvency laws.

German industry welcomes the Chips Act as an important step to strengthen Europe as a global player in chip production. Semiconductors are essential for the future of European industry and the successful ecological and digital transformation of Europe as a business location. Becoming more independent in chip design and production is an integral part of a resilience-oriented European industrial policy.

Dear Sir or Madam, Please find attached feedback by the Federation of German Industries (BDI) on the European Commission's proposal for a regulation on the protection of the Union and its Member States from economic coercion by third countries [COM(2021)775]. We thank the Commission for both the sincere work it has put into drafting this proposal as well as for extending the deadline for feedback by two weeks.

Currently taxation is subject to a special legislative procedure, meaning that unanimity in the Council is required for the adoption of a directive. The European competence for directives in tax matters is not only associated with amendments of existing taxes, but also with the introduction of completely new or the abolition of existing types of taxes.

The Foreign Subsidies Regulation is an essential tool to prevent distortions of competition in the internal market. However, two years after the entry into force, many questions remain open and the bureaucratic burden on companies to process FSR reporting obligations internally is enormous. Any clear guidance on the application of the Regulation is therefore welcome.

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To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

For German industry, the standard for the exchange of electronic invoices (EDI and in particular EDIFACT in the automotive industry), which has been proven for decades, must be maintained with the introduction of the European reporting system.

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To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

Access to a free and fair market is important for the BDI and the export-oriented German industry. We therefore look forward to the European Commission’s initiative to review the existing regulatory framework on market access conditions in inland navigation. In this context, all hazard charges must be reduced to the same extent on national and international waterways in the EU.

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