industriAll European Trade Union

Resoins Ref. Ares(2025)9519040 - 05/11/2025 IndustriAll Europe’s reaction to the European Commission’s call for evidence for the impact assessment on the Circular Economy Act Brussels, 16/10/2025 Disclaimer: The below reaction is a preliminary opinion on the upcoming Commission Proposal on the Circular Economy Act, which is based on positions previously adopted by industriAll Europe’s Executive Committee.

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

IndustriAll Europe welcomes the Industrial Decarbonisation Accelerator Act and its objective to foster competitive, sustainable and resilient decarbonisation in energy-intensive industries in the EU. The European Commission must send a clear message that European industrys competitiveness and resilience can only be achieved by upholding Europes strong social model, nurturing a highly qualified and motivated…

IndustriAll European Trade Union welcomes this consultation process on the revision of the legislative framework for public procurement. Our feedback is in the attached document. Please note that this document has been prepared to answer the public consultation and reflects the preliminary analysis of industriAll Europes secretariat and industriAll Europe affiliates.

Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europes industrial workforce at European Level. Trade unions have long been calling for a stronger EU strategy on raw materials to move towards greater independence through the sustainable exploitation of their own resources, as well as security of supply through a joint and fair…

IndustriAll European Trade Union’s response to the call for evidence on the forthcoming EU Critical Raw Materials Act Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level.

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

IndustriAll European Trade Unions full position will be uploaded as annex to this feed-back. The proposal for a new pharmaceutical legislation in Europe broadly addresses relevant issues to ensure a safe and supportive supply for patients.

IndustriAll Europe welcomes the European Commission’s draft regulation on AI, as it is the first proposal of its kind and will set new standards when it comes to addressing the challenges of high-end technology and human rights implications. We appreciate the opportunity to provide feedback on the draft regulation.

IndustriAll European Trade Union (IAE) is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 200 national trade union affiliates in 39 European countries.

In principle, iAE is in favour of introducing an EU legislation to accelerate the uptake of zero-emission vehicles (ZEVs) in company fleets in order to achieve the EU's CO2 reduction targets provided that the legislation is crafted to bolster the European automotive industry and its supply chain while generating high-quality employment.

[See industriAll Europe's complete feedback in attachment] Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level.

For IndustriAll Europe, increasing the EU climate ambition in a context of global asymmetrical climate policies requires – among other instruments - a Carbon Border Adjustment Mechanism (CBAM) to include imports into the EU Emission Trading System and to exempt exports from the impact of such a scheme.

To limit the risk of delocalisation of manufacturing activities downstream the value chain, CBAM should also apply to additional intermediate and finished products. A CBAM that would lead to offshore assembly or finishing industrial activities would be an unacceptable threat to employment in industries and would be in conflict with the EU industrial strategy objectives such as the open strategic autonomy.

IndustriAll European Trade Union is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 180 national trade union affiliates in 38 European countries.

On behalf of industriAll European Trade Union, representing 7 million workers in the mining, manufacturing and energy sectors, we would like to thank the European Commission for the opportunity to give our opinion on the revision of the Chip Act. Please find our position in the attached document.

You'll find attached the position paper adopted by IndustriAll Europe's Executive Committee. The paper covers the EU Green Deal Industrial Plan in general but it also contains a specific annex dealing with the Net Zero Industry Act.

IndustriAll European Trade Union is a federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities. We speak for 7 million working men and women united within 180 national trade union affiliates in 38 European countries.

IndustriAll Europe represents trade unions organising over 7 million workers across Europes manufacturing, mining and energy sectors, bringing together more than 200 affiliates in 39 countries. IndustriAll Europe welcomes the opportunity to provide feedback on the draft implementing regulation for the Digital Product Passport (DPP), a key instrument for operationalising the Ecodesign for Sustainable Products…

Representing 7 million manufacturing, mining and energy sector workers across Europe, industriAll European Trade Union is the voice of Europe’s industrial workforce at European Level. IndustriAll Europe is an organisation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and…

IndustriAll Europe welcomes the proposed Regulation on machinery products and strongly supports the scope and destination route. We also welcome the linkage to the draft Regulation on AI. As the European federation of independent and democratic trade unions representing manual and non-manual workers in the metal, chemical, energy, mining, textile, clothing and footwear sectors and related industries and activities…

Our observation relates to the proposed methodology of the Impact Assessment. The Option 2 being considered (p.3) mixes in its bullet point on changes to "the essential health and safety requirements" two very different issues: (1) the possibility to submit documentation in digital format, which is easy to discuss and raises no specific issue; and (2) the inclusion of developments in "emerging digital technologies"…

Representing 6 million workers in the manufacturing, mining and energy sectors, industriAll Europe stresses that Good quality jobs are not a luxurythey are the backbone of a fair and resilient European economy. For too long, competitiveness has been wrongly pursued through wage suppression and job degradation.

In the uploaded document, IndustriAll Europe Secretariat presents its preliminary analysis of the the proposed Just Transition Mechanism. Whereas the initiative will help industrial regions to better manage their transition to a low-emission economy, a series of questions and concerns remain and the proposed initiative could be improved in many ways.

The next VET strategy should: 1. Ensure full involvement of trade unions (and social partners, more broadly) in all skills-related initiatives/strategies designed at company, local, sectoral and national levels 2.

As mentioned in our answer to the consultation and in the Policy Brief attached, industriAll European trade union supports legislative measures providing detailed principles (option 3), establishing a “single European regulator of digital on-line services”.

IndustriAll Europe welcomes the Commission's initiative to develop a delegated act under the Ecodesign for Sustainable Products Regulation (ESPR) for iron and steel products. The delegated act should contribute not only to decarbonisation and circularity, but also to strengthening European industrial capacity and ensuring a Just Transition for workers.

Labour migration must not lead to exploitation Social Progress with EU-wide Fair Labour Mobility counselling structure IndustriAll European Trade Union very much welcome the Commissions initiative for a Fair Labour Mobility Package. We think this proposal will be very important to address the shortcomings in the internal market that undermine workers rights.

The industriAll European Trade Union aims to develop common views and positions with its affiliates in order to build up efficient strategies to defend the economic, social and cultural interests of the workers in these industries on a basis of solidarity, mutual respect and common principles.

Competition policies have a significant impact on employment levels, wages and working conditions. Adverse consequences may arise whenever a narrow assessment of the consumer interest and strict economic efficiency tests are insufficiently balanced with social considerations. Merger controls focus narrowly on economic efficiency and consumer welfare and leave little room for the promotion of social dialogue.