Japan Business Council in Europe

The Japan Business Council in Europe (JBCE) welcomes the European Commissions initiative to establish harmonised requirements for producer registration and reporting under Article 44 of the Packaging and Packaging Waste Regulation (PPWR). A harmonised framework has the potential to reduce administrative burdens, improve consistency across Member States and strengthen the functioning of the EU Single Market.

JBCE urges the co-legislators to prioritise four areas in finalising the Digital Omnibus. First, JBCE considers that the proposed amendments to the trade secret safeguards under the Data Act remain insufficient. Trade secret protection must be recognised as a fully independent ground for refusing data access requests, without imposing mandatory notification obligations on data holders.

JBCE is a leading European organisation based in Brussels representing the interests of 115 multinational companies of Japanese parentage active in Europe. Our members have a strong European footprint and operate across multiple Member States.

This paper outlines recommendations from Japan Business Council in Europe (JBCE) on behalf of Japanese businesses operating in the EU on key digital legislation, focusing on the Data Act, cybersecurity frameworks such as the Cyber Resilience Act (CRA) and the Directive on measures for a high common level of cybersecurity across the Union (NIS2), and the Artificial Intelligence (AI) Act.

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) and the Japanese associations in Japan welcomes the opportunity to contribute to the Call for Evidence on the Circular Economy Act.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to provide its feedback on the revision of the Public Procurement directives as part of the Call for Evidence launched on 3 November 2025. Indeed, while acknowledging the strategic imperative of the European Union (EU) to secure its own competitiveness and economic security agenda, JBCE has been actively promoting since Spring 2025 a Made with…

The Japan Business Council in Europe (JBCE) welcomes the opportunity to comment on the European Commissions proposal for an Industrial Accelerator Act (IAA) presented on 4 March 2026. The IAA proposal aims to boost the demand and manufacture of clean technologies in the Union, driving the creation of lead markets.

Being a cross-sector association with member companies operating in different industries and stages in the supply chain, JBCE welcomes the opportunity to contribute to the call for feedback on the proposal for a Packaging and Packaging Waste Regulation (PPWR). JBCE welcomes and supports the overall aim of the European Commission to strive for more sustainable packaging and subsequently reducing its waste.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion in support of the review of the EU Taxonomy Environmental Delegated Act and Climate Delegated Act. Having previously submitted our opinions on the Do No Significant Harm (DNSH) criteria during the EU Taxonomy Stakeholder consultation in 2023 and 2025 , we are eager to continue supporting the European Commissions efforts for…

The Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion regarding the Do No Significant Harm (DNSH) principle. We submitted our initial opinion on DNSH during the EU Taxonomy Stakeholder consultation in 2023. JBCE very much welcomes the adoption of the Delegated Act on 4th July 2025, which makes the DNSH requirement (d) align with the requirement of the RoHS Directive.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to comment on the European Commissions proposed Delegated Regulation amending Delegated Regulation (EU) 2023/2772 as regards the simplification of certain sustainability reporting standards (ESRS) .

JBCE welcomes the European Commission’s attempt to set a horizontal Regulation for trustworthy AI with the AI Act. In this context, JBCE asks for a clear definition of AI to ensure an effective and harmonized interpretation and enforcement of the Act.

JBCE welcomes the European Commission’s efforts to establish a common European approach to AI. This will help the EU’s AI market reach scale and avoid legal uncertainty or fragmentation of multiple policies among EU Member States, through protecting our safety, consumer rights and fundamental rights when we use AI applications.

JBCE is pleased to contribute by actively taking part in public consultations and hearings. The measures should be functional and effective to achieve the ambitious goal. For that we suggest following points: •Before a new system is introduced, socio impact assessments should be always carried out to find out the most efficient way and figure out whether the benefits excess the burden in the whole society.

JBCE welcomes the opportunity to share our position on the Corporate Sustainability Due Diligence Directive, following the proposal published by the European Commission on 23 February, 2022. JBCE support the Commission’s ambition to enhance due diligence in corporate management processes and hence prevent adverse impacts related to environmental and human rights factors.

The Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding the Commission’s initiative on Sustainable Corporate Governance, with the proposal expected in Q1 2021. JBCE appreciates this timely proposal as responsible corporate behaviour throughout the supply chain is becoming an increasingly salient topic.

Japan Business Council in Europe (JBCE) appreciates the opportunity to provide comments on the Commission proposal for the regulation of Carbon Removal Certification. JBCE believes the proposed regulation is an important step in stimulating the markets for carbon removals and achieving the goal of carbon neutrality. Nevertheless, we would like to feedback as detailed in the two points below.

As a cross-sector association with member companies operating in different industries and stages of the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to contribute to the consultation regarding the review of the EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve. Our key messages are as following: 1.

Japan Business Council in Europe (JBCE), a cross-sector association representing member companies from various industries and supply chain stages, welcoms the oppotunity to provide its feedback on the European Commission's proposal for a Green Claims Directive. JBCE supports truthfulness and transparency in environmental information to protect consumers.

The Japan Business Council in Europe (JBCE) welcomes this opportunity to provide feedback on the Commission's proposal for the Ecodesign for Sustainable Products Regulation (ESPR). JBCE is a cross-sectoral association of companies with Japanese parentage. We support the EU’s ambition to make sustainable products the norm in the EU and we firmly believe JBCE can contribute to this through the ESPR.

Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding the Commission’s Sustainable Products Initiative. JBCE supports the EU’s target to achieve climate neutrality by 2050 and JBCE has committed to the European Commission’s objective to ensure that products placed on the market contribute to the circular economy transition.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to present its views on the European Commission's proposal for a European Biotech Act. JBCE supports the proposal's ambitious and innovation-oriented framework for the competitiveness of the EU's biomanufacturing sector, in particular its commitment to rewarding innovation, as well as its measures to accelerate and simplify clinical trials, foster…

The Japan Business Council in Europe (JBCE) would like to share its concerns regarding the proposed extension of the Carbon Border Adjustment Mechanisms (CBAM) scope for three reasons: (i) lack of proportionality, (ii) difficulty in complying on the basis of actual emission data, and (iii) insufficient alternative measures to enable compliance.

Being a cross-sector association with member companies operating in different industries and stages in the supply chain, JBCE welcomes the opportunity to submit its views on the feedback for the revision of EU legislation on hazard classification, labelling and packaging of chemicals. JBCE supports the risk management approach based on chemical substances and mixtures.

Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of CLP. JBCE supports the EU’s aims at ensuring both a well-functioning single market for chemicals and a high level of protection of human health and of the environment.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion in support of the review of the EU Taxonomy Environmental Delegated Act and Climate Delegated Act. Having previously submitted our opinions on the Do No Significant Harm (DNSH) criteria during the EU Taxonomy Stakeholder consultation in 2023 and 2025 , we are eager to continue supporting the European Commissions efforts for…

The Japan Business Council in Europe (JBCE) would like to welcome the Data Act proposed by the European Commission to promote fairness in the use of and access to data. We believe that the use of data among various stakeholders is essential to strengthen the competitiveness of companies and to create a fair society where everyone has the opportunity to innovate.

As a cross-sector association representing over 110 multinational companies of Japanese parentage active in Europe, JBCE welcomes the opportunity to provide feedback on the European Commissions evaluation of the Single-Use Plastics Directive (SUPD). We support the Commissions efforts to reduce marine litter and enhance resource efficiency while ensuring a predictable and science-based regulatory framework.

Please find below the key messages from the Japan Business Council in Europe (JBCE) . (1) Simplified implementation of the EUDR is essential to ensure feasibility and effectiveness across industries. (2) Greater flexibility should be introduced to allow the submission of single due diligence statements covering multiple shipments/batches from a variety of sources.

28 February 2021 JBCE’s Feedback on the Proposal for a European Battery Regulation As a cross-sector association with member companies operating in different industries and at different stages of the supply chain, JBCE welcome the opportunity to contribute to the public consultation. JBCE believes that the new battery regulation proposal will drive sustainable battery supply chain including recycling process.

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

General Comments The Japan Business Council in Europe (JBCE) supports the European Commission's efforts to create a trusted and interoperable data sharing environment in the EU and welcomes the general idea of Data Governance Act (DGA) which sets ambitious goals for creating trust in data intermediaries and strengthens data-sharing mechanisms across the EU.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its opinion in support of the European Commissions proposals for the simplification of administrative burden in environmental legislation . JBCE appreciates the European Commissions recent initiatives to streamline EU legislation, enhance implementation efficiency, and reduce unnecessary administrative burdens for businesses.

JBCE represents the interests of about 90 multinational companies of Japanese parentage active in Europe. Our members operate across a wide range of sectors, and include companies that are active in developing, producing and marketing refrigeration, air conditioning and heat pump (RACHP) equipment.

The Japan Business Council in Europe (JBCE) supports the European Commission’s proposal to enhance companies’ disclosure of corporate sustainability information, encompassing not only the environmental aspect, but also social and governance aspects. JBCE recognises the contribution that this legislation will make in the sustainable growth of companies.

Japan Business Council in Europe (JBCE) appreciates this opportunity to give a feedback on the inception impact assessment on the revision of the Non-Financial Reporting Directive. We would like to make comments on the following 7 points; 1. Non-financial reports (NFR) are tools, through which companies and stakeholders including investors can exchange on value-creating processes.

The Japan Business Council in Europe (JBCE) welcomes the opportunity to comment on the European Commission's proposal for the Chips Act 2.0. Japanese companies have long been integral partners in Europe's semiconductor ecosystem, contributing advanced materials, equipment and manufacturing know-how across the value chain. Against this background, JBCE expects the following three points.

Being a cross sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive , machinery, semiconductor, steel, nonferrous metal, textiles, ceramics, and glass products), Japan Business Council in Europe (JBCE) welcomes the opportunity to contribute to the Commission 's proposal regarding End of life Vehicles (ELV) revision of EU…

Japan Business Council in Europe (JBCE) welcomes the feedback opportunity regarding Inception Impact Assessment/Revision of REACH. JBCE supports the objectives of the Chemicals Strategy for Sustainability are to better protect citizens and the environment against hazardous chemicals and encourage innovation for the development of safe and sustainable alternatives.

Japanese Business Council in Europe (JBCE) welcomes the opportunity to contribute to the European Commissions consultation on the Cyber Resilience Act proposal. Attached you will find the feedback of the Japanese Business Council in Europe (JBCE) on the Cyber Resilience Act. The views in the document also reflect those of many domestic industries in Japan.

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish harmonised rules for the calculation and verification of recycled content in plastic packaging under Article 7 of the Packaging and Packaging Waste Regulation (PPWR).

The Japan Business Council in Europe (JBCE) and Japanese 4EE industrial associations (JP4EE: JEMA, JEITA, JBMIA, CIAJ) support the idea that proving and transparently demonstrating the sustainability of an entire product lifecycle using a Digital Product Passport (DPP) would benefit both consumers and users.

Please find attached our detailed submission setting out concrete observations and recommendations regarding this initiative. We broadly support the objectives pursued and welcome the opportunity for stakeholder input at this stage.

Japan Business Council in Europe (JBCE) welcomes and strongly supports the European Commissions Proposal for a Directive on common rules promoting the repair of goods. We believe that the proposal creates a proportionate framework ensuring that consumers have access to safe and high-quality repair.

JBCE welcomes the opportunity to contribute to this initiative aimed at reducing administrative burdens by 25% in the face of ever-increasing regulatory compliance. We would like to endorse the European Commissions idea of streamlining, digitizing, and optimizing reporting requirements for companies through this call for evidence.While reporting information which are vital to achieve policy objectives such as…

Japan Business Council in Europe (JBCE) welcomes the opportunity to provide our feedback on the proposal for the Revised Directive on Security of Network and Information Systems (NIS2). The proposal is very important and timely as it supports the Commission’s efforts to address new challenges in the cybersecurity threat landscape in Europe.

Proposal for a Regulation on Machinery Products JBCE's position Japan Business Council in Europe (JBCE) welcomes the proposal for the Regulation on Machinery Products, new legislative framework (NLF) and to reduce the costs of transposition with the choice of a Regulation.

We welcome the continuous work and intention of EU Commission to improve the Machinery Directive. JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the inception Impact Assessment in relation to the revision of the Machinery Directive.

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) welcome the European Commissions initiative to establish a framework for assessing third-country equivalence for recycled content under the Packaging and Packaging Waste Regulation (PPWR).

Being a cross-sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymers, automotive, machinery, semiconductors, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the discussion regarding the proposal for Chemicals…

Please find attached JBCEs position paper on the proposals for a Regulation on the digitalisation and alignment of common specifications under the Omnibus IV package. JBCE welcomes the Commissions initiative and highlights the need to more boldly embrace digitalization approaches, remove physical requirements, ensure horizontal alignment across the NLF, and prioritise international standards over EU-specific common…

As a cross-sector association with member companies operating in different industries and at different stages of the supply chain (electronics, chemicals, polymers, automotive, HVACR, machinery, semiconductors, wholesale trade, precision instruments, pharmaceuticals, steel, non-ferrous metals, textiles, ceramics and glass products), JBCE welcomes the opportunity to contribute to the draft delegated regulation1 act…

Japan Business Council in Europe (JBCE) welcomes the proposal for the Regulation on General Product Safety, which also addresses New Legislative Framework (NLF) and Market Surveillance Regulation and to reduce the costs of transposition with the choice of a Regulation.

Being a cross-sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymers, automotive, machinery, semiconductors, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the discussion regarding the proposal for Chemicals…

Being a cross-sector association with member companies operating in different industries and stages in the supply chain (electronics, chemicals, polymers, automotive, HVACR, machinery, semiconductors, wholesale trade, precision instruments, pharmaceuticals, steel, non-ferrous metals, textiles, ceramics and glass products), JBCE welcomes the opportunity to contribute to the discussion regarding the amendment of RoHS…

Japan Business Council in Europe (JBCE) is a cross sector organisation representing the interests of more than 90 multinational companies of Japanese parentage active in Europe. We support EU law aimed at protecting human health and the environment. We are also pleased to be able to contribute to “Chemicals-making best use of EU agencies to streamline scientific assessments”.

JBCE are happy to have an opptunity for giving in our comment on the Scientific opinions on chemical substances based on existing tasks that may be transferred from RoHS Directive to the Committee for Risk Assessment. JBCE welcomes a better alignment of RoHS Directive with REACH Regulation regarding the assessment of restriction substances.

Please find attached JBCEs position paper on the proposals for a Directive on the digitalisation and alignment of common specifications under the Omnibus IV package. JBCE welcomes the Commissions initiative and highlights the need to more boldly embrace digitalization approaches, remove physical requirements, ensure horizontal alignment across the NLF, and prioritise international standards over EU-specific common…

The Japan Business Council in Europe (JBCE) and the Japanese 4EE industrial associations (JP4EE) appreciate the continued opportunity to engage in dialogue with the European Commission concerning the implementation of the Ecodesign for Sustainable Products Regulation (ESPR), particularly with regard to the draft implementing act on the disclosure of unsold consumer products.

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to submit its feedback regarding the upcoming Implementing Regulation laying down rules as regards format and harmonised specifications for certain batteries labelling requirements.

We are pleased to contribute about the labeling requirements for air-to-air conditione. We(Japan Business Council in Europe :JBCE) and Air Conditioning Industry Association (JRAIA) made our position paper in Sep 2021 (attached file). JBCE and JRAIA would like to make further contributions whenever it is useful and needed and share the knowledge and experience of our members.

The Japan Business Council in Europe (JBCE) would like to express its support for the position paper submitted by the European Partnership for Energy and the Environment (EPEE) on 23 January 2026. The paper concerns the proposed revisions to the Ecodesign implementing Regulation and the Energy Labelling delegated Regulation for space and combination heaters, as well as water heaters (ENER Lot 1 & 2).

The Japan Business Council in Europe (JBCE) would like to express its support for the position paper submitted by the European Partnership for Energy and the Environment (EPEE) on 23 January 2026. The paper concerns the proposed revisions to the Ecodesign implementing Regulation and the Energy Labelling delegated Regulation for space and combination heaters, as well as water heaters (ENER Lot 1 & 2).

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to provide its feedback on the impact assessment concerning ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR).

The Japan Business Council in Europe (JBCE) would like to express its support for the position paper submitted by the European Partnership for Energy and the Environment (EPEE) on 23 January 2026. The paper concerns the proposed revisions to the Ecodesign implementing Regulation and the Energy Labelling delegated Regulation for space and combination heaters, as well as water heaters (ENER Lot 1 & 2).

On March 8th, the European Commission published their key Communication to react to the urgency to move away from EU’s dependency on fossil fuel imports “REPowerEU”. Heat pumps are seen as a central and key technology for reshaping the EU’s heating energy needs, today and in the future.

JBCE thanks the European Commission for giving the possibility to comment the new strategy for the European Standardisation. First, we would like to comment that the proposed amendment of the regulation covers a tighter scope compared to the strategy announced by the Commissioner.

Japan Business Council in Europe (JBCE), representing companies of Japanese parentage operating in Europe, appreciates the opportunity to provide feedback on the Draft Implementing regulation [Ares (2024)3437233] on the RACHP certification requirements extended to organic Rankine cycles and refrigerated units in mobile equipment.

The Japan Business Council in Europe (JBCE) welcomes the Cloud and AI Development Act (CADA) and supports its objectives. Japan shares the EU's dependence on a narrow group of non-EU providers and its exposure to extraterritorial laws.

The Japan Business Council in Europe (JBCE) would like to express its support for the position paper submitted by the European Partnership for Energy and the Environment (EPEE) on 23 January 2026. The paper concerns the proposed revisions to the Ecodesign implementing Regulation and the Energy Labelling delegated Regulation for space and combination heaters, as well as water heaters (ENER Lot 1 & 2).

The Japan Business Council in Europe (JBCE) appreciates the European Commissions proposals to amend the EU Batteries Regulation (EUBR) via Omnibus package IV. We hereby submit our comments on the amendments concerning battery due diligence obligations, along with suggestions to further rationalise the administrative burden in accordance with proportionality.

As a cross-sector association with member companies of Japanese parentage operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive, machinery, semiconductor, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the consultation regarding the MCCPs.

As a cross-sector association with member companies of Japanese parentage operating in different industries and stages in the supply chain (electronics, chemicals, polymer, automotive, machinery, semiconductor, wholesale trade, precision instruments, pharmaceutical, steel, nonferrous metal, textiles, ceramics, and glass products), JBCE welcomes the opportunity to contribute to the consultation regarding the…

The Japan Business Council in Europe (JBCE), representing companies of Japanese parentage operating in Europe, and the Japan Refrigeration and Air Conditioning Industry Association (JRAIA), representing manufacturers of refrigeration and air conditioning equipment in Japan, would like to commend the efforts of the European Commission and the study teams regarding the revision of the Ecodesign Regulation…

JBCE would like to thank the European Commission for the opportunity to provide input to the consultation on the roadmap for the review of the RoHS Directive. We support that this evaluation will assess effectiveness, efficiency, relevance and coherence, however, there are a few areas which we would like the evaluation to incorporate: • Providing sufficient consultation period A sufficient consultation period should…

The Japan Business Council in Europe (JBCE) appreciates the Commission’s work to make necessary amendments to the 2019 energy labelling and eco-design Regulations.Taking this opportunity, JBCE would like to propose following comments, especially for Eco-design requirements for electronic displays (Regulation (EU) 2019/2021). Please find the attached for our comments.

The Japan Business Council in Europe (JBCE), a cross-sectoral organisation representing companies of Japanese parentage active in Europe, recognises that the EU-Japan Economic Partnership Agreement (EPA) has significantly contributed to deepening trade relations between the two regions over the past five years.