MEDEF

For a Pragmatic and Competitive Path to Industrial Decarbonisation - MEDEFs Response to the Public Consultation on the Industrial Decarbonisation Accelerator Act (IDAA) 1. Preamble: Decarbonisation as an Industrial Strategy MEDEF welcomes the Industrial Decarbonisation Accelerator Act (IDAA), one of the four pillars of the Clean Industrial Deal.

Position du MEDEF relative au projet de règlement sur les emballages et déchets d’emballages Un cadre législatif mature à réformer dans la continuité Cela fera bientôt 30 ans que l’Union européenne a adopté sa première législation relative aux emballages et déchets d’emballages.

Filed in French · English published by the European Commission

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

Medef supports the European Commission's review of the delegated acts relating to climate and environment in the EU taxonomy, as it provides an opportunity to address challenges and resolve inconsistencies. These relate to issues at several levels, including adjusting technical selection criteria, improving definitions, clarifying compliance requirements and removing redundant or disproportionate obligations.

French companies acknowledge the Commissions important efforts to further simplify the ESRS by reducing workload and unnecessary costs for companies. The following issues still need to be addressed to make ESRS a useful instrument serving the transition.

Ecological transition is a key issue in France and in Europe. French companies welcome the ambition of the Green Deal for the European economy: o A strategy in favour of sustainable growth. o A logic of deep transformation to make Europe the first carbon neutral continent. o An ambition for Europe to be leader in the race for green technologies.

In a context of sovereignty and international competitiveness where the development of technological and digital infrastructures has become essential, it is vital to build a European ecosystem in favour of innovation and artificial intelligence (AI) that is respectful of European values.

Contribution from the Mouvement des Entreprises de France ( MEDEF) A) Context and definition of the problem The Medef shares the Commission’s objective to take a stand in favour of corporate governance that focuses on the long term and on sustainable growth.

Towards a Stronger EU ETS by 2040: Summary The EU Emissions Trading System (ETS) remains central to the EUs climate strategy. While it has reduced emissions, it must now adapt to heightened climate goals, global competition, and faster industrial transitions.

Contribution du MEDEF relative au projet de directive sur les allégations écologiques Les entreprises, en proposant des produits et des services plus respectueux de l’environnement, ont un rôle majeur à jouer dans la transition écologique. Mais elles ne pourront le faire seules, sans l’adhésion de leurs clients et consommateurs finaux.

Filed in French · English published by the European Commission

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

MEDEF shares the European objective of decarbonising road transport and recognises the greening of corporate fleets as a major lever. — It is essential, in consultation with public stakeholders, to define a balanced strategy for greening fleets, based on clear and shared milestones, ensuring a successful, competitive and fair decarbonisation of road transport, integrating the economic and operational realities of…

Filed in French · English published by the European Commission

Paris, le 22 juin 2022 Position du MEDEF relative au projet de règlement sur l’éco-conception des produits durable Une conception durable et harmonisée des produits, associée à une information qui permet d’éclairer le consommateur dans ses choix doit permettre de concourir à l’atteinte des objectifs de neutralité carbone et plus généralement à la réduction des impacts des produits et de la consommation sur…

Filed in French · English published by the European Commission

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

In order to speed up the ecological transition, the environmental impact of the use of products should be further reduced. This can be achieved by addressing businesses’ supply of more sustainable products and consumer demand. Linking the new Circular Economy Action Plan with the consultation on consumer autonomy in the green transition is a relevant approach.

Filed in French · English published by the European Commission

The ambitious goal of a carbon-neutral economy by 2050 requires accompanying the financing of massive investments, the emergence of disruptive technologies and the preservation of companies with less ambitious international competition. France and Europe have become aware that their climate policy weakens their champions without reducing global emissions and that it leads to the transfer of emissions across borders.

Filed in French · English published by the European Commission

MEDEF, together with AFEP and France industrie, shares the European decarbonisation ambition and recognises the central role of the European Union Emissions Trading System (EU ETS) in the European climate strategy to steer industrial investments towards decarbonisation. This transition cannot take place at the cost of weakening European and French industrial competitiveness.

Dear Sir / Madam, We thank you for the opportunity to comment on the Inception impact assessment relating to the revision of the Energy Taxation Directive (ETD). We would like to share our views on the overarching principles which, according to us, should guide the revision of the ETD: - Protect and strengthen the competitiveness of the European Business, especially the European industry in the energy sector: this…

MEDEF takes note of the Commission’s commitment to develop consumer protection rules online and supports the obligation to ensure fairness for consumers and businesses in transactions in the Digital Single Market, to improve legal certainty, to ensure effective enforcement and to prevent market fragmentation. However, this fairness cannot result from the introduction of new obligations for companies.

Filed in French · English published by the European Commission

MEDEF consulted its members on the proposed amendments to the delegated acts concerning the green taxonomy. We note that trade associations are finding it very difficult to assess the proposed changes within such a short consultation period.

LInnovation Act doit faire de lEurope lendroit le plus simple pour financer, tester et mettre sur le marché des innovations, à toutes les étapes de TRL. Nos priorités : (1) achever et approfondir lUnion de lépargne et de linvestissement afin de faire face aux défis du financement des transitions digitales et environnementales en même temps que du renforcement de la compétitivité des entreprises en mobilisant jusquà…

It is widely recognised that data are today a source of values, opportunities and innovation offering broad prospects for growth and competitiveness. The sources of digital power are now considered to be in the exploitation of data. To this end, MEDEF supports the horizontal approach adopted by the European Commission in its proposal for a Regulation on access and use of data (‘Data Act’), presented on 23 February.

Filed in French · English published by the European Commission

Agricultural development, urbanisation, the development of transport networks, but also the construction of infrastructure dedicated to energy production, the protection of property and people, etc. have been accompanied by a deterioration in certain environments: disappearance of wetlands, disruption of ecological continuities, reduced self-regulation capacity of environments, resulting in deterioration of nature…

Filed in French · English published by the European Commission

MEDEF welcomes the work carried out by the European Commission on the DSA which is a rather well-balanced text. On the one hand, it maintains the key principles of the e-commerce directive (liability exemption for technical intermediaries and prohibition of general monitoring obligations).

AFEP, MEDEF, France Industrie Press Release 2040 CLIMATE TARGET Achieving Europes decarbonisation requires the immediate launch of a globally competitive agenda The European Commission proposes to create a legally binding target to reduce net greenhouse gas emissions by at least 90% by 2040 compared to 1990 levels.

Paris, le 23 juin 2022 Position du MEDEF vis-à-vis de la proposition de la Commission Européenne révisant la directive sur les émissions industrielles Alors que l’évaluation faite de la directive IED avait montré la pertinence de cette dernière pour réduire de façon conséquente les émissions industrielles, la Commission Européenne a fait le choix de réviser cette directive pour renforcer sa mise en œuvre dans les…

Filed in French · English published by the European Commission

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

MEDEF, Comments on the Inception Impact Assessment on IED directive While many industrial sectors are currently mobilized in the management of the COVID-19 crisis, it is extremely difficult to carry out this consultation which requires the answer of all the sectors concerned.

Propositions pour la future initiative de la Commission Européenne « Portabilité des compétences dans l’UE » Février 2026 Le MEDEF soutient la libre circulation des travailleurs et la portabilité des compétences. Le MEDEF a d’ailleurs formulé en 2024 des propositions pour soutenir la mobilité des ressortissants européens pour faire face aux pénuries de main d’œuvre en Europe.

Filed in French · English published by the European Commission

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

MEDEF welcome this proposal for a regulation, the first part of the European data strategy, which aims to promote the availability of data and to regulate data sharing services. However, this proposal for a regulation raises a lot of questions as to its scope and how it reports with European texts (in force or under discussion), such as the DSA/DMA or the future data act, and with initiatives such as Gaia-X and the…

Filed in French · English published by the European Commission

Mouvement des entreprises de France (Medef) is the main French business association, representing companies of all sizes and sectors, both issuers and investors. Medef welcomes the opportunity to comment on the proposal for a directive on corporate sustainability reporting.

As the leading representative organisation of French businesses, the Mouvement des Entreprises de France (MEDEF) brings together, with its members - 101 professional federations and 119 territorial organisations - more than 200 000 companies of all sizes, from small and medium-sized enterprises to large corporations, covering all sectors of the French economy.

The Medef is in favour of a general increase in the level of cybersecurity in Europe and therefore the objective pursued by the proposed Regulation. With the development of connected objects and the Internet of Things (IoT), which are central to our daily lives (from watches connected to industrial sensors), it is important to give users access to hardware and software products with fewer vulnerabilities.

Filed in French · English published by the European Commission

For MEDEF, electrification is an important lever for the energy transition, competitiveness and European sovereignty. The delectrification strategy must be based on coherent planning of loops, infrastructure, demand and value chains and on a credible business model for electrification.

Filed in French · English published by the European Commission

Summary - MEDEF welcomes the Digital Markets Act (DMA), marking a major step in the project to regulate the most structuring digital platforms to ensure more effective operation of the internal market. This is an issue of sovereignty and fair competition for French and European companies.

Response of the MEDEF to the consultation of the European Commission — see attached document As part of the launch of two impact studies, the European Commission is planning to: The introduction of a “New competition tool”, and/or An ex ante regulatory instrument for large online platforms with significant network effects which may play a role in access to certain markets within the European Union (‘large platforms…

Filed in French · English published by the European Commission

MEDEF welcomes the European Commissions initiative to provide guidance on the implementation of the Cyber Resilience Act through operational guidelines. This effort is both timely and necessary, as it contributes to enhancing legal certainty, facilitating a harmonised application of the Regulation, and better aligning its requirements with industrial, technological and sector-specific realities.

MEDEF supports the European Commission’s initiative to introduce measures to facilitate access to repair for consumers. These proposals complement the French initiatives that have already been introduced since 2020, and in particular the ‘repair fund’ under LOI No 2020-105 of 10 February 2020 on combating waste and the circular economy (Article 62).

Filed in French · English published by the European Commission

The French Business Confederation (MEDEF) is the largest business organisation in France, representing over 200 000 companies of all sizes and sectors. Please find our full position on the Quantum Act in the attachments. MEDEF fully supports the European Commissions ambition to make the European Union a global leader in quantum technologies.

MEDEF welcomes this European cybersecurity strategy because it seems today, more than ever, necessary to strengthen the level of cybersecurity of the entire European ecosystem, be it companies, but also and above all States and public authorities.

CONSULTATION DE LA COMMISSION EUROPÉENNE RÉVISION DES DIRECTIVES PCD ET DROITS DES CONSOMMATEURS OBSERVATIONS DU MEDEF ID#43763731235-75 Consultation de la CE – Révision des directives PCD et droits des consommateurs Observations du MEDEF – Mai 2022 1 Proposition de directive européenne modifiant les directives 2005/29/CE et 2011/83/CE pour donner aux consommateurs les moyens d’agir en faveur de la transition…

Filed in French · English published by the European Commission

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

The Medef welcomed the reform of the electricity market and the European Commission’s initial proposals to introduce long-term market signals while preserving the short term functioning needed to balance demand. This reform is crucial because access to abundant and competitive low-carbon electricity is essential for the decarbonisation of the European economy and the resilience of its industrial competitiveness.

Filed in French · English published by the European Commission

While the main climate and energy framework for 2030 is now in place and the European Union has a target of reducing greenhouse gas emissions by 90 % by 2040, the task now is to prepare the post-2030 framework. With this in mind, MEDEF supports the revision of the European Regulation on the Governance of the Energy Union.

Filed in French · English published by the European Commission

The French Business Movement (MEDEF) welcomes the publication of this draft Regulation, which partly addresses the major issues raised by MEDEF in its contribution to the new Consumer Agenda of September 2020. We are particularly interested in two main objectives pursued by this revision: — the alignment of product safety and compliance rules in the EU and the alignment of the responsibilities of each economic…

Filed in French · English published by the European Commission

Dear Sir/Madam, We welcome the European Commissions Call for Evidence on the forthcoming Tax Omnibus initiative, which aims to introduce targeted changes to EU direct tax legislation. MEDEF has actively contributed to all public consultations conducted in 2025 in the context of the Commissions simplification agenda. We refer to our previous submissions, which remain largely valid.

Taking note of the Commission’s willingness to revise the Market Surveillance Regulation, MEDEF welcomes this initiative, subject to the following elements: 1. Prioritising the effectiveness of controls on incoming flows rather than new constraints for European actors: The lessor of extra-European e-commerce and Chinese platforms favours the entry of often non-compliant products into the domestic market.

Filed in French · English published by the European Commission

MEDEF welcomed the draft European MISP text. It is an important step in enhancing the integration and competitiveness of European financial markets to the benefit of businesses. In the current context, a high level of ambition is essential. The US and several Asian squares are making rapid progress in adapting their regulatory framework to financial and technological transformations.

Filed in French · English published by the European Commission

PROPOSITION DE DIRECTIVE DU PARLEMENT EUROPEEN ET DU CONSEIL RELATIVE A LA RESPONSABILITE DU FAIT DES PRODUITS DEFECTUEUX OBSERVATIONS DU MEDEF Observations du Medef sur la proposition de directive du Parlement européen et du Conseil relative à la responsabilité du fait des produits défectueux – Novembre 2022 1 Remarques liminaires Le 28 septembre dernier, la Commission européenne a présenté deux propositions de…

Filed in French · English published by the European Commission

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

MEDEF welcomed the draft European MISP text. It is an important step towards strengthening the integration and competitiveness of European financial markets to the benefit of businesses. In the current context, it is essential to have a high level of dambition. The US and several Asian squares are making rapid progress in adapting their regulatory framework to financial and technological transformations.

Filed in French · English published by the European Commission

Please find attached our full position. With four years to go until 2030, the Digital Decade is entering a decisive phase. The European Union has been able to equip itself with an ambitious policy and normative framework to accompany the digital transformation. It has set clear objectives, established common monitoring mechanisms and affirmed a globally recognised regulatory capacity.

Filed in French · English published by the European Commission

In its Banking Package 2021, the Commission proposes a review of EU banking rules to finalise the implementation of the Basel III agreement in the EU. While we recognise the Commission’s efforts to take EU specificities into account, its proposal is not yet in line with the mandate given to the Basel Committee to finalise the Basel III framework without significantly increasing overall capital requirements across…

While the European Union faces huge challenges in ensuring the energy, ecological and digital transition of its economy and financing the hundreds of billions of euros of necessary investments, Medef is extremely concerned about the consequences of the transposition of the Basel agreements of December 2017 into their current form:  A negative macroeconomic impact: impact studies carried out by the European Banking…

Dear Sir, thank you for the opportunity to share our thoughts in the context of the public consultation on the BEFIT (Business in Europe: Framework for Income Taxation), which concerns the limitation of business income in the European Union (EU). Businesses essentially expect a harmonised European basis for simplification, competitive advantage and legal certainty.

Filed in French · English published by the European Commission

Dear Sir/Madam, We welcome the consultation of the European Commission (EC) relating to a proposal for a Council Directive on transfer pricing. Please find hereattached our feedback. As always, we stand ready to further discuss and explain our views. Yours sincerely, [name removed] MEDEF

Dear Sir/Madam, We very much welcome the consultation of the European Commission (EC) relating to a proposal for a Council Directive establishing a Head Office Tax system for small and medium-sized enterprises, published on 12 September 2023 and which is part of the SME Relief Package. The Commission assesses that SMEs spend approximately 2.5% of their turnover on compliance with their tax obligations (e.g.

Dear Sir/Madam, We welcome the consultation of the European Commission relating to its proposed package on VAT in the Digital Age published on 8 December 2022. We would like to share hereattached some overarching observations, followed by some more technical comments.

The Medef welcomed the Commission’s proposal for a regulation on the transparency and integrity of environmental, social and governance (ESG) rating activities. In addition to the need to foster sustainable investments recalled by the Commission, ESG ratings also help companies assess their value chain, the dynamics of which are increasing due diligence and due diligence requirements.

Filed in French · English published by the European Commission

MEDEF comments on the European Commission proposals dated 27 April 2023 for a Regulation on the unconditional supplementary protection certificate for plant protection products; on compulsory licensing for crisis management and amending Regulation (EC) 816/2006; on standard essential patents and amending Regulation (EU) 2017/1001 (Patent package).

Filed in French · English published by the European Commission

MEDEF welcomes this initiative, which promotes the development of the digital single market by enabling citizens and businesses to identify themselves quickly and share documents more easily and under the same conditions within the EU.

Filed in French · English published by the European Commission

We welcome the consultation of the European Commission (EC) relating to the Council Directive on Faster and Safer Relief of Excess Withholding Taxes published on 19 June 2023 and are pleased to provide input. We agree fully with the ECs assessment that inefficient withholding tax relief procedures are one of the main obstacles to the free movement of capital and to the integration of capital markets.

Mouvement des Entreprises de France (MEDEF) welcomes the European Commission's initiative to address the issue of burdensome withholding tax relief procedures for cross-border investors with respect to certain types of income (mainly dividends, interest and royalties). This is a long-standing problem on which little progress has been made in recent years.

the SRD II framework broadly functions. The main challenges lie in practical cross-border implementation and intermediary compliance. Targeted improvements should therefore focus on strengthening the regulatory framework for proxy advisors, improving operational efficiency in cross-border chains and preserving issuer flexibility within a harmonised EU framework.

In an increasingly international and digitalised context, and in particular in the run-up to Brexit, it is essential for businesses to rapidly have a stable, secure and effective legal solution that allows for the maintenance and continuity of transfers of personal data outside the EU, especially as standard contractual clauses remain the most used tool by companies for transfers outside the EU.

Filed in French · English published by the European Commission

The Mouvement des entreprises de France is the first network of entrepreneurs in France representing more than 173 000 member companies comprising all sectors of activity and 95 % of which are SMEs/ETI. The mission of the French Business Movement is to promote and represent the interests of French companies vis-à-vis the French and European public authorities and to develop entrepreneurship.

Filed in French · English published by the European Commission

MEDEF broadly supports the draft EU regulation on foreign subsidies to address distortions of competition in the single market. The latter includes a number of comments and priorities expressed by French companies during the public consultation on the Commission’s White Paper. Our main reservation relates to the effectiveness of tools 2 and 3 on mergers and public procurement as the thresholds are too high.

Filed in French · English published by the European Commission

A risk-based European strategy focused on the effectiveness of rules and the recognition of integrity frameworks The future European anti-corruption strategy should be structured around three complementary priorities: a risk-based approach, better enforcement of existing rules, and recognition of the most mature integrity frameworks.

We are pleased to provide the following comments with respect to the European Commission’s initiative on debt-equity bias reduction allowance, which aims to encourage companies to finance their investment through equity contributions rather than through debt financing.

MEDEF would like to remind about its previous contributions submitted in July 2024 and June 2025, which remain largely valid. As regards the recast of the Directive on Administrative Cooperation (Directive 2011/16/EU DAC), we would recommend focusing on the following key priorities: eliminating reporting obligations that are obsolete or provide limited value, particularly under DAC6, and streamlining overlapping or…

In a context of international sovereignty and competitiveness where the development of European technological and digital infrastructures has become indispensable, it is crucial to build a European ecosystem of trust that respects both European values and innovation and artificial intelligence (AI), so that citizens and businesses can benefit from cutting-edge technologies.

Filed in French · English published by the European Commission

Dear Sir/Madam, We thank you for the opportunity to participate in the public consultation on the proposal for a directive on “shell companies” and would like to share with you the following detailed comments and proposed amendments (please see attached). As always, we stand ready to further discuss and explain our views. Yours sincerely, [name removed] – MEDEF

In its Inception impact assessment, the European Commission indicates that the issue at stake is the use of legal entities with no or minimum substance and no real economic activities, by taxpayers operating cross-border to reduce their tax liability.

The Mouvement des Entreprises de France (MEDEF) welcomes the European Commissions proposal for a review of the Regulation on Foreign Direct Investment screening in the EU. Over all, the updates proposed in the new Regulation go into the right direction. It becomes for example mandatory for all Member States to establish a screening mechanism.

The Mouvement des Entreprises de France (MEDEF) is the leading network of entrepreneurs in France, representing more than 173 000 member companies covering all sectors of activity, 95 % of which are SMEs/ETI. The mission of the French Business Movement is to promote and represent the interests of French companies vis-à-vis the French and European public authorities and to develop entrepreneurship.

Filed in French · English published by the European Commission

The proposed revision adds many provisions to the originally revised Directive, but these provisions are still unclear. Our contribution focuses on the definition of offences (Articles 2 and 3 of the proposal). The principle of clarity and precision of criminal law All unlawful acts as defined in Article 2, as detailed in Article 3, constitute infringements.

Filed in French · English published by the European Commission

The Mouvement des Entreprises de France supports the global minimum tax project, in that it can limit certain excessive tax differences between countries. However, this important political objective must not be achieved at the expense of European (including French) companies.