Siemens AG

Intro The immense regulatory burden stifles competitiveness and pace of innovation of European tech companies: every day, we are losing ground to the USA and China! The growing patchwork of digital regulation (AI Act, Data Act, Cyber Resilience Act) imposes significant and costly implementation efforts on European operators.

The full set of recommendations can be found in the attached paper. Below, the most urgent comments: 1. Scope: Recognise the role of energy efficiency solutions (esp. manufacturing) for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

Siemens main recommendations: 1. Scope: Recognise the role of energy efficiency solutions for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

Siemens main recommendations: 1. Scope: Recognise the role of energy efficiency solutions for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

Siemens welcomes the work of the Commission in revising the Energy Performance of Buildings Directive (EPBD) as part of the ‘Fit for 55 Package’ and coherently connecting it with both the Renovation Wave, the Digital Decade and the Energy System Integration Strategy.

Siemens, a global technology leader, actively participates in EU R&I programmes, recognizing innovation and international collaboration as vital for its competitiveness and for addressing key societal challenges.

Siemens believes in the importance of standardization and the development of a shared language, as intended by the EU Taxonomy Regulation and the Corporate Sustainability Reporting Directive (CSRD). We are strong supporters of advancing sustainability reporting by promoting greater accuracy, comparability and reliability.

Siemens AG recognizes the European Commission’s effort to propose world’s first AI regulation, building on its last year’s White Paper and aiming at ensuring that AI systems, introduced on the EU market are safe and respect EU laws and values while at the same time creating legal certainty to facilitate investment and innovation in AI.

The careful analysis of the proposal from the European Commission identified points which would result in a severe impact to manufacturer. Some of these are for example fixed deadlines for harmonized technical specifications, marking requirements, validity of notified bodies certificates and manufacturer obligations. The attached document list these and other points in detail and propose how they shall be improved

The full set of recommendations can be found in the attached paper. Below, the most urgent comments: 1. Scope: Recognise the role of energy efficiency solutions (esp. manufacturing) for industrial processes to foster EUs decarbonization, resilience and competitiveness objectives and include relevant activities in the Taxonomy scope. 2.

The Data Act constitutes a horizontal regulation for all IoT application fields even though there appears to be no apparent evidence of market failure or information asymmetries, or only in very specific market segments. Therefore, such a broad regulatory intervention seems premature and could even create new obstacles for the desired market uptake of the European data economy in industry.

Overall, we support the position/input from DigitalEurope to this consultation and do not see the need to duplicate the content of their document. (Siemens is member of DigitalEurope and occupies a board seat in this association) Beyond this association position, we want to emphasize 2 additional aspects that Siemens AG sees as highly important to take care of: (1) Radio Spectrum: Siemens welcomes the engagement for…

Siemens AG welcomes the opportunity to provide its feedback and recommendations on the European Commission’s proposal, released April 5th., to revise the Fluorinated Greenhouse Gases (F-gas) regulation to prevent further F-gas emissions and foster the uptake of climate and environmentally friendly solutions.

Siemens AG likes to address 3 topics regarding aspects of SF6 management in its feedback to (EU) No 517/2014. For further details and annotations please refer to the attachment. A. Countries that adopted a self-commitment on SF6 emissions reduction, show significantly higher reductions from 2.G.1 sector than others. We recommend implementing the content of these well-working commitments into a regulation recast. B.

Siemens AG welcomes this opportunity to provide feedback on the implementation of CBAM. Please find below and attached our main recommendations: Standardise emissions methodology and simplify reporting with user-friendly systems and minimal verification requirements. Define clear, grid-specific emission factors for electricity to incentivize low-carbon energy use in production.

Siemens AG welcomes a horizontal EU-wide cybersecurity regulation that ensures the functioning of free movement of goods in the EU internal market for covered products. We ask to consider the specifics of products intended to be used by professionals solely in industrial and critical infrastructure domains (e.g.

Siemens AG and its affiliated companies have a strong interest in a functioning and high-performing European standardization system to support legal certainty for manufacturers, traders, vendors and users, to maintain the free movement of goods within the internal market, and to accompany innovation in competitive markets.

With electricity demand surging and renewable integration accelerating, the EUs grid infrastructure faces unprecedented challenges that require bold, system-wide investments. The most effective way to enhance the EUs energy security, competitiveness, and resilience toward 2050 is to intensify the sustainable transformation of the gridplacing digital technologies at the heart of this effort to ensure it is smart…

Siemens A.G. welcomes the European Commissions initiative to boost electrification through an Electrification Action Plan. As a European technology leader, electrification is at the core of our mission, as it provides the most effective lever to decarbonise the economy, enhance energy resilience, and strengthen industrial competitiveness.

Siemens AG as a global manufacturer of machinery and electrical equipment for machinery, and at the same time operator of factories worldwide appreciates the possibility to submit comments on the proposed Regulation on Machinery Products.

Siemens AG is a technology company focused on industry, infrastructure and transport. We have a strong digitalisation expertise and long experience as providers of software solutions and manufacturers of highly complex electronics.

Siemens welcomes the opportunity to provide feedback on the European Commission’s Inception Impact Assessment on adapting liability rules to the digital age and artificial intelligence. For many purposes, specifically in the industrial domain, AI is a powerful technology which helps to make our lives and work easier.

We welcome the opportunity to comment on the Proposal for a Regulation of the European Parliament and of the Council on standard essential patents (SEPs) and amending Regulation (EU)2017/1001 . Our detailed assessment and comments can be found in the attached uploaded document.

Dear EU Commission, We thank you for the opportunity to comment on the proposal VAT in the Digital Age. Siemens AG is committed to promoting digitalization in tax law. We therefore comment attached our position on the planned changes. We would like to emphasize in advance that we welcome the initiative, even if not fully. For us, e-invoicing is the right step into a more digital future.

From a Siemens AG perspective, it is essential that companies are being given sufficient time to prepare the implementation of the CRA. We feel that the current deadlines are very challenging and force companies to allocate significant resources to it. This is also valid for the European standardisation activities which will rely on those technical descriptions. Simplification of the framework is therefore critical.

We welcome the ALD (AI Liability Directive) as being a directive and not a Regulation leaving the details of the liability regime to the Member States We also welcome the proposed fault-based regime (and that the EC does not entertain previous attempts to introduce strict liability for AI). We would prefer that the ALD set this principle as a standard to avoid fragmentation among the Member States.

Overall, we welcome the Chips Act proposal from the European Commission. It underlines the vital importance of semiconductor in every aspect of industry and daily life, and it shows that the current chips shortages have awakened Europe.

Have Your Say (24/01/2025): On the proposal for a regulation on a public interface connected to the Internal Market Information System for the declaration of posting of workers and amending Regulation (EU) No 1024/2012 General remarks We welcome the opportunity to comment and have our say and highly appreciate the Commissions' proposal to harmonize and regulate the declaration of posting of workers.

We appreciate the opportunity to provide feedback on the EU's Ecodesign review for electric motors and variable speed drives, focusing on system efficiency, material efficiency, and information requirements. Please refer to the annex for reasoning.