Technology Industries of Finland

Technology Industries of Finland (TIF) welcomes the European Commissions intention to simplify EU digital legislation through the Digital Omnibus proposals on AI as well as data and cyber. European digital investments need better regulation.

Technology Industries of Finland welcomes the European Commissions initiative to streamline the EUs digital regulation framework through the Digital Package for Simplification. The package is an opportunity to remove unnecessary burdens, overlaps and inconsistencies, ensuring legislation supports innovation, investment and competitiveness. 1.

The Technology Industries of Finland welcomes the initiative for a Circular Economy Act as an opportunity to create a coherent and investment-friendly EU framework for circularity. The Act should strengthen industrial competitiveness and internal market integration, while avoiding overlaps with existing legislation such as ESPR and the CRMA.

TIF feedback to REDII: REDII should be amended so as to include hydrogen and RFNBO-fuels produced from low carbon sources. Also nuclear power contributes to reducing GHG emissions and therefore it must be regarded as low carbon energy. The EU-level target should remain indicative. Member States should have the obligation to include their targets in the National Energy and Climate Plans (NECP).

Technology Industries of Finland (TIF) supports the objectives of the proposed new Regulation on Packaging and Packaging Waste (henceforth PPWR) as an effective tool in the transition towards a circular economy. Aside from learning new ways of consuming less and more sustainably, it is commendable that attention is also paid on packaging to avoid unnecessary use of resources.

Technology Industries of Finland (TIF) warmly welcomes the European Commissions planned adoption of a European Critical Raw Materials Act. Raw materials are indispensable to ensuring that the transition towards a green and digital European economy is successful. At the same time, they are also commodities that are at high risk of supply disruption.

Technology Industries of Finland supports enshrining the objective of climate neutrality by 2050 in a new Climate Law under the Green Deal. It is important that EU climate policy is determined for a long term with clear targets so that European industries are able to plan their investments in a stable and enabling framework.

The Commission has come along with an ambitious proposal to regulate AI. Getting the balance right in ensuring that obligations drive policy outcomes, while allowing AI innovators sufficient flexibility in meeting those obligations, is going to be critical. Especially the ethical requirements will drive forward trust and sustainable use of AI solutions.

Technology Industries of Finland (TIF) represents more than 1,600 companies, active in Finland in various sectors of technology industries. Our member companies cover both developers and deployers of AI. Our main messages are: • There is no one, overarching AI. AI is a set of technologies for processing and extracting value out of data, automating decisions and extracting insights.

Proposal for a Directive of the European Parliament and of the Council on Corporate Sustainability Due Diligence and amending Directive (EU) 2019/1937 – Comments by Technology Industries of Finland The Finnish Technology Industries organization promotes competitiveness and operational preconditions for technology industry companies, the largest and most important export sector in Finland.

TIF supports the Commission’s aim to modernise regulation of ecodesign requirements of products and set a legal framework for digital product passports, facilitating the combination of data with material flows. Our key messages are: The EU should be the global leader in setting standards together with industries for a sustainable and responsible market economy.

Sustainable Product Policy – a necessity to fulfil Circular Economy Technology Industries of Finland welcomes the commissions initiative on Sustainable Product Policy. It is crucial for our industries that the sustainable product policy legislative initiative will provide a stable framework, while upholding the basic principle of technology neutrality which is a key enabler of ensuring a variety of technology…

The Technology Industries ry has committed to Finland’s carbon neutrality target in 2035 and as part of the European Union’s international climate goals and agreements, such as the Paris Agreement on Climate Change. This requires building long-term climate action so that the EU’s carbon neutrality is achieved in a socially, economically and environmentally sustainable manner before 2050.

Filed in Finnish · English published by the European Commission

The enclosed document gives the reactions from the Finnish Technology Industries – which accounts over 50 % of the Finnish exports - to the European Commission’s inception impact assessment (IIA) on carbon border adjustment mechanisms. Given the expected potential higher climate ambition for 2030, we recognize that additional and improved carbon leakage provisions may be needed.

EU Energy Efficiency Directive – evaluation and review The Finnish Technology Industry welcomes the opportunity to comment on the subject matter. Summary of the main messages of our opinion: •Technology is in favour of tightening the energy efficiency target at EU level as it generates markets and demand for energy-efficient solutions.

Filed in Finnish · English published by the European Commission

Technology Industries of Finland’s comments on the Inception Impact Assessment of the revision of REACH and CLP regulations The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland.

A vote on the classification of cobalt will be held at the February meeting of the REACH committee. According to the current information, the vote at the meeting will be held on the Commission’s proposal for a new hazard classification, with the main topic being that cobalt is carcinogenic 1B on all exposure routes, with a GCL (General concentration limit) of 0.1, and a new working group should be established to…

The Technology Industries of Finland (TIF) is committed to the fight against climate change and sees that the EU and its Member States must make rapid progress in implementing their emission reduction commitments under the Paris Climate Agreement. We are in favor of tightening the EU's 2030 emissions reduction target to 55% and the goal of climate neutrality in the Union by 2050.

Technology Industries of Finland proposes that all heating fuels should be included in the ETS and no CO2-taxes should be collected in the heating sector. Energy taxes on heating fuels shall be set by Member States within the frames of Energy Taxation Directive. District heating and cooling are already within the ETS. The enclosed document enlightens our views more in detail.

Summary of Technology Industries of Finland’s contribution to the Education Package 2040 Technology Industries of Finland welcomes the European Commission’s Education Package 2040 and supports its focus on basic skills, teachers and digital education as key drivers of Europe’s competitiveness, innovation and resilience.

Filed in Finnish · English published by the European Commission

Summary of Technology Industries of Finland's contribution to the Education Package 2040 Technology Industries of Finland welcomes the European Commission's Education Package 2040 and supports its focus on basic skills, teachers and digital education as key drivers of Europe's competitiveness, innovation and resilience.

Technology Industries of Finland welcomes the Commission initiative on putting use data of connected machines into use. Globally, the Commission's proposal marks a third way between Eastern and Western approaches and aims especially to help SME companies in their digitalisation pathway.

Initial Comments to the Data Act Technology Industries of Finland has more than 1,600 members in various fields of technology, of which roughly 1,500 are SME companies. We have been actively advancing data usage within our member companies and developing balanced and practical models for data usage and sharing. Commission proposes new practices for public sector access to business data.

Technology Industries of Finland’s contribution to the Inception Impact Assessment of the revision of Industrial Emissions Directive (IED) Technology Industries of Finland thanks for of the possibility to comment Commission’s plan, revision of Industrial Emissions Directive, in its early stage as Inception Impact Assessment is.

Technology Industries of Finland (TIF) represents more than 1,600 companies operating in Finland in various areas of technology. In Finland, the technology industry directly employs more than 300 000 people. Technology Industries of Finland regards the Data Governance Act a key piece of regulation and would like to provide the following comments: Chapter I Concept of Data Sharing Service Provider should be defined.

Technology Industries of Finland (TIF) warmly welcomes initiatives that enhance data usage and interoperability and would like to especially highlight importance of following factors: • Personal data is to be found on many public and private datasets. In order to put this data to use, we need to have in place solutions to provide consent and better understanding on effect of privacy enhancing technologies.

Europes competitiveness and technological resilience depend on keeping pace with the fast-evolving semiconductor landscape. Technology Industries of Finland urges the EU to act with urgency in its chips policy so that implementation matches global developments and delivers a systemic, forward-looking strategy that consolidates strengths, tackles dependencies, reflects and catalyses demand and aligns EU and national…

Technology Industries of Finland’s comments on the Inception Impact Assessment of the revision of REACH and CLP regulations The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland.

Ref. Ares(2022)1955751 - 17/03/2022 Dear recipient, Technology Industries of Finland (later TIF) wishes to thank European Commission for the possibility to be heard on the matter of European Commission’s call for evidence for an impact assessment on Cyber Resilience Act. Please find our position paper attached.

Technoolisus ry supports action at EU level to increase the use of renewable aviation fuels. The measures chosen should be implemented in a way that effectively reduces aviation emissions, prevents carbon leakage and takes into account the operating conditions of the air transport sector and the accessibility of Member States.

Filed in Finnish · English published by the European Commission

Technology Industries of Finland considers it highly important that the EU updates its Arctic policy to reflect the rapidly changing geopolitical, economic and security environment. The 2021 Joint Communication no longer adequately reflects current circumstances, in which the Arctic has gradually shifted from being a zone of cooperation to also becoming a focal point of strategic competition and great-power…

Technology Industries of Finland appreciates the opportunity to provide early feedback on the upcoming delegated regulation that defines the requirements for digital product passport (DPP) service providers. Recommendations for the upcoming delegated regulation defining requirements for Digital Product Passport service providers: 1.

The Finnish Technology Industries promotes competitiveness and operational preconditions of technology industry companies, the largest and most important export sector in Finland. Technology industry comprises five sub-sectors: electronics and electro technical industry, mechanical engineering, metals industry, consulting engineering and information technology industries.

Technology Industries of Finland thanks of the possibility to comment Commission’s plan, revision of Waste Shipment Directive, in its early stage as Inception Impact Assessment is. Finnish companies are at the forefront of creating new solutions for the circular economy, but request for predictable regulation, a well-functioning internal market and cost-efficient implementation.

Europe faces a critical juncture in quantum technology, where strategic choices in the coming years will determine its global position. The continent has world-class research capabilities, strong industrial frontrunners and early infrastructure investments. Yet the global race is intensifying, and without a clear and bold strategy, Europe will fall behind.

Technology Industries of Finland sets out these recommendations to contribute to the Digital Fitness Check and to support a regulatory approach that strengthens Europes competitiveness in the digital domain. Europe should restore the link between regulation and the Single Market. Instead of rushed volume and omnibus-scale mistakes, regulation should be guided by necessity, consistency, andabove allquality.

Technology Industries of Finland (TIF) is an industry association that promotes the competitiveness and business environment of Finland's most important export sector. TIF represents 1,800 member companies. The forthcoming EU Business Wallet will create real value only if it primarily supports business-to-business (B2B) interactions rather than being limited to business-to-government (B2G) compliance.

In turbulent times, the European business environment needs to focus on safeguarding its critical know-how. Technology Industries of Finland (TIF) advocates for a market-driven approach to de- risk industrial value chains. Excessive governmental intervention should be minimized, focusing instead on fostering conditions conducive to technological leadership and long-term global competitiveness.

The Technology Industries of Finland welcomes the initiative to green-list certain waste and consider the proposed Delegated Regulation an important step towards a more proportionate and efficient framework for intra-EU shipments of waste destined for recovery.

Technology Industries of Finlands submission to the public consultation: Proposal for a Council Directive establishing a Head Office Tax System for micro, small and medium sized enterprises (HOT) The European Commission (EC) has requested comments regarding the so called HOT-directive proposal.

Please see the attached file. Technology Industries of Finland (TIF) is of the opinion that although the said goals of BEFIT are highly supportable, BEFIT is not the correct tool, nor is it introduced at the right time. The BEFIT proposal should be postponed and discussed only after the OECD pillars and the EU minimum taxation directive are in place, fully and successfully implemented and operated for several years.

The Commission has proposed an ambitious programme, Path to the Digital Decade, to boost the digitalisation development throughout the EU. Technology Industries of Finland finds the four-pronged approach of the Compass in principle balanced and well-founded. GENERAL The Compass is missing a few essential themes, and we urge the Commission to include targets for data economy development and soft infrastructures.

Technology Industries of Finland is strictly against transition to qualified majority voting (QMV) in EU taxation policy due to the following reasons: 1) The Commission has claimed, that the veto right has caused a significant “cost” to the EU, due to tax proposals like digital services tax (DST) and common consolidated corporate tax base (CCCTB) being blocked by some Member States.

The European business environment needs to focus on safeguarding its critical know-how. Technology Industries of Finland (TIF) advocates for a market-driven approach to de-risk industrial value chains. Excessive governmental intervention should be minimized, focusing instead on fostering conditions conducive to technological leadership and long-term global competitiveness.