TNO

TNO welcomes the announcement of the Circular Economy Act (CEA) as a timely and ambitious step to strengthen Europes single market for secondary raw materials and accelerate the transition to a truly circular economy.

TNO welcomes the initiative of the European Commission to create a legislative package on the Critical Raw Materials (CRM). TNO is a research and technology organization in the Netherlands with the Material Transition as an important area of activities.

TNO welcomes the European Commissions proposals for the European Competitiveness Fund (м) and Horizon Europe 2.0 as part of the next Multiannual Financial Framework (20282034). Europe enters a decade in which technological capability, industrial competitiveness and innovation ecosystems will determine its position in the world.

Filed in Dutch · English published by the European Commission

TNO welcomes the Commissions initiative to propose a European Innovation Act to create an innovation-friendly environment in Europe. Scaling up innovation is crucial for the EU to compete globally with players such as the US and China. This Act is an important step in that direction and represents a unique opportunity to strengthen Europes technological sovereignty and competitiveness.

From TNÓ's involvements in Dig.Infra developments we have made the following observation in which we focused on the aspects concerning Telco, Cloud and Edge. Also see attachment. 1) The title of the document suggests a broad vision on digital infrastructures. The content of the document however limits digital infrastructure to physical infrastructure and digital control over these networks (NaaS).

Thank you for the opportunity to share our feedback. Multiple improvements and positive points to mention. Including a focus on demand side; important, though let's realize that it will take time to have the desired impact. Small question: I wonder how non-EU demand might be included in the methodology. Europe is famous for its high-tech equipment and materials.

Less focus on the % of manufacturing in Europe and more on 'Control Point': products by European companies based on European technology (and infrastructure and ecosystem of suppliers, etc.) that are indispensable in international value chains. We have two kinds of this: First, existing strengths, which can be in chip manufacturing but equally well in equipment (ASML) or materials (Soitec).

TNO herewith would like to provide additional contributions on the stated questions how to reduce delays and costs that affect housing supply and affordability and make some suggestions for increasing productivity in construction and renovation. Provide methods for a shorter, continues and predictable plan-phase in residential development projects (ref.

We welcome the proposal and acknowledgement of the role of semantic modelling. This provides an excellent foundation for semantic interoperability for DPPs. However, we do have a number of points of feedback based on TNOs experience with the creation and governance of Semantic models, and decentralized data sharing architectures. We are available to support resolving our feedback as well of course. 1.

TNO, the Dutch Research Technology Organisation, welcomes the development of the future European strategy for Research and Technology Infrastructures (TIs). We especially support the recommendations made by the Expert Group on TIs, particularly those regarding improved access to TIs for industry, especially SMEs.

TNO endorses the initiative of the European Commission to tackle microplastics that are unintentionally released in the environment. TNO also concurs with the European Commission Regulatory Scrutiny Board that there is still room for improvement on the report Impact assessment/ Measures to reduce the release of microplastics in the environment.

TNO Public 16 September 2026 Contact person: [email removed] Ref. Ares(2026)8797557 - 16/09/2026 www.tno.nl TNO welcomes the European Commission's initiative to develop sustainability criteria for plastic recycling technologies under the Packaging and Packaging Waste Regulation (PPWR).

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

TNO applauds the European Commissions efforts to improve the position of women in research, innovation and start-ups and welcomes the call for evidence to contribute feedback. At TNO, we work hard to create a work environment where every employee can flourish. An effective action plan from the European Commission to improve the position of women will boost our, and other organisations, ability to do so.

TNO welcomes the European Commissions ambition to address the challenges identified in this consultation and strongly supports the initiative to strengthen Europes leadership in advanced materials. Advanced materials are critical enablers of Europes green and digital transitions, industrial competitiveness, and strategic autonomy.

Quantum technologies are critical for Europes competitiveness and economic security. TNO highlights the risk of strategic dependencies on non-EU suppliers for key quantum devices, components, and materials. To address this, we recommend establishing an Economic Security Intelligence Taskforce for quantum technologies to monitor supply chains, leverage existing data sources, and provide actionable intelligence for…

TNO fully supports the initiative of the European Commission to revise the air quality rules, as announced in the European Green Deal and its zero-pollution ambition for a toxic-free environment. We have aligned our suggestions with the document DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on ambient air quality and cleaner air for Europe (26.10.2022 COM (2022) 542 final 2022/0347 (COD)); $ 2.4 preferred…

We strongly support this initiative on the provision of a common framework for calculating GHG emissions of transport operations in the freight and passenger transport sectors. At this moment the information on GHG emissions related to transport activity of passengers and freight is generally not shared with the users of transport, while there is strong evidence that carbon footprinting can lead to better decisions…

TNO welcomes the Commissions initiative to revise the definition of undertaking in difficulty (UID), as currently formulated in Article 2 (18) of the GBER, and the Rescue and Restructuring Guidelines. The current definition Unintentionally excludes innovative deeptech startups and scale-ups from access to EU state aid under the GBER safe harbour.

Filed in Dutch · English published by the European Commission

Thank you for the opportunity to provide feedback on the draft. We would like to draw your attention to a few specific comments regarding the icon showing that the appliance is compliant with the EU Code of Conduct for the interoperability of energy-smart appliances: We do not support this icon proposed for both space and water heaters.

Recent geopolitical and economic shifts underline the need for the EU to act with greater focus, confidence and foresight. Rather than trying to excel at everything, Europe can strengthen its longterm position by concentrating effort where it has the highest chances of success, building on existing strengths and values, flourishing our prosperity.