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
Academic / research · Netherlands · EU Transparency Register 40524063921-20
Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 126 think tanks and research institutions on this site, they rank #7 by legislative files engaged — a count of participation, not a measure of influence.
Declares membership of
- EARTO →
- Neth-ER
- EARPA
- EECARO
- EASTRO
- EDRIN
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Think tanks and research institutions
- Registered as
- Netherlands Organisation for Applied Scientific Research TNO (TNO)
- Head office
- Den Haag, Netherlands
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
TNO filed 12 positions between 29 Jun 2024 and 10 Jul 2026, across 12 of the 326 legislative files tracked here, attaching a full position paper 8 times.
What they argued
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).
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 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 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.
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.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.
- Commissariat à l'énergie atomique et aux énergies alternatives (CEA) · 6 files in common
- Confederation of Swedish Enterprise · 5 files in common
- German Association of Biotechnology Industries (DIB) within the German Chemical Industry Association - VCI · 5 files in common
- VTT Technical Research Centre of Finland · 5 files in common
- BEUC - The European Consumer Organisation · 4 files in common
Showing 5 of 191.
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Quotes are verbatim from submissions published by the European Commission, trimmed to their opening passage and never summarized by a model. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.