VDMA

E U R O P E A N O F F I C E A N D L E G A L D E PA R T M E N T FEEDBACK Feedback on the Commission proposal for a “EU Inc.” Registration number in the register of interest representatives: 976536291-45 June 2026 Mechanical and plant engineering is a key strategic industry for the EU economy. VDMA represents 3.500 German and European mechanical and plant engineering companies.

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

VDMA represents more than 3,600 companies of the machinery and equipment manufacturing industry in Europe and Germany. Please find below our non-exhaustive feedback in relation to the 28th regime EU corporate legal framework: VDMA welcomes in principle the idea of a 28th regime through the creation of a fundamentally uniform European company form.

VDMA represents 3,500 German and European mechanical and plant engineering companies. The industry stands for innovation, export-orientation and SMEs. The companies employ a total of around 3 million people in the 27 EU Member States, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries.

VDMA supports the objectives of the Environmental Delegated Acts but identifies substantial weaknesses in both the Circular Economy criteria (Annex II) and the DNSH requirements (Annex IV, Appendix C) that significantly limit practical applicability, legal certainty, and investment incentives for manufacturing companies.

The EU Taxonomy is a central instrument to guide sustainable investment and to define environmentally sustainable economic activities. The ongoing review of the Climate and Environmental Delegated Acts is therefore an important opportunity to further enhance the frameworks clarity, coherence and usability.

The machinery and plant engineering sector welcomes the European Commissions initiative to revise the technical screening criteria (TSC) under the EU Taxonomy. This revision is urgently needed because the current TSC disadvantages our industry.

VDMA represents 3500 German and European machinery companies. The industry stands for innovation, export orientation and SMEs. The companies employ a total of around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes the machinery sector the largest employer among the capital goods industries, both in the EU-27 and in Germany.

The VDMA represents 3600 German and European mechanical and plant engineering companies. The industry stands for innovation, export orientation and SMEs. The companies employ around 3 million people in the EU-27, more than 1.2 million of them in Germany alone. This makes mechanical and plant engineering the largest employer among the capital goods industries, both in the EU-27 and in Germany.

With this contribution the VDMA responds to the European Commissions Call for Evidence on the revision of the Renewable Energy Directive (RED IV). It welcomes the initiative to further develop the EU renewable energy framework in light of evolving climate, energy security, and competitiveness challenges, and underlines the importance of RED IV as a post2030 strategic framework.

Filed in German · English published by the European Commission

The VDMA welcomes the Commissions intention to revise the Climate Delegated Act and acknowledges certain positive developments, such as the recognition of energy efficiency services and the replacement of the benchmarking concept best available alternative with current state of the art.

The EU Taxonomy is a central instrument to guide sustainable investment and to define environmentally sustainable economic activities. The ongoing review of the Climate and Environmental Delegated Acts is therefore an important opportunity to further enhance the frameworks clarity, coherence and usability.

The machinery industry is driving innovation in its own products and in many strategic customer sectors. We welcome in principle the upcoming European Innovation Act and appreciate the opportunity to contribute to the Call of Evidence. To close the innovation gap, Europe´s industry needs urgently better framework conditions for innovation.

Stopping deforestation is an important goal. The path to achieve this goal should serve the goal itself and be as unbureaucratic as possible. Unfortunately, the Deforestation Regulation (EUDR) in its current form does not fulfill this requirement. The resources that companies currently have to spend on assessing their impact, developing and establishing processes are considerable.

VDMA Key Messages on the EU Environment Omnibus VDMA welcomes the European Commissions objective to reduce administrative burdens and improve regulatory coherence through the EU Environment Omnibus. For the mechanical and plant engineering sector, simplification and legal certainty are essential to enable investment, innovation and the transition towards climate neutrality and circularity.

On behalf of VDMA, we welcome the opportunity to contribute to the public consultation on the implementing act concerning the methodology for determining embedded emissions required for CBAM reporting. We strongly urge the swift adoption of this act by Q3 2025, alongside the remaining implementing legislation, as a matter of urgency. Please find our feedback in the attached document.

Essential requirements for DPP Service Providers from a Machinery and Equipment Manufacturer persepctive: 1. Data security and integrity: DPP service providers must adhere to strict data security standards to protect sensitive product information. This includes in particular; the use of the harmonised standards being currently created for the DPP system. 2.

VDMA represents >3,600 German and European companies in the mechanical and plant engineering sector. As an umbrella organisation of 36 specialised associations, VDMA covers the full value chain of the capital goods industryfrom components to complete systems, and from machinery to digital logistics.

With reference to the attached position paper, the VDMA takes a position on the discussion on the CO2 fleet limits for cars and light commercial vehicles and calls in particular for: 1. A timely discussion and presentation of a Commission proposal The ramp-up of electro-mobility in the EU lags behind political and industrial expectations.

Filed in German · English published by the European Commission

VDMA, the European machinery association, calls for an ambitious and far-reaching Digital Fitness Check. The Omnibus initiatives have streamlined certain details but have fallen short of addressing the lack of consistency and assessing the cumulative overall impact of the digital acquis. There is a need for general alignment of definitions and provisions across all legal acts.

Please find attached the VDMA Power Systems position paper on the revision of the Network Code Requirements for Generators (NC RfG 2.0). The paper Consolidates the contributions of the participating manufacturers and outlines the key industry recommendations regarding harmonisation, implementation timelines, grid-forming requirements, certification, compliance procedures and technology-neutral grid connection…

Filed in German · English published by the European Commission

VDMA welcomes the opportunity to comment on the Omnibus proposals COM(2025)503 and COM(2025)504 and would like to address the element for Common Specifications only. In light of the increasing European Commissions intention to use Common Specifications (CS) as a regulatory fallback mechanism to harmonised European Standards (hEN) within the European Single Market, and their embedding in both new and revised legal…

VDMA welcomes the opportunity to comment on the Omnibus proposals COM(2025)503 and COM(2025)504 and would like to address the element for Common Specifications only. In light of the increasing European Commissions intention to use Common Specifications (CS) as a regulatory fallback mechanism to harmonised European Standards (hEN) within the European Single Market, and their embedding in both new and revised legal…

VDMA Statement on ESPR Public Consultation: Concerns Regarding Article 4 Verification Obligations for Discarded Unsold Consumer Products As the representative voice of the mechanical engineering industry in Europe, the VDMA welcomes the overarching aims of the Ecodesign for Sustainable Products Regulation (ESPR) to enhance sustainability, promote circularity, and reduce environmental impact.

VDMA feedback on European Commissions draft Implementing Regulation laying down rules for the application of Regulation (EU) 2023/1542 of the European Parliament and of the Council as regards format and harmonised specifications for certain labelling requirements.

VDMA represents around 3,500 member companies of the mechanical and plant engineering industry in Germany and Europe. As many machinery manufacturers rely on globally integrated supply chains and import CBAM-covered materials and components, the practical implementation of CBAM is of significant importance to our industry.

Ladies and gentlemen, the Omnibus package (Omnibus IV) is part of the European Commission’s current efforts to step up efforts to reduce red tape. Omnibus IV focuses on various proposals aimed, inter alia, at reducing the red tape of existing EU legislation. In the context of Omnibus IV, targeted amendments to specific legal acts are expected to bring about tangible reductions in red tape.

Filed in German · English published by the European Commission

The PED was first published in 1997 as 97/23/EC, and its technical content has remained largely unchanged since then, Hence, much of its content is more than 25 years old, so one can certainly find a significant number of reasons that might speak for a revision: 1. It would give the opportunity to - where appropriate - address recent technical developments more specifically and precisely, such as e.g.

Both the Pressure Equipment Directive and the Simple Pressure Vessels Directive have proven valuable and reliable legislation supporting European companies coping with their business challenges. Any change of the Directives would create questions within their daily business. Therefore, I strongly recommend to leave the Directives unchanged except legal or formal adaptions if necessary.

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, is supportive of the Commissions 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 1024/2012/EU.

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, is very critical towards the White Paper of the Commission on Dual Use: Below you will be able to find our non-exhaustive feedback: - VDMA reaffirms its fundamental critical stance towards the EU harmonization of export controls.