VDMA

The VDMA welcomes the harmonisation of packaging reporting envisaged in the draft Implementing Regulation. A uniform, interoperable and machine-readable format across the EU can significantly facilitate the practical implementation of extended producer responsibility (EPR). However, harmonisation must result in genuine simplification and must not create additional data collection or documentation requirements.

VDMA welcomes in principle the Digital Omnibus proposals of the EU-Commission as the first small step in the right direction. However, the proposed changes to the AI Act are not enough to keep the promises of the EU´s simplification agenda.

VDMA welcomes in principle the Digital Omnibus proposals of the EU-Commission as the first small step in the right direction: It is positive that three of the most burdensome pieces of Digital legislation are addressed (Data Act, GDPR, AI). However, the proposed changes are not enough to keep the promises of the EU´s simplification agenda.

VDMA welcomes the European Commission's plan to simplify digital regulations with a Digital Omnibus. The EU´s acquis for digital regulation is, together with other regulations, increasingly becoming a burden for innovation and competitiveness, outweighing the benefits.

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 welcomes the objectives of the proposed EU Packaging Regulation and the change from a directive to a regulation. EU-wide harmonised and thus uniform packaging law requirements contribute significantly to a sustainable circular economy and the efficient functioning of the EU internal market.

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 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.

We welcome that the EU Commission has recognised the strategic importance of raw materials and is acting. However, in particular articles 27 and 28 on the recycling of permanent magnets should be considered for closer analysis and for changes. VDMA represents 3,600 German and European machinery and equipment manufacturing companies. The industry stands for innovation, export orientation and SMEs.

The VDMA acknowledges that the Commission has improved the draft in several respects compared to EFRAGs technical advice. Notable adjustments include clarifications on user needs, selected structural improvements to the materiality assessment, and the extension of certain reliefs.

The Mechanical Engineering Industry Association (VDMA) appreciates the opportunity to provide feedback to the consultation on the proposal for the Artificial Intelligence Act. For our companies, AI is a key technology for competitiveness and sustainability. Our export-oriented sector brings production equipment with embedded AI to a variety of industrial customers in EU and worldwide.

VDMA (German Mechanical Engineering Industry Association) welcomes the opportunity to provide feedback to the Inception Impact Assessment of the European Commission for a proposal for a legal act of the European Parliament and the Council laying down requirements for Artificial Intelligence. AI will be a core enabling technology for many sectors of European industry. Therefore, VDMA supports an European approach.

VDMA represents over 3.400 mechanical engineering companies in Germany and Europe. The industry stands for innovation, export orientation, medium-sized businesses and employs around four million people in Europe, of which more than 1 million are employed in Germany alone. With around 90.000 companies, the mechanical engineering is one of the largest industries in the EU economy.

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.

CO2 pricing as leverage A comprehensive energy system transformation cannot be financed solely from the electricity sector. A viable and coherent concept must be developed in which tax, levy and contribution systems do not represent an additional burden in the conversion of energy forms.

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.

VDMA represents more than 3,400 German and European companies of the mechanical engineering industry. The industry stands for innovation, export orientation and medium-sized businesses. Our companies are solution providers for digital manufacturing and are core enablers for Industry 4.0.

The German Mechanical Engineering Industry Association (VDMA) represents over 3.300 mechanical engineering companies in Germany and Europe. Our companies are solution providers for digital manufacturing and are core enablers for Industry 4.0. Consequently, the exchange and usage of industrial data is of high importance for the innovation capacity and global competitiveness of our member companies.

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.

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.

The German Mechanical Engineering Industry Association (VDMA) represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of EUR 230 billion (2019), the sector is the largest industrial employer and one of Germany’s leading sectors of industry overall.

The German Mechanical Engineering Industry Association (VDMA) represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe. With around 1,3 million employees in Germany and a turnover of EUR 230 billion (2019), the sector is the largest industrial employer and one of Germany’s leading sectors of industry overall.

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.

Comments of the VDMA Compressed air technology department and the Air-Handling Technology Department for the Proposal for a regulation on fluorinated greenhouse gases, amending Directive (EU) 2019/1937 and repealing Regulation (EU) No 517/2014 (2022/0099 (COD)) Compressors, Compressed Airand Vacuum Technology Date: 22.06.2022 Air-Handling Technology Our compressed air industry as well as the Air-Handling industry…

Filed in German · English published by the European Commission

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

The VDMA welcomes this opportunity to comment on the EU Commission's proposal to revise the Non-Financial Reporting Directive (NFRD) - in the future called CSR Directive (CSRD). CSR reporting is becoming increasingly important for companies in the mechanical and plant engineering sector, as they are continuously developing sustainable products and production technologies.

EU Chips Act 2.0: VDMA recommendations for efficient implementation and international cooperation September 2026 The VDMA represents 3500 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.

The VDMA represents 3,600 mechanical and plant engineering companies in Europe, employing around three million people in the EU. The EU Chips Act 1.0 aimed to strengthen Europes semiconductor value chain with 43 billion in funding but benefits for the machinery and equipment sector have been limited.

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.

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.

The EU's climate targets are the most ambitious in the world. To achieve the 2030 and 2050 objectives, all possible technological solutions must be used – this includes electric mobility as well as efuels and hydrogen.

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

The VDMA rejects the proposal published by the EU Commission in the present version for a regulation on preventing plastic pellet losses to reduce microplastic pollution for the following reasons. The companies concerned are already applying extensive measures to prevent the release of plastic pellets. A current study confirms low overall releases of plastic granulate into the environment.

VDMA The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

We welcome the development of sustainability criteria for plastic recycling technologies. The machinery and equipment manufacturing industry provides the technologies and equipment that enable efficient plastics recycling and processing. The regulatory framework should therefore support technological innovation and investment rather than prescribe specific recycling processes. Our recommendations 1.

We welcome the Commissions initiative to establish harmonised rules for the calculation and verification of recycled plastic content. A simple, reliable and EU-wide methodology is essential to provide legal certainty and a level playing field. The machinery and equipment manufacturing industry is an important part of the plastics value chain.

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents more than 3.300 member companies in the SME-dominated mechanical engineering industry in Germany and Europe.

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.

The VDMA represents 3.600 German and European mechanical and plant engineering companies. The industry stands for innovation, export-orientation and medium-sized companies. The VDMA believes that the EU Internal Market is one of the biggest achievements of the EU. Especially in the small and medium-sized mechanical and plant engineering sector, the close integration within the EU is evident.

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.

VDMA, the German Mechanical Engineering Association, appreciates the opportunity to comment on the legislative proposal for a directive on measures for a high common level of cybersecurity across the Union. As producers of connected and digitized machines and industrial equipment, our sector is one of the drivers of Industrie 4.0.

VDMA answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC Both the recent publication of the Evaluation report and the Communication on AI respectively underline that the Machinery Directive is fit for purpose and that the EU safety framework is robust enough to provide for machines embedding AI-driven functions.

We support the development of clear and reliable conditions for the import of recycled plastics and products containing recycled plastic from third countries. For European industry, it is essential that imported recycled materials are subject to requirements that provide a genuine level playing field with recycled materials produced in the EU. Our recommendations 1.

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

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. The VDMA represents around 3300 German and European companies in the mechanical engineering industry.

VDMA expressly supports the efforts of the EU Commission to further improve air quality in the EU. Updating the EU air quality directives makes sense but must be carried out with the appropriate sense of proportion. Within the framework of this position paper, we have outlined various aspects and issues that must definitely be taken into account when drafting the legislative text.

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…

The VDMA represents more than 3,500 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.

Below you can find our non-exhaustive feedback to the proposal from September 2022 for a Directive on liability for defective products: VDMA is sceptical of the definition of products - as foreseen in Article 4 - to explicitly include digital manufacturing files and software. The definition of digital manufacturing files is vague and the term software has to be differentiated.

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.

The Mechanical Engineering Industry Association (VDMA) represents over 3.300 mechanical engineering companies in Germany and Europe. The industry stands for innovation, export orientation, medium-sized businesses and employs around 4 million people in Europe, of which more than 1 million are employed in Germany alone.

The German Mechanical Engineering Industry Association (VDMA) is in favour of the European Commission taking a closer look at subsidies from third countries. These subsidies distort production costs and influence competition in the EU’s Internal Market. They create thus disadvantages for European market players in the mechanical engineering 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.

The Mechanical Engineering Industry Association (VDMA) is in principle supporting the proposed „Anti-Coercion Instrument“ (ACI) of the EU under the condition, that this ACI is an integrative part of and coordinated with further EU legislative and non-legislative action to deter and counter foreign economic coercion.

The German Mechanical Engineering Industry Association (VDMA) is in principle in favour of the EU adopting an EU legal instrument to deter and counteract coercive actions by third countries. Coercive economic actions of third countries are fundamentally unacceptable for the SME-dominated German mechanical engineering sector.

VDMA, which represents more than 3,600 German and European mechanical and plant engineering companies, is critical towards the proposal of the Commission for a new Regulation on the screening of foreign investments.

VDMA represents 3,600 German and European machinery and equipment manufacturing companies. The industry stands for innovation, export orientation and SMEs. Below you will be able to find our non-exhaustive feedback: - VDMA believes that foreign direct investments are beneficial to the EU and its Member States, as they support the economy, employment and competitiveness in the EU.

The Mechanical Engineering Industry Association (VDMA) represents over 3.500 mechanical engineering companies in Germany and Europe. Below you will be able to find the non-exhaustive feedback of VDMA to the Commission proposal of 19 September 2022 for a Regulation establishing a Single Market Emergency Instrument and repealing Council Regulation 2679/98/EC: VDMA welcomes the provisions proposed in Articles 16 and…

VDMA represents more than 3,400 European companies of the mechanical engineering industry which stands for innovation, export orientation and SMEs. The EU Single Market is key for the competitveness of our companies an we support the EU-Commission’s plans to improve its resilience.

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.

• We welcome the initiative to achieve a single market for mobile machinery. • There exist a strong need for a legislation for road circulation harmonisation that takes into account the complexity of existing technical requirements, including from occupational safety, and sector specific requirements.

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.

Below you can find the non-exhaustive feedback of the Mechanical Engineering Industry Association (VDMA) to the combined Evaluation Roadmap and Inception Impact Assessment of the European Commission for the amendment of the Blocking Statute. Economic coercion by third countries against EU companies is a strongly growing problem.