VNO-NCW (Confederation of Dutch Industry and Employers) and MKB-Nederland (Dutch Federation of Small and Medium-Sized Enterprises) are pleased to share their position paper presenting the Dutch business perspective on the EU Circular Economy Act (CEA).
VNM
VNO-NCW & MKB-Nederland
Industry association · Netherlands · EU Transparency Register 13255254129-80
7
positions filed
in the 326 files tracked
7
legislative files
of 326 tracked
7
with a full position paper
attached to a submission
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 1205 trade and business associations on this site, they rank #232 by legislative files engaged — a count of participation, not a measure of influence.
5.8
declared lobbying FTE
self-declared
€1M+
declared costs / yr (floor)
3
EP accreditations
as declared to the register
2010
in the register since
Declares membership of
- Lid van / Netwerken
- BUSINESSEUROPE →
- ICC
- BIAC/OECD
- EESC
Self-declared to the EU Transparency Register (snapshot 30 Aug 2026).
- Register category
- Trade and business associations
- Registered as
- Vereniging VNO-NCW (VNO-NCW)
- Head office
- Den Haag, Netherlands
- EU office
- Brussel
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
VNO-NCW & MKB-Nederland filed 7 positions between 30 Apr 2024 and 25 Jun 2026, across 7 of the 326 legislative files tracked here, attaching a full position paper 7 times.
2024 · 1 filed2025 · 1 filed2026 · 5 filed
What they argued
VNO-NCW and MKB-Nederland, representing businesses across all sectors of the Dutch economy, strongly welcome the fact that the European Commission is now explicitly considering legislative action in response to the consequences of the RAAP judgment (Case C-265/19).
VNO-NCW and MKB-Nederland welcome the opportunity to contribute to the public consultation on the Draft Commission guidance on the Cyber Resilience Act. As the leading employers' organisations in the Netherlands, we represent the interests of both large companies and small and medium-sized enterprises across all sectors of the Dutch economy.
VNO-NCW and MKB-Nederland welcome the Digital Fitness Check as a step to stress-test the efficiency and effectiveness of the cumulative Digital Rulebook1. We stress the importance of European legislators to continuously assess, now and in the future, the coherence, clarity, proportionality, enforceability and required implementation efforts of the cumulative rules of the Digital Rulebook to support EUs…
This paper presents the views of The Confederation of the Netherlands Industry and Employers (VNO NCW), representing 90 percent of the Dutch business community on the EU Economic Security Strategy and Economic Security Package.
Please find full reaction attached. Summary below: VNO-NCW and MKB-Nederland represent large companies and SMEs across all sectors of the Dutch economy, including the agrifood supply chain. Recent Dutch national implementation and EU evaluations show that while the Directive sets clear norms, its practical impact is limited by high reporting thresholds, divergent enforcement and insufficient comparable data.
Reform priorities (ranked) 1. Proxy advisers strengthening the SRD framework to improve accuracy, integrity, transparency, dialogue, and accountability. 2. Modernisation of company law by harmonisation maximum harmonisation of convocation period to 21 days for annual general meeting; 14 days for extraordinary general meeting; harmonisation by introducing legal right/statutory right to hold an exclusive…
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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.
- Confederation of Swedish Enterprise · 4 files in common
- Verband der Automobilindustrie e.V. · 4 files in common
- Bitkom e.V. · 3 files in common
- SMEunited · 3 files in common
- CLEPA European Association of Automotive Suppliers · 3 files in common
Showing 5 of 87.
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Everything on this page comes from VNO-NCW & MKB-Nederland’s own submissions to the European Commission — we have added nothing and interpreted nothing. If something is wrong or out of date, email info@policyspeak.com and we will correct it. If you are an individual named in a record, our privacy policy sets out your rights to correction, objection and removal.
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.