VNO-NCW & MKB-Nederland

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).

VNO-NCW and MKB-Nederland support the Commission’s objective to improve waste management by reducing waste generation and mixed waste, and increasing preparation for re-use or recycling of waste by improving separate collection. Therefore we support revision of the Waste Framework Directive by introducing measures that can create a European market for secondary raw materials.

I. Basic approach of business - Problems related to ESG occurring in supply chains need to be addressed. Building on the experience with the UN Guiding Principles and the OECD MNE Guidelines, an additional substantial step forward in the field of due diligence should be taken.

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).

We welcome the upcoming Cyber Resilience Act as horizontal legislation addressing all relevant aspects of the cybersecurity of digital products and services. We support the introduction of mandatory horizontal cyber security requirements for all forms of ICT products, services and processes, regardless of whether they are linked to a physical product and regardless of the target group.

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

The Dutch business community embraces the simplifications introduced by the European Commission in the proposal for the New UCC. Based on a data-led approach the reform can reduce cumbersome customs procedures, reducing 27 systems to just one harmonized model.

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…

VNO-NCW and MKB-Nederland support the efforts of the European Commission to increase cyber resilience. We believe that cybersecurity requires European coordination and alignment, given the strong interdependencies. The rapidly increasing threats posed by digitization justify this revision of the NIS directive. We regard the proposals on more European cooperation and information exchange as positive.

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…

Input Call for evidence – DG Connect I.2 Copyright September 22, 2022 The Commission is considering an initiative that would introduce rules for third country nationals, whether natural or legal persons, by amending the article 8 (2) of the Directive 2006/115/EC on rental and lending rights (RLR directive). We fully support this initiative and hope for rapid implementation.

The EU should give direction to social policy not by taking away responsibilities from Member States but by supporting and complementing Member States to act in the field of social policy. The Treaty clearly defines which areas of social policy fall under qualified majority voting and which areas fall under unamity (core pillars of national socio-economic systems; they are related to how Member States define the…