Wirtschaftskammer Österreich

Dear Sir, Madam, The Austrian Federal Economic Chamber (WKO) would like to thank you for the possibility of submitting a draft implementing regulation on Article 44(2) of Regulation (EU) 2025/40 (PPWR) regarding the format for registration and notifications in the register of producers and the information to be provided in this context, and requests that the comments set out in the Annex be taken into account.

Filed in German · English published by the European Commission

With reference to the Call for Evidence regarding the Digital Omnibus published by the European Commission, the Austrian Federal Economic Chamber would like to communicate a number of initial thoughts and considerations regarding the three general topics addressed there, without prejudice to a more clear-cut response that may result from an analysis of a future document by the European Commissions that may contain…

18 May 2026 Position on the Industrial Accelerator Act Austrian Federal Economic Chamber (WKÖ) The following sets out the WKÖ’s assessment of the Commission’s proposal for the Industrial Accelerator Act (IAA) and the resulting policy positions for the further drafting of the legislation. The WKÖ’s policy positions are set out in detail below: 1.

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

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich/WKÖ) supports the goal of European climate policy to achieve greenhouse gas neutrality by 2050. The economy can make a significant contribution, but it needs a fair, plannable, and competitive legal framework in order to continue to implement investments in Europe.

The Austrian Chamber of Commerce welcomes the initiative to simplify EU rules on medical devices and in vitro diagnostic medical devices. The implementation of the MDR and IVDR has led to high requirements for all economic operators. There has been a huge increase in both the bureaucratic and financial burden on entrepreneurs. In general, the requirements are very complex and require a high level of expertise.

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The Austrian Chamber of Commerce welcomes the objective of the proposal for a Digital Networks Regulation [COM (2026) 16 final] to modernise, simplify and harmonise the rules on connectivity networks, as partly already expressed in the Draghi report.

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The Austrian Federal Economic Chamber would like to thank you for the opportunity to comment on the draft Regulation of the European Parliament and of the Council on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repealing Directive 94/62/EC. Please find attached a detailed opinion on the proposal. Yours sincerely, [name removed]

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WKÖ comment Kommentar zu Inception Impact Assessment „Review of the requirements for packaging and other measures to prevent packaging waste“ Die Wirtschaftskammer Österreich bedankt sich für die Gelegenheit zur Initiative „Überprüfung der Anforderungen Verpackungen und andere Maßnahmen zur Verhinderung Verpackungsabfälle“ Stellung zu nehmen.

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

WIRTSCHAFTSKAMMER ÖSTERREICH Bundesministerium für Justiz z.H. LStA Dr. [name removed], LL.M. [address removed] Abteilung für Rechtspolitik Wiedner Hauptstraße 63 | 1045 Wien T 05 90 900 DW E [email removed] W wko.at/rp per E-Mail: [email removed] [email removed] Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum Z10.200 – 2026-0.245.550 - Rp 50.6.12/2026/AS/CG Dr.

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

WIRTSCHAFTSKAMMER ÖSTERREICH Europäische Kommission Generaldirektion Justiz und Verbraucher Abteilung für Rechtspolitik Wiedner Hauptstraße 63 | 1045 Wien T 05 90 900DW E [email removed] W wko.at/rp Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum Ares(2025)5502931 8.7.2025 Rp 50.6.12/2025/AS/CG Dr.

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

This draft amendment to Delegated Act (EU) 2021/2486 is an important and necessary step to improve the practical applicability of the EU Taxonomy. Businesses urgently need tangible and practical simplifications. The following feedback is intended to provide further suggestions for improvements to simplify the EU Taxonomy Regulation in practice.

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The Austrian Federal Economic Chamber (WKÖ) welcomes the European Commission's initiative to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy. The criteria of the delegated acts must be revised for their practicality and, above all, their feasibility coherence between the EU Taxonomy and other legislation.

The Austrian Federal Economic Chamber (WKÖ) welcomes the European Commission's initiative to improve the clarity, usability, legal certainty, and cost-effectiveness of the EU Taxonomy. The criteria of the delegated acts must be revised for their practicality and, above all, their feasibility coherence between the EU Taxonomy and other legislation.

The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative to revise the Energy Performance of Buildings Directive (EPBD). It is a necessary step towards contributing to achieving the goals of the European Green Deal. Investment in buildings can provide a boost to businesses. In the light of the COVID-19 pandemic, this will be a necessary driver for the economy and central to the EU’s green recovery.

Strengthening Europes competitiveness must be at the core of the next Multiannual Financial Framework (MFF 20282034). The global economic environment is rapidly changing: the United States and China are deploying massive industrial and technological investment programmes, while Europe faces slower growth, higher regulatory costs, and fragmented capital markets.

The Austrian Economic Chamber welcomes in principle the European Commission’s objectives under the Pharmaceutical Strategy and sees them as an opportunity to strengthen the pharmaceutical base in Austria and Europe.

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Dear Sir, Madam, The Austrian Federal Economic Chamber, Reg. No 10405322962-08, has drawn up the attached opinion on the Revised European sustainability reporting standards (ESRS) initiative. This was uploaded due to the limited number of characters in the feedback field in the Annex. Best regards, Dr [name removed], Head of Department

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WKÖ-Position Paper on the Regulatory Framework for Artificial Intelligence Technological development is progressing and AI applications are becoming increasingly diverse, so their own uniform rules are to be welcomed in principle. In order to guarantee a level playing field, each AI system in the internal market must comply with the same requirements.

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WKO Austria welcomes the opportunity to provide input to the Commission’s Inception Impact Assessment for the upcoming legislative framework on AI. We strongly believe, that it is very important to secure a future-proof framework that will support an innovative and competitive European market, and also too much complexity and over-regulation should be avoided.

The Austrian Federal Economic Chamber would like to thank you for the opportunity to comment on the ongoing initiative of the EC to revise the Waste Framework Directive based on the requirements of the European Green Deal and the circular economy strategy with the objectives — reduction of the Waste generation, i.e.

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In the light of the upcoming review of the Geo-blocking Regulation, it is particularly important to stress that the single market is based on four freedoms, which are intended to enable market participants to make use of it, but there is no obligation to make use of these freedoms.

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The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication. 99,6% of our members are SME.

WKO Position Paper Short Summary - Proposal for a Green Claims Directive: less restrictions for the benefit of consumer orientation more exemptions and support for SMEs, implementation leeway needed substantiation to be simplified radically verification and authority-OK to be deleted national, regional and private labels to be exempted from verification in any case.

• In general: EU framework for methodology on PEF and OEF on voluntary basis in a harmonised matter may be useful – mandatory system not first choice, different P(O)EFCRs in Member States to be avoided – therefore WKO proposing to consider option 1 (update of PEFs and OEFs) or 2 (voluntary legal framework), currently not option 3 (legal framework establishing obligation for claims by PEF/OEF) because of costs and…

Europäische Kommission Directorate General - Communication [name removed] auf Have-Your-Say Homepage Abteilung für Umwelt- und Energiepolitik Wiedner Hauptstraße 63 | 1045 Wien T 05 90 900-DW | F 05 90 900-269 E [email removed] W wko.at/up Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum Ares(2025)6054791 WKO/HP/STN/CCF Mag. Dr.

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 WKÖ supports and commits to the objective of climate neutrality by 2050. A concrete set of measures is now needed to support a sustainable, green transition in the EU in line with a new growth strategy. The WKÖ advocates legislation that meets the requirements of effective climate protection while being practicable and compatible with economic prosperity.

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The Austrian Federal Economic Chamber, Wiedner [address removed], Austria, is registered with the number 10405322962-08 in the Transparency Register of the European Parliament and the European Commission. Feedback on the Sustainable products initiative November 2, 2020 The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian companies –…

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

Currently, the EU protects its sites from carbon leakage through free allowances under the EU Emissions Trading Scheme (EU ETS). The European Commission is now proposing to phase out free alowances and replace them with a Carbon Border Adjustment Mechanism (CBAM). However, in its present form such a "climate tariff" does not offer equivalent protection against delocalisaitons.

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich, WKÖ) supports the goal of the European Climate Policy to attain climate neutrality by 2050. Given the massive negative repercussions of the current COVID-19 pandemic on the European population, business and industry, all relevant considerations, measures and instruments – including preparations for a possible Carbon Border Adjustment Mechanism…

Vorschlag für eine Verordnung des Europäischen Parlaments und des Rates zur Schaffung eines Rahmens für Maßnahmen zur Stärkung der Biotechnologie und der Bioproduktion in der Union, insbesondere im Bereich der Gesundheit, und zur Änderung der Verordnungen (EG) Nr. 178/2002, (EG) Nr. 1394/2007, (EU) Nr.

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)

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

The Austrian Federal Economic Chamber (Wirtschaftskammer Österreich/WKÖ) supports the goal of European climate policy to achieve greenhouse gas neutrality by 2050. The economy can make a significant contribution, but it needs a fair, plannable, and competitive legal framework in order to continue to implement investments in Europe.

If the EU unilaterally tightens up climate and energy policy targets, significantly strengthened protection measures for Industry are needed, because their pressure to shift is growing due to increasing energy and climate costs. Expanding the ETS as guidance instrument for investment in the location and the climate protection is necessary.

The Austrian Chamber of Commerce welcomes the objectives of simplification, increased legal certainty and harmonisation of key provisions of the EU Cybersecurity Package (CSA 2 and amendment NIS 2) – the current proposal offers some opportunities to update the cybersecurity framework of the European Union. In particular, attempts to narrow down the scope of the relevant rules in a targeted manner seem promising.

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final 18. August 2025 Ref. Ares(2025)6713005 - 19/08/2025 Carbon Leakage bei CBAM (und ETS 1 Gratiszuteilungen) Schwerpunkte: Exportregelung, downstream Produkte und Gratiszuteilung A) Ausgangslage Die EU-KOM plant nach den CBAM-Vereinfachungen mit dem – von der Industrie begrüßten „Omnibus Vorschlag“ weitreichende Reformen für den Carbon Border Adjustment Mechanism (CBAM) und für den EU-Emissionshandel 1 (ETS 1).

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

Key positions by the Austrian Federal Economic Chamber There are several issues of concern that require further clarifications. 1. Scope (Article 2) The proposal presented by the Commission, while excluding some products that are covered by the current CPR, seeks to extend the scope of the current Regulation to include families of products which currently are not considered as construction products (3D-datasets…

The CPR has created a single european market for construction products for the benefit of all manufacturers in the member states During the last years we have seen problems for EK and CEN to develop and publish hENs in a technical proper and judical correct way in due time. Out of these reasons we are aware, that CPR needs a revision.

Introduction of new hazard classes: We do not support the unilateral introduction of new hazard classes (PMT, vPvM and ED) by the EU. Such hazard classes should first be negotiated at UN level and included in the GHS in order to ensure global harmonisation. The EU has already been at the forefront of the implementation of the existing GHS.

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Dear Sir/Madam, please find enclosed the feedback from the Austrian Economic Chamber. [complimentary close] From: Dr [name removed] Head of Unit Department of Finance and Taxation Policy Austrian Chamber of Commerce Wiedner Hauptstrasse 63 I 1045 Vienna T [phone removed] I F [phone removed] E [email removed] I W https://news.wko.at/fp

Filed in German · English published by the European Commission

Dear Sir/Madam, please find enclosed the feedback from the Austrian Economic Chamber. Yours faithfully, Dr [name removed] and Fiscal Policy Wirtschaftskammer Österreich Wiedner Hauptstraße 63 I 1045 Vienna T [phone removed] I F [phone removed] E  [email removed] I W https ://news.wko.at/fp

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This draft amendment to Delegated Act (EU) 2021/2139 supports the Commission’s objective of improving the usability and consistency of the EU Taxonomy criteria. For this reason, the revision of the DNSH criteria is in principle welcomed. Businesses urgently need tangible and practical simplifications.

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The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents all Austrian businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication. 99,6% of our members are SME.

Ref. Ares(2021)4153008 The Austrian Federal Economic Chamber is the legal representative of the entire Austrian business community and represents - 25/06/2021 all Austrian companies – some 540,000 businesses drawn from the areas of Crafts and Trade, Industry, Commerce, Banking and Insurance, Information and Consultancy, Tourism and Leisure, Transportation and Communication.

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)

We would like to share some specific reflections on specific issues raised in the White Paper COM(2024) 81 final: In our view, it is essential that all sub-sectors of the electronic communications sector are examined for actual adaptation, in compliance with the principles of subsidiarity and proportionality.

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The Austrian Federal Economic Chamber welcomes the opportunity to contribute to the evaluation of the Single-Use Plastics Directive. The Single-Use Plastics Directive and its implementation into national law pose challenges for producers, retailers, and the food services industry.

Austrian Economic Chamber (WKÖ): The WKÖ is the legal representative of some 540,000 Austrian companies in the industrial, commercial, commercial, transport, banking & insurance, tourism and services sectors. In principle, the Austrian Federal Economic Chamber supports the European Commission’s efforts to restore degraded semi-natural habitats in their networked functionality.

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Industry supports the objective of protecting, promoting and using its components in a sustainable manner. Clear objectives, (economic) measures, coherent instruments and reliable long-term development of a regulatory framework are essential to ensure competitiveness and the European business location. Many factors influence biodiversity loss.

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From the perspective of the Austrian Federal Economic Chamber (WKO), the proposed 90% target for 2040 would represent an abrupt and disproportionate reduction step between 2030 and 2040, which is neither economically viable nor technically justified. Therefore, the 90% target for 2040 is not supported.

WKO, the Austrian Federal Economic Chamber, is still in the process of developing a compre-hensive position regarding the legislative proposal COM(2022) 156 final for amending the IED. As from our point of view the legislative proposal contains quite some problematic provisions, for now we would just like to provide feedback in form of a catalogue of questions – which we hope the European Commission can both answer…

Feedback to the Inception Impact Assessment (IIA) of the Revision of the IED published by DG ENV on 26 March 2020 The IIA refers to an evaluation of IED according to which in the following areas the operation of the legislative framework might be improved: 1) There may be sectors outside the IED scope that cause high pollution and for which the IED could be an appropriate policy instrument 2) Comparability of Member…

Austrian Federal Economic Chamber Abteilung für Finanz- und Handelspolitik Wiedner Hauptstr. 63 | Postfach A-1045 Wien T [phone removed]DW | F [phone removed] E [email removed] W http://wko.at To European Commission DG FISMA Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum FHP/Mag.

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

Austrian Federal Economic Chamber Abteilung für Finanz- und Handelspolitik Wiedner Hauptstr. 63 | Postfach A-1045 Wien T [phone removed]DW | F [phone removed] E [email removed] W http://wko.at To European Commission DG FISMA Ihr Zeichen, Ihre Nachricht vom Unser Zeichen, Sachbearbeiter Durchwahl Datum FHP/Mag.

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

ÖFFENTLICHE KONSULTATION ZUR SKILLS PORTABILITY INITIATIVE RÜCKMELDUNG DER WIRTSCHAFTSKAMMER ÖSTERREICH / AUSTRIAN FEDERAL ECONOMIC CHAMBER Februar 2026 MAßNAHME 1 Portabilität von Kompetenzen, Maßnahme 1 – Förderung der Arbeitskräftemobilität in der gesamten EU durch verbesserte Transparenz bei Kompetenzen und durch Digitalisierung Die grenzüberschreitende Übertragbarkeit von Berufsbildungsabschlüssen bleibt eine…

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

The Austrian Chamber of Commerce expresses its gratitude for the opportunity to comment on the initiative “Modernisation of the EU rules on batteries”. • Concerning sustainability and competitiveness in the management of waste batteries is to be welcomed • The intended strengthening of secondary raw materials markets is also positive.

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The Austrian Chamber of Commerce (Wirtschaftskammer Österreich) is the legal representative of the whole Austrian economy and represents all Austrian companies — around 540.000 businesses in the areas of crafts and trades, industry, commerce, banking and insurance, information and advice, tourism and leisure, transport and communication. 99.6 % of our members are SMEs with fewer than 10 employees. I.

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o We generally agree with the overall aim of the European Commission´s Roadmap and especially regarding the reduction of transaction costs for data access, sharing and reuse for research and innovation activities. At the moment many Companies cannot access the data they need and they often face strict limitations when they want to (re-)use data.

The Austrian Federal Economic Chamber (WKO) welcomes the simplifications to environmental management systems (EMS) under the Industrial Emissions Directive (IED), the deletion of the Substances of Concern In Products (SCIP) database, the Extended Producer Responsibility (EPR) authorized representative shift in waste dossiers, and sensible adjustments in the area of environmental impact assessment (EIA) approvals.

As early as 2017, it became clear that the availability of the main F-gases in the internal market will be limited. Prices were exploded and supply could no longer be guaranteed for many applications. Only between March and October 2017 did the prices of common refrigerants in Central Europe increase by ~750 %. This trend continued until 2018 and then stabilised.

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Proposal for a Corporate Sustainability Reporting Directive amending Directive 2013/34/EU, Directive 2004/109/EC, Directive 2006/43/EC and Regulation (EU) No 537/2014, as regards corporate sustainability reporting 24.06.2021 The Austrian Federal Economic Chamber (WKÖ) is the legal representative of the entire Austrian business community and represents all Austrian companies – some 540,000 businesses drawn from the…

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

WKO supports the Commissions ambition to catalyze private investment in nature-friendly measures, but the current roadmap is not yet an economically viable or trustworthy basis for business action. Only once legal clarity, binding and robust certification/monitoring, simple digital assessment tools, and market-wide integration deliver tangible economic benefits should a Nature Credits market be advanced; until then…

Europäische Kommission Directorate‑General for Communications Networks, Content and Technology / Unit C3 “Microelectronics and Photonics” Abteilung Innovation und Digitalisierung Wiedner Hauptstraße 63 I 1045 Wien T [phone removed] E [email removed] Unser Zeichen Durchwahl Datum InDi/2026/FS [name removed], MSc 3164 10.09.2026 Stellungnahme zum Chips Act 2.0 Europäischen Kommission Sehr geehrte Damen und Herren, die…

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

The WKÖ welcomes this initiative. From the proposal, a clear paradigm shift of the Commission can be seen - away from a primarily regulation-driven policy of green change towards a green industrial policy that carries a business-friendly note in terms of location and competition policy. The EC is thus taking a long overdue step towards a coherent, effective, and targeted European industrial policy.

Communication in the supply chain: The current system should become more efficient. The interface with worker protection needs to be improved. The quality and availability of SGMs has improved significantly in recent years. We therefore do not see a need for more information, but rather simplification. Authorisation: This is a major challenge for our businesses.

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The Austrian Chamber of Commerce recognises the European Commission’s objectives to strengthen cyber resilience, as a cybersecurity incident can undoubtedly lead to enormous financial burdens due to business disruption (e.g. due to a ransomware attack), reputational damage to businesses and a threat to the security of our economy and society.

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The following measures on “perishable housing” are proposed: 1. Non-profit housing/non-speculative/self-use dwellings built by non-profit housing associations are not speculative or investment objects. We therefore suggest clarifying the interpretative leeway for the sale of freely funded dwellings: There should be a clear focus on the owner-occupation of the dwelling. Any other type of use (e.g.

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WKO reply to the Call for Evidence for the revision of Regulation 1025/2012 on European standardisation July 2025 The Austrian Economic Chamber, WKO, welcomes the opportunity to provide feedback to the call for evidence for the revision of Regulation 1025/2012 on European standardisation (from here on “The Regulation”). European standards play a crucial role in advancing strategic priorities.

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

The WKÖ supports the European simplification package in principle, but calls for a comprehensive approach: Housing is set to become cheaper and faster through digital and streamlined procedures, faster permitting, less duplication, proportionate energy and environmental requirements, mobilisation of the building stock, and better financing conditions.

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The WKÖ supports the European simplification package in principle, but calls for a comprehensive approach: Housing is set to become cheaper and faster through digital and streamlined procedures, faster permitting, less duplication, proportionate energy and environmental requirements, mobilisation of the building stock, and better financing conditions.

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In the paper attached, we want to touch upon the following aspects in relation to the unintentional release of microplastics: - Concerning the policy options for plastic pellet loss - Measures of the Austrian plastics industry to reduce the amount of plastic pellet losses to the environment - Microplastic release from textile sources - Microplastics in other industries

The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative of the European Commission to review the legislative framework in order to design competitive decarbonised gas markets as a means to facilitate the gas sector’s contribution to the overall energy system decarbonisation.

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

Dear Sir, Madam, The Austrian Federal Economic Chamber (WKO) thanks the initiative entitled ‘Harmonising the rules for calculating and verifying recycled content in plastic packaging’ for the opportunity to comment and requests that the opinion in the Annex be taken into account.

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WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

Von Wirtschaftskammer Österreich Bundessparte Industrie An Europäische Kommission GD ENER – Referat C2 Ihr Zeichen, Ihre Nachricht vom Sparte Industrie Wirtschaftskammer Österreich Wiedner Hauptstraße 63 | Postfach 330 1045 Wien T [phone removed] E [email removed] W wko.at/industrie Unser Zeichen/Sachbearbeiter Durchwahl Datum WoBre 3076 8.9.2025 CO2-Markt und CO2-Infrastruktur in der EU Sehr geehrte Damen und…

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

An effective TEN-E Regulation is a crucial component for achieving climate neutrality by 2050 and for the success of the energy transition. The basic requirement for this is that energy infrastructure projects can be implemented more quickly and easily.

The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative of the European Commission to revise the regulatory framework for energy infrastructure, including the Regulation (EU) No 347/2013 on guidelines for trans-European energy infrastructure ("TEN-E Regulation"). A consistency with the 2050 climate neutrality in the context of the European Green Deal must be ensured.

The Austrian Chamber of Commerce would like to make the following comments on the text of the Inception Impact Assessment concerning the update of EU legislation on urban waste water treatment: • Eutrophication After almost 30 years of transposition of the Directive, there are still agglomerations in the EU that are insufficiently connected to urban waste water systems.

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We welcome that the Communication of the EC (COM/2026/615 final) explicitly recognises the need to strengthen competitiveness while preserving and supporting the diverse structures of banking across the EU. In this context, it is essential that the regulatory and supervisory framework continues to acknowledge the specific role of all legal forms, including cooperatives and savings banks, where decentralised…

WKÖ supports the European Green Deal and stands by the climate neutrality goal by 2050. Now a concrete set of measures for a sustainable, ecological change in the EU, in line with a new growth strategy, is necessary. WKÖ will contribute to a legislative package that meets the requirements of effective climate protection and at the same time is practicable and compatible with economic prosperity.

The Austrian Federal Economic Chamber (WKÖ) welcomes the initiative of the European Commission (EC) to promote the reduction of methane emissions throughout the EU. In Austria, methane (CH4) is the second most relevant greenhouse gas with a share of 8.0 % in 2017. At the same time, methane emissions were reduced by 36.3 % between 1990 and 2017 (source: Umweltbundesamt: Klimaschutzbericht 2019).

Contribution of the Austrian Federal Economic Chamber (WKO) on the call for evidence regarding the planned EU legislative act on the European Research Area (ERA Act) 1. General assessment of the initiative The Austrian Federal Economic Chamber (WKO) welcomes the initiative of the European Commission to strengthen Europes scientific and technological competitiveness through a binding legal framework for the European…

Konsultation zu CO2-Grenzwerten für PKW und leichte Nfz Sehr geehrte Damen und Herren, die Wirtschaftskammer Österreich nimmt zur gegenständlichen Konsultation wie folgt Stellung: 1. Allgemeines Die CO₂-Flottenziele der EU für 2030 und das geplante Verbot von Verbrennungsmotoren 2035 sind zentrale Säulen der Klimapolitik der EU. Doch seit der Festlegung dieser Ziele hat sich die Welt verändert.

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

Digitalisation offers significant opportunities to improve efficiency and sustainability in the water sector. Speeding up implementation is therefore to be welcomed in principle. However, this requires a structured roll-out, taking into account technical, economic and organisational circumstances.

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The Austrian Federal Economic Chamber welcomes the European Commission's initiative to establish harmonized, EU-wide end-of-waste (EoW) criteria for plastic waste in accordance with Article 6(2) of the Waste Framework Directive and appreciate the opportunity to provide feedback aimed at further enhancing their clarity, practicality, and harmonised implementation in the EU.

In general, the Austrian Federal Economic Chamber sees the EU initiative to reform the electricity market design positive. Although, our market design has worked well in the past and has yielded low energy prices for the final customers, it has shown its limitations in the current energy crisis.

Rechtsakt für hochwertige Arbeitsplätze – Aufforderung zur Stellungnahme zur Folgenabschätzung Die Wirtschaftskammer Österreich nimmt die Aufforderung der Europäischen Kommission zur Stellungnahme zur Folgenabschätzung für den geplanten Rechtsakt für hochwertige Arbeitsplätze zum Anlass, die Perspektive der Unternehmen einzubringen. Die WKÖ bekennt sich klar zu hochwertigen, sicheren und fairen Arbeitsplätzen.

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

The Austrian Chamber of Commerce welcomes the European Commission’s efforts to evaluate the cosmetics regulatory framework in order to allow for further development. The current legal framework provides the basis for a high quality of cosmetic products and thus also for the protection of consumers.

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FEEDBACK FROM THE AUSTRIAN FEDERAL ECONOMIC CHAMBER: In response to Russia's war on Ukraine and the resulting need for increased defence spending, the EU seeks to also prioritize targeted research into dual-use technologies such as drones and GPS, which deliberately allows for both civilian and military applications, driving defence capabilities and technological innovation to enhance European competitiveness.

The Austrian Federal Economic Chamber would like to thank you for the opportunity to comment on the draft delegated act. We welcome the European Commission’s objective to add certain non-hazardous wastes to the Green List of the EU Waste Shipment Regulation in order to facilitate and speed up their transport within the EU for recovery purposes.

Filed in German · English published by the European Commission

The Austrian Chamber of Commerce supports the climate objectives of the European Union. The WKÖ will promote legislation that meets the requirements of effective climate protection while being practicable and compatible with economic prosperity. Please find attached our detailed position paper on the proposal for a regulation on the proposed regulation on the reduction of CO2 emissions from heavy-duty vehicles.

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Site relevance is high The site relevance of the Air Quality Directive, which has been revised for the first time since 2008 and is being developed in the direction of the most recent extremely stringent WHO recommendations of September 2021, is high. Where exceedances occur permanently, there is considerable pressure on the Länder governments to define air remediation areas in accordance with the IG-L.

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Austrian Federal Economic Chamber (WKO) feedback on IIA - revision of AAQDs – EC air quality roadmap: We encourage the Commission to avoid, prevent or reduce harmful effects of poor air quality on human health and the environment. To substantially improve enforcement of the AAQDs, we recommend a change of strategy for “full effectiveness” in air quality policy.

Dear Sir, Madam, The Austrian Chamber of Commerce (WKO) thanks for the opportunity to comment on the draft delegated act on Article 31a(2) of Directive 2018/2001 on improving the traceability of data throughout the supply chain and asks for the considerations set out in the Annex to be taken into account.

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Position Paper 4 Omnibus Package Small Mid-Cap Enterprises and Digitalisation th July 2025 GENERAL COMMENTS From the point of view of the Austrian Federal Economic Chamber (WKÖ), a tangible simplification and reduction of the administrative burden of EU legislation for all companies must be achieved quickly in order to strengthen Europe's competitiveness.

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

Austria has a perfect private audit system — must be maintained. Coordinate type approval and tests — ECSS system Switch intervalves at the same time Access to data shall be free of charge and easily accessible to all. New propulsion systems!!!

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The Austrian Federal Economic Chamber recognizes the importance of standardization regarding electrical-vehicle charging infrastructure, hydrogen refilling infrastructure and smart electricity and gas meters. In order to keep costs as low as possible and legal certainty as high as possible for economic operators, the regulations should only apply to new systems.

The Austrian Federal Economic Chamber recognizes the importance of standardization regarding electrical-vehicle charging infrastructure, hydrogen refilling infrastructure and smart electricity and gas meters. In our opinion therefore it would be essential for such an undertaking to carry out a valid impact assessment in advance to present the possible effects for all stakeholders.

Stellungnahme zum Vorschlag für eine „EU-Verordnung über die allgemeine Produktsicherheit“ COM (2021) 346 final 1. Allgemeines Auch wenn mit den bestehenden Regelungen zur allgemeinen Produktsicherheit (Richtlinie 2001/95/EG, Produktsicherheitsgesetz) und deren Anwendung ein gutes Niveau betreffend die Sicherheit nicht harmonisierter Produkte gewährleistet werden konnte, ist die Initiative der Kommission aus…

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

In principle, we welcome the important step taken by the European Commission to combat child abuse. In order to combat such acts in a sustainable manner, the provider considers it necessary to focus on the principle of ‘erasure rather than blocking’.

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Dear Sir/Madam, 1. The WKÖ warmly welcomes the abolition of the minimum holding ratio for interest, royalties and dividends. We also urge harmonisation of withholding tax relief procedures, evidence requirements and forms within the EU. In addition, in the interests of the location of the business, provision should be made for a much earlier application than that on 1 January 2037. 2.

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The Austrian Economic Chamber (WKÖ) represents the interests of more than 590.000 member companies. As part of this consultation, the WKÖ responds to the concerns of its members and advocates a workable, competitive and low-bureaucratic framework.

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Streamlining and optimising public administration structures is always a useful approach. Particularly in the area of chemicals legislation, it is very good to do so. We fully agree on the need to use existing resources more efficiently. Optimising cooperation between EU and national authorities is crucial for savings. Synergies and overlaps need to be clearly identified.

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In our view, it is clear that ECHA’s workload is increasing and that this effort must be financed. However, more centralisation of tasks within an agency should be carried out where necessary and appropriate. Consequently, this should go hand in hand with greater efficiency and resource savings. Resources committed in the previously responsible bodies should also be freed up.

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In general, a revision of Euro 6 and VI standards into new Euro 7 and VII in the near future seems far too early – especially from the point of view of the most relevant sector, the automobile industry. Some important implementation steps of Euro 6 (f.e.

The proposal to amend the existing EU Aarhus Regulation (1367/EC/2006) aims at extending the rights to seek administrative review of administrative acts of EU institutions (delegated acts, implementing acts and decisions) for environmental NGOs: - Extension to "general acts": While currently a review procedure can only be requested for acts of "individual scope" (this means for acts directly addressed to a legal…

Austrian Federal Economic Chamber (WKO) – 02/04/2020 Aarhus Convention in the area of access to justice in environmental matters Aarhus-Roadmap [Ref. Ares(2020)1406501 - 06/03/2020] on Aarhus Regulation 1367/2006 From the point of view of the Austrian Federal Economic Chamber (WKO), the mandatory representation of 550,000 Austrian companies, a future consultation on access to justice referring to EU institutions…

Position Paper 4 Omnibus Package Small Mid-Cap Enterprises and Digitalisation th July 2025 GENERAL COMMENTS From the point of view of the Austrian Federal Economic Chamber (WKÖ), a tangible simplification and reduction of the administrative burden of EU legislation for all companies must be achieved quickly in order to strengthen Europe's competitiveness.

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

— Simplification of the label is absolutely necessary, as information on chemical labels is currently overcrowded. Information on the label shall be limited to the most essential information (e.g. CLP marking). Other information (e.g. additional label elements due to specific rules) should be made available digitally.

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The Austrian Federal Economic Chamber welcomes the European Commission's initiative on harmonized labeling requirements for all battery categories based on Articles 7(2) and 13 of the EU Battery Regulation (EU 2023/1542) and appreciates the opportunity to comment on it. Article 1(2) of the draft specifies how to proceed if the surface of the battery is not large enough to affix a label.

Es wurden keine grundsätzlichen Bedenken gegen die Funktionalität der Regelungen des Entwurfs rückgemeldet. Dennoch sind die Unternehmen in einigen Punkten zu weitgehend eingeschränkt und es dürfte der mögliche Sitzwechsel von CBAM-Anmeldern in einen anderen EU-Mitgliedstaat nicht bedacht worden sein.

The Austrian Federal Economic Chamber (WKÖ) welcomes the European Union’s initiative to simplify legislation on energy-efficient products. The need for these measures cannot be overestimated, as regulatory barriers and administrative burdens remain by far the biggest challenge for 64 % of EU SMEs. With more than 80 % of SMEs, this also applies to the members of the WKÖ.

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Positionspapier zur Konsultation betreffend die Verwendung von nicht ökologischem Eiweißfutter in der biologischen Produktion Die Wirtschaftskammer Österreich unterstützt den Vorschlag der Europäischen Kommission, die derzeit in Anhang II, Teil II, Punkt 1.9.3.1(c) und Punkt 1.9.4.2(c), Verordnung (EU) 2018/848 vorgesehene Ausnahmeregelung für Ferkel und Junggeflügel um 10 Jahre bis zum 31.12.2036 zu verlängern.

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

The Austrian Federal Economic Chamber (WKÖ) strongly supports a more effective and result-oriented implementation of EU funds within the next Multiannual Financial Framework (MFF 20282034). Sound management of public resources is essential to strengthen the EUs competitiveness and to ensure that every euro spent delivers measurable European added value.

Sondierung: Fahrplan für hochwertige Arbeitsplätze Aus Sicht der Wirtschaftskammer Österreich ist jeder Arbeitsplatz, der in Europa von einem wettbewerbsfähigen Unternehmen geschaffen wird, ein „hochwertiger Arbeitsplatz“ und erhöht die Produktivität.

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

In principle, we welcome the facilitation of innovative services in the transport sector. It is important, however, that the vehicle owner always has an easy to implement, clearly communicated and traceable OPT-OUT. In this context, we are also engaged in intensive exchanges with our European umbrella and sister associations (e.g.

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WKÖ Draft Input on Roadmaps for revised OELs for lead and diisocyanates We welcome the opportunity to voice our opinion and concerns on the occasion of the call for evidence for an impact assessment on a proposal for a Directive on protecting workers from exposure to chemicals (lead and di-isocyanates).

The Austrian Federal Economic Chamber (WKÖ1) is committed to the goal of reducing the gender pay gap. However, we are expressly opposed to mandatory pay reporting at European level. Austria has already introduced pay reporting for companies with more than 150 employees, which has resulted in a considerable additional administrative burden for these companies, as the preparation of such reporting has had to be…

Bodies dealing with the EHDS should pay attention to the protection of trade secrets and promote research with the built-up data base in the least burdensome way. In this sense, the last sentence of Article 8 should be strengthened: Should EHDS Board members, invited experts and observers fail to respect these obligations, the Commission MUST take all appropriate measures.

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The Austrian Economic Chamber sees the PRTR revision as a unique opportunity to make EU environmental reporting obligations more meaningful and more targeted: • Yes to “improving coherence with related legislation in particular IED, water and waste legislation” in the sense of “data once only” and uniform, simple and harmonised EU standards for reporting obligations.

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WKÖ Draft Input on Roadmap for revised OEL for asbestos We welcome the opportunity to voice our opinion and concerns on the occasion of the call for evidence for an impact assessment on a proposal for a Directive on protecting workers from asbestos exposure.

The Austrian Federal Economic Chamber thanks for the opportunity to comment on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and of the Council as regards the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles.The full commentary on the drafted Decision is attached.

Wirtschaftskammer Österreich (Austrian Federal Economic Chamber) welcomes all initiatives to improve access to finance for companies, esp. for SMEs. Financing needs and preferences differ depending on the individual situation of a business. A broad choice of financing means incl. internal finance are therefore important.

Austrian Federal Economic Chamber (WKO) on Aarhus Convention in the area of access to justice in environmental matters Aarhus-Roadmap on Aarhus Regulation 1367/2006 From the point of view of the Austrian Federal Economic Chamber (WKO), the mandatory representation of 500,000 Austrian companies, a future consultation on access to justice referring to EU institutions should not extend the scope of the Aarhus…

The promotion of increased and faster provision of affordable, sustainable and decent housing in the EU is in principle welcome and supported. However, it cannot be achieved by weakening the standards and rules in force in the Member States.

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The Austrian Federal Economic Chamber has repeatedly stated that administrative burdens act as a barrier to businesses whose international competitiveness and, more generally, the functioning of the internal market. We warmly welcome the 25 % reduction in reporting requirements for businesses and 35 % for SMEs, as set out in the Commission’s programme.

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Ladies and gentlemen, we would like to respond to the invitation to comment on the document on consumer rights adaptation of out-of-court dispute resolution to digital markets: As a preliminary point, it is necessary to counter the rather negative picture in the invitation to submit comments: In the vast majority of cases, consumer transactions work perfectly smoothly.

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The Austrian Chamber of Commerce (WKÖ) welcomes the progress of the EU Talent Pool. This corresponds to a long-standing demand for WKÖ and is urgently needed due to the sharply increasing labour shortages in Austria and Europe. Only by promoting the European workplace and actively attracting specialists can the EU be established in the international community.

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In general, the Austrian Federal Economic Chamber sees the EU initiative to reform the electricity market design positive. Although, our market design has worked well in the past and has yielded low energy prices for the final customers, it has shown its limitations in the current energy crisis.

Abteilung Europapolitik Wiedner [address removed] T [phone removed] | F [phone removed] E [email removed] W http://wko.at/eu Statement of the Austrian Federal Economic Chamber (WKÖ) Proposal for a new regulation on the screening of foreign investments The intention of the European Commission (EC) to strengthen the economic security of the European economy is to be welcomed.

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

Dear Sir or Madam, the Austrian Federal Economic Chamber welcomes the proposal in so far as it makes it clear that the principle of reciprocity under international law must also be observed in respect of the copyright remuneration of performers and phonogram producers. This corresponds to the current legal situation in Austria.

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In essence, the EC presents the proposal for UAP8 Governance instrument in the form of a decision by the Council and the EP: Legislative procedures. Content is different from UAP7 (ending (2020) which contains, in addition to the Decision, an extensive substantive annex, none will be profiled in this supplement.

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Dear Ladies and Gentlemen, the The Austrian Federal Economic Chamber comments on the Proposal for a Directive on combating corruption [COM(2023) 234] as enclosed. We kindly ask to take our comments into account. Yours sincerely Dr. [name removed] Head of Department

With regard to the present invitation to submit comments on an initiative (anti-corruption rules updated in the EU), it should be noted at the outset that it is unclear why two requests for comments have been issued at the same time on the same subject [i.e. also on Ares(2023)452845]. It is undisputed that corruption harms society and the economy.

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Feedback will be provided in consultation with the Civil Security Working Group (ARGE Civilian Security): • Deactivated weapons, acoustic weapons and alarm and signal weapons (pyrotechnic weapons) are not firearms used against living organisms. They are therefore, for good reason, not taken into account in the scope of the Firearms Regulation.

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The Austrian Federal Economic Chamber is the legal representative of all persons and other legal entities operating independently in Austria in the field of trade, crafts, industry, mining, commerce, money, credit and insurance, transport, news, broadcasting, tourism and leisure activities and other services.

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Sparte Industrie Wirtschaftskammer Österreich Wiedner Hauptstraße 63 | Postfach 330 1045 Wien T [phone removed] E [email removed] W wko.at/industrie Von Bundessparte Industrie WKÖ An EU-Kommission Ihr Zeichen, Ihre Nachricht vom Unser Zeichen/Sachbearbeiter Durchwahl Datum WoBre 3076 12.8.2026 Entwurf der Verordnung: Finanzielle Kompensation für nicht vom ETS 2 umfasste Emissionen (DRAFT Implementing Regulation (EU)…

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

We suggest that the concept of average expected activity level and the associated changes in the Annex (which is now Annex I) and in Article 5 should not be added to the ALCR. This new rule seems not be legally mandated but adds considerable complexity.

The Austrian Federal Economic Chamber (WKÖ) recognizes a secure and stable energy supply as an essential prerequisite of a thriving economy. National gas storage facilities herby play an essential role. However, affordability and the fair sharing of (financial) burdens have to be equally considered. In this context we would like to comment on the proposed regulation.

The purpose of this draft is to create the technical conditions for smart tachograph 2 to be able to provide proof of occasional transport digitally in the future. It is crucial that this creates all the conditions to make the EU Green Driving Licence obsolete. This bureaucratic burden on businesses should be removed as soon as possible.

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Our opinion (attached as PDF) provides information on the following areas related to the UTC for PCBs: Recycling; — Manufacture of cables; Organic pigments; Analytics. We would like to point out some of the necessary adjustments to the UTC, as it is not feasible for selected areas in its current form.

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In principle, we see it as a positive approach that the new proposal for a Directive allows vehicles to be classified in a more favourable tariff category for distance-based tolls. The inclusion of trailers and semi-trailers in the assessment of the CO2 class could provide incentives for the market uptake and market uptake of more energy efficient trailers and semi-trailers, as well as for the use of more energy…

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Ladies and gentlemen, we would like to respond to the invitation to provide an opinion on the impact assessment on consumer protection. The level of consumer protection in the Union is already extremely high. Further burdens on the economy are strongly rejected; this is particularly important in view of the current extraordinary challenges faced by businesses.

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