Follow-up paper

1

Friends of Industry 2026

Joint statement on strengthening the competitiveness of European industry by the Ministers of Industry of Austria, Croatia, Czech Republic, France, Germany, Italy, Luxembourg, Poland, Portugal, Slovakia, Spain

This paper builds on the Berlin Declaration. The positions outlined in the Berlin Declaration

are supported by the signatories.

In the Berlin Declaration, we underlined the need for a strong industry for a strong

Europe. This is becoming even more important and urgent in the current geopolitical

situation. To provide a stimulus for growth, innovation, competitiveness and to enhance

our own defence-oriented production capabilities, we need to improve the business

environment. We note with growing concern that, despite the commitment to simplify

and ease the regulatory burden, numerous additional legislative instruments are being

prepared or have already been proposed by the European Commission. Instead of this, in

order to truly support European industry, a strong commitment to better regulation

should be put into practice, ensuring that new initiatives are necessary, proportionate,

coherent and implementable, while systematically assessing their cumulative impact on

industrial value chains. We therefore re-emphasise that co-legislators should internalise a

new legislative mindset that reflects a strong commitment to better regulation in all

legislative activities, starting when the Commission exercises its right of initiative,

throughout the negotiation process, and subsequently in the establishment of delegated

and implementing acts. New legislation should be introduced only to those cases where

there is a clear European added value and designed in a simple, coherent and investment-

friendly manner.

Companies need planning security for investment, a level playing-field, affordable

electricity prices and space in which to innovate. To foster investment in Europe, we need

a clear and predictable legislative framework, with simpler rules for the industrial sector.

Regulatory aspects affecting industry should be addressed through a coherent framework

with harmonised procedures, consolidated guidance and clear interfaces between

instruments. The fact that many topics are addressed concurrently in different existing

and upcoming legislative instruments entails many challenges for economic actors, and

also for public administrations and implementing bodies (e.g. there are more than 80

sectoral legal instruments that contain rules on public procurement; currently, the

environmental Omnibus, the IAA and the NZIA all aim at accelerating permitting in the

industrial sector, with different rules for different sectors).

2

In this regard, the currently discussed legislative instruments, like automotive package

and the Industrial Accelerator Act as well as the revision of the CBAM and the future

revision of ETS, shall focus on eliminating all non-necessary burdens on industry, thus

promoting their competitiveness.

We have reached a point where even the legislators seem unable to grasp all the different rules in the various legislative instruments. Such simplification should focus on eliminating overlaps and contradictions, while preserving necessary sector-specific requirements related to safety, cybersecurity and security of supply; without undermining predictability, policy goals, high standards and the integrity of the Single Market. The consequence is a high level of bureaucracy for companies and authorities which have to monitor compliance with all these rules, some of which are actually contradictory. Additionally, there is the risk of unnecessary delays of approvals as sectoral legislative acts often involve separate, additional documentation requirements. European industry needs the opposite: true acceleration of approval procedures through substantive simplification.

We call for:

• A new legislative mindset that reflects a strong commitment to better regulation as a proactive approach from outset of every legislative proposal,

• true substantive simplification within existing legislation, e.g. by means of Omnibuses, and also in necessary new legislation, which should be designed in a simple and unbureaucratic way,

• Horizontal issues should be addressed via a central legislative act. If this is not possible consistency and convergence of sector-specific case by case regulation needs to be ensured for instance in the area of public procurement.

• strengthening of legislative discontinuity in line with the treaty, whereby unfinished legislative proposals at the first reading stage between the co-legislators, where no agreement is in sight, are not automatically carried over in the next legislative period.

• Bridging the gap between public & private sectors through a constant communication with representative industrial stakeholders and assuring a high grade of transparency in the process of designing and adoption of new regulatory framework or new initiatives with impact on industrial competitiveness of the member states.

• An Industrial Accelerator Act that delivers substantial acceleration and simplification for industrial projects, ensures legal certainty and avoids unnecessary administrative burdens, while strengthening Europe’s industrial value chains, supporting SMEs and enhancing investment and strategic autonomy within the Single Market.

3

To achieve our common goal of a stronger, more resilient and more competitive Europe,

we will need to create a policy environment in which both digitalisation and

decarbonisation of industry can become a realistic and successful business case along the

entire industrial value chain. Therefore, measures should reflect more the needs of and

the current competitive situation facing industry. For example, industrial AI (artificial

intelligence) can be a strong European asset, especially since European industry owns its

data and is already aiming to utilise it to strengthen its competitiveness. Therefore, we

need a coherent legislative framework for the digital transformation regarding Business

to Business relation in the industry. The development of interoperable, sovereign and

trusted data ecosystems in Europe is a key to the shared use of high-quality and sensitive

data across companies, e.g. for innovative services and AI applications. If this does not

happen, innovative business models will not be realised in Europe due to the high level of

government intervention and regulation.

Decarbonisation should not be achieved by deindustrialisation. The decarbonisation of

the industry can be a successful business case, as long as the regulatory framework

reflects the international competition that European companies face and takes into

account the necessity for a level playing field. Thus, emission reduction in industry

should be achieved as cost-efficiently as possible. In this spirit, the upcoming ETS

revision should strive to support the competitiveness of European industry, and enhance

investments in innovative technologies. Given the decline in the EU-wide emissions cap,

industrial actors face the risk of high price levels, increased market volatility and limited

liquidity. Notably, investments in necessary enabling conditions for decarbonisation

must be increased and there is a need for targeted carbon leakage protection. At the same

time, predictability and regulatory stability is key to avoid market volatility and

damaging the functioning of the ETS. The upcoming revision should therefore ensure

effective price signal, market stability, predictability and sufficient liquidity, a pragmatic

and investment-compatible approach to free allocation that fosters investments in

climate-friendly technologies and is fully coherent with CBAM, while safeguarding the

European industrial base.

We call for:

• A proportionate, risk-based and innovation-friendly implementation of industrial AI rules, supported by clear guidance, harmonised de-facto standards, conformity rules and realistic timelines. Especially a clarification of the interplay between the AI Act and the Machinery Regulation the course of the AI-Omnibus, is necessary,

• Realistic implementing deadlines for industrial AI in the AI Act that give companies enough time to implement the rules based on the guidelines and standards which are delayed, as overshooting requirements for innovative companies will drive them out of the EU,

• An ETS revision that enhances EU competitiveness by ensuring an effective price signal, predictability, market stability and protection against excessive price volatility, together with a pragmatic approach to free allocation that fosters investments in climate-friendly technologies and provides robust safeguards against carbon leakage.

1

Friends of Industry 2026

Joint statement on strengthening the competitiveness of European industry by the Ministers of Industry of Austria, Croatia, Czech Republic, France, Germany, Italy, Luxembourg, Poland, Portugal, Slovakia, Spain

This paper builds on the Berlin Declaration. The positions outlined in the Berlin Declaration

are supported by the signatories.

In the Berlin Declaration, we underlined the need for a strong industry for a strong

Europe. This is becoming even more important and urgent in the current geopolitical

situation. To provide a stimulus for growth, innovation, competitiveness and to enhance

our own defence-oriented production capabilities, we need to improve the business

environment. We note with growing concern that, despite the commitment to simplify

and ease the regulatory burden, numerous additional legislative instruments are being

prepared or have already been proposed by the European Commission. Instead of this, in

order to truly support European industry, a strong commitment to better regulation

should be put into practice, ensuring that new initiatives are necessary, proportionate,

coherent and implementable, while systematically assessing their cumulative impact on

industrial value chains. We therefore re-emphasise that co-legislators should internalise a

new legislative mindset that reflects a strong commitment to better regulation in all

legislative activities, starting when the Commission exercises its right of initiative,

throughout the negotiation process, and subsequently in the establishment of delegated

and implementing acts. New legislation should be introduced only to those cases where

there is a clear European added value and designed in a simple, coherent and investment-

friendly manner.

Companies need planning security for investment, a level playing-field, affordable

electricity prices and space in which to innovate. To foster investment in Europe, we need

a clear and predictable legislative framework, with simpler rules for the industrial sector.

Regulatory aspects affecting industry should be addressed through a coherent framework

with harmonised procedures, consolidated guidance and clear interfaces between

instruments. The fact that many topics are addressed concurrently in different existing

and upcoming legislative instruments entails many challenges for economic actors, and

also for public administrations and implementing bodies (e.g. there are more than 80

sectoral legal instruments that contain rules on public procurement; currently, the

environmental Omnibus, the IAA and the NZIA all aim at accelerating permitting in the

industrial sector, with different rules for different sectors).

2

In this regard, the currently discussed legislative instruments, like automotive package

and the Industrial Accelerator Act as well as the revision of the CBAM and the future

revision of ETS, shall focus on eliminating all non-necessary burdens on industry, thus

promoting their competitiveness.

We have reached a point where even the legislators seem unable to grasp all the different rules in the various legislative instruments. Such simplification should focus on eliminating overlaps and contradictions, while preserving necessary sector-specific requirements related to safety, cybersecurity and security of supply; without undermining predictability, policy goals, high standards and the integrity of the Single Market. The consequence is a high level of bureaucracy for companies and authorities which have to monitor compliance with all these rules, some of which are actually contradictory. Additionally, there is the risk of unnecessary delays of approvals as sectoral legislative acts often involve separate, additional documentation requirements. European industry needs the opposite: true acceleration of approval procedures through substantive simplification.

We call for:

• A new legislative mindset that reflects a strong commitment to better regulation as a proactive approach from outset of every legislative proposal,

• true substantive simplification within existing legislation, e.g. by means of Omnibuses, and also in necessary new legislation, which should be designed in a simple and unbureaucratic way,

• Horizontal issues should be addressed via a central legislative act. If this is not possible consistency and convergence of sector-specific case by case regulation needs to be ensured for instance in the area of public procurement.

• strengthening of legislative discontinuity in line with the treaty, whereby unfinished legislative proposals at the first reading stage between the co-legislators, where no agreement is in sight, are not automatically carried over in the next legislative period.

• Bridging the gap between public & private sectors through a constant communication with representative industrial stakeholders and assuring a high grade of transparency in the process of designing and adoption of new regulatory framework or new initiatives with impact on industrial competitiveness of the member states.

• An Industrial Accelerator Act that delivers substantial acceleration and simplification for industrial projects, ensures legal certainty and avoids unnecessary administrative burdens, while strengthening Europe’s industrial value chains, supporting SMEs and enhancing investment and strategic autonomy within the Single Market.

3

To achieve our common goal of a stronger, more resilient and more competitive Europe,

we will need to create a policy environment in which both digitalisation and

decarbonisation of industry can become a realistic and successful business case along the

entire industrial value chain. Therefore, measures should reflect more the needs of and

the current competitive situation facing industry. For example, industrial AI (artificial

intelligence) can be a strong European asset, especially since European industry owns its

data and is already aiming to utilise it to strengthen its competitiveness. Therefore, we

need a coherent legislative framework for the digital transformation regarding Business

to Business relation in the industry. The development of interoperable, sovereign and

trusted data ecosystems in Europe is a key to the shared use of high-quality and sensitive

data across companies, e.g. for innovative services and AI applications. If this does not

happen, innovative business models will not be realised in Europe due to the high level of

government intervention and regulation.

Decarbonisation should not be achieved by deindustrialisation. The decarbonisation of

the industry can be a successful business case, as long as the regulatory framework

reflects the international competition that European companies face and takes into

account the necessity for a level playing field. Thus, emission reduction in industry

should be achieved as cost-efficiently as possible. In this spirit, the upcoming ETS

revision should strive to support the competitiveness of European industry, and enhance

investments in innovative technologies. Given the decline in the EU-wide emissions cap,

industrial actors face the risk of high price levels, increased market volatility and limited

liquidity. Notably, investments in necessary enabling conditions for decarbonisation

must be increased and there is a need for targeted carbon leakage protection. At the same

time, predictability and regulatory stability is key to avoid market volatility and

damaging the functioning of the ETS. The upcoming revision should therefore ensure

effective price signal, market stability, predictability and sufficient liquidity, a pragmatic

and investment-compatible approach to free allocation that fosters investments in

climate-friendly technologies and is fully coherent with CBAM, while safeguarding the

European industrial base.

We call for:

• A proportionate, risk-based and innovation-friendly implementation of industrial AI rules, supported by clear guidance, harmonised de-facto standards, conformity rules and realistic timelines. Especially a clarification of the interplay between the AI Act and the Machinery Regulation the course of the AI-Omnibus, is necessary,

• Realistic implementing deadlines for industrial AI in the AI Act that give companies enough time to implement the rules based on the guidelines and standards which are delayed, as overshooting requirements for innovative companies will drive them out of the EU,

• An ETS revision that enhances EU competitiveness by ensuring an effective price signal, predictability, market stability and protection against excessive price volatility, together with a pragmatic approach to free allocation that fosters investments in climate-friendly technologies and provides robust safeguards against carbon leakage.