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Position Paper on draft Implementing Decision laying down rules for the application of Directive (EU) 2019/904

June 2021 – We, the undersigned stakeholders comprising NGOs, industry and civil society, welcome the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 of the SUPD. However, we call on the European Commission and national authorities to provide more clarification of certain provisions of the draft Decision which, in their current format, would significantly undermine the intent of the Directive. This position paper lays out our recommendations for the Commission.

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