03 / 06 / 2021

EARTO Response to EC Consultation on the Revised Framework for State Aid RD&I

To answer the European Commission’s public consultation on the review of the Communication on the Framework for State aid for Research, Development and Innovation (RD&I), EARTO has analysed the draft revised RD&I Framework Communication, and would like to bring forward the following comments and recommendations:  
  1. EARTO welcomes the proposed continuity with the current provisions: the rules to distinguish economic from non-economic activities are efficient. However, their national/regional interpretation needs to be improved, to ensure that they do not hamper Europe’s innovation capacity. In addition, Research and Technology Organisations (RTOs) should be considered by default as Research and Knowledge Dissemination Organisations (RKDOs), and not as “undertakings” under the RD&I Framework definitions. RTOs should therefore be able to have their 100% full costs covered in national/regional RD&I competitive programmes funded by national public bodies.
  2. The new concept of “technology infrastructures” (TIs) is welcome. However, the definition and conditions proposed are not aligned with the reality of RD&I ecosystems. TIs are managed and used by non-profit research organisations mainly in “effective collaboration” with other RKDOs and private companies, including SMEs (mainly non-economic activities with ancillary economic activities). However, the EC proposed definition for TIs rather addresses “Pre-production Demonstration Infrastructures” with mainly economic activities, and should therefore be relabelled as such. In addition, the EC proposal creates a gap between Research Infrastructures (RIs) and TIs, where a continuum is required. TIs should be clearly included into the current definition of RIs and mentioned under the scope of section 2.1 of the RD&I Framework.
  3. The rules of pre-commercial procurements need to be simplified to boost Europe’s innovation capacity. There should be only one single call for tender covering both the RD&I phase and the manufacturing phase. This would first make the administrative process easier, but it would also increase the incentive for RD&I providers (incl. SMEs) to take part in the RD&I phase since they would be assured to get an opportunity to bring their innovation to the market.
  EARTO remains at the disposal of the EU Institutions to further discuss these recommendations and support the EC in its work to revise the European State Aid RD&I rules.   Read the full EARTO paper for more details on EARTO’s position on these three key points, along with detailed text changes suggestions.